Opinion
2:20-cv-02042-KJD-NJK
10-11-2022
XIAO YE BAI, Petitioner, v. STATE OF NEVADA, et al., Respondent(s).
AARON D. FORD ATTORNEY GENERAL JAIMIE STILZ (BAR NO. 13772) DEPUTY ATTORNEY GENERAL STATE OF NEVADA OFFICE OF THE ATTORNEY GENERAL ATTORNEYS FOR RESPONDENTS RON Y. SUNG ASSISTANT FEDERAL PUBLIC DEFENDER C. MARTINEZ AN EMPLOYEE OF THE OFFICE OF THE ATTORNEY GENERAL
AARON D. FORD
ATTORNEY GENERAL
JAIMIE STILZ (BAR NO. 13772)
DEPUTY ATTORNEY GENERAL
STATE OF NEVADA
OFFICE OF THE ATTORNEY GENERAL
ATTORNEYS FOR RESPONDENTS
RON Y. SUNG ASSISTANT FEDERAL PUBLIC DEFENDER
C. MARTINEZ AN EMPLOYEE OF THE OFFICE OF THE ATTORNEY GENERAL
UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER TO SECOND AMENDED PETITION FOR WRIT OF HABEAS CORPUS (ECF NO. 24) (SECOND REQUEST)
Respondents move this Court for an enlargement of time of 60 days from the current due date of October 7, 2022, up to and including December 6, 2022, in which to file their Answer to Second Amended Petition for Writ of Habeas Corpus (ECF No. 24). This Motion is made pursuant to Fed.R.Civ.P. 6(b) and Rule 6-1 of the Local Rules of Practice and is based upon the attached declaration of counsel. This is the second enlargement of time sought by Respondents, and the request is brought in good faith and not for the purpose of delay.
DECLARATION OF JAIMIE STILZ
I, JAIMIE STILZ, being first duly sworn under oath, depose and state as follows:
1. I am an attorney licensed to practice law in all courts within the State of Nevada, and am employed as a Deputy Attorney General in the Office of the Nevada Attorney General. I am assigned to represent Respondents in Xiao Ye Bai v. State of Nevada, et al., Case No. 2:20-cv-02042-KJD-NJK, and as such, have personal knowledge of the matters contained herein.
2. This is my second request for an extension to file the Answer to the Second Amended Petition for Writ of Habeas Corpus (ECF No. 24), and this Motion is made in good faith and not for the purpose of delay.
3. The Answer is currently due on October 7, 2022.
4. I am unable with due diligence to timely complete the Answer herein. I am still attempting to manage ongoing medical/health issues. I am also managing a significant workload that has recently expanded due to a senior supervising colleague leaving the office, and the assignment of two upcoming oral arguments in the Ninth Circuit. I have been diligently striving to resolve and/or work around these issues but they have significantly impacted my ability to complete the Answer in a timely fashion, thus necessitating an extension.
5. In seeking this extension, I am taking into consideration additional obligations and deadlines for both myself and my new supervising senior colleague.
6. I have spoken to counsel for Bai, and he does not oppose this request.
7. Based on the foregoing, I respectfully request an enlargement of time of 60 days, up to and including December 6, 2022, to file the Answer to the Second Amended Petition for Writ of Habeas Corpus (ECF No. 24).
I declare under penalty of perjury that the foregoing is true and correct.
IT IS SO ORDERED: