Free Motion for Extension of Time - District Court of Arizona - Arizona

TERRY GODDARD ATTORNEY GENERAL (FIRM STATE BAR NO. 14000) KATIA MÉHU ASSISTANT ATTORNEY GENERAL CRIMINAL APPEALS SECTION
1275 WEST WASHINGTON PHOENIX, ARIZONA 85007­2997 TELEPHONE: (602) 542­4686 (STATE BAR NUMBER 016992) E-MAIL: [email protected]

ATTORNEYS FOR RESPONDENTS

UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
RICHARD FARRALL, JR.,
Petitioner,

CV 04­00260­PHX­EHC MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION FOR EVIDENTIARY HEARING (First Request)

-vsDORA B. SCHRIRO, et al.,
Respondents.

Respondents respectfully request a first 60­day extension of time, until June 9, 2008, in which to respond to Petitioner's Motion for Evidentiary Hearing. The response is currently due on April 11, 2008. Undersigned counsel needs the additional time because Respondents have never addressed the merits of the claims raised in the Petition for Writ of Habeas Corpus and undersigned counsel requires additional time to analyze the issues raised therein and in the motion for evidentiary hearing.

Case 2:04-cv-00260-EHC-BPV

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Undersigned counsel notified opposing counsel, Justin Marceau, of her intent to seek an extension of time in this case, and was informed that Petitioner wishes that the matter proceed expeditiously. However,

undersigned counsel's inability to address the matter at the present time is due to her extremely heavy caseload, and her prior involvement in other appeals and legal matters assigned before this matter arose. Ninth Circuit Supplemental Brief in Ruiz v. Schriro, 05­ 16564, filed on April 1, 2008; Response to Motion to Expand Record in Pearce v. Schriro, CV­06­2841­PHX­WMM (JM), filed on April 4, 2008; Response to Court Order in Nardi v. Schriro, CV­01­1185­ PHX­EHC (LOA), filed on April 9, 2008; Answering Brief in State v. Romero, 1 CA­CR 07­0019, due on April 11, 2008; Answering Brief in State v. Gleason, 1 CA­CR 2007­0455, due on April 16, 2008; Answer to Petitioner's Petition for Writ of Habeas Corpus in Allen v. McDaniel, CV­07­1264­PHX­NVW (HCE), due on April 16, 2008; Answering Brief in State v. Karr, 1 CA­CR 07­0183, due on April 17, 2008; Answer to Petitioner's Petition for Writ of Habeas Corpus in Kanger v. Schriro, CV­07­8094­PCT­PGR (MHB), due on April 30, 2008;

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Answering Brief in State v. Dasher, 1 CA­CR 07­0836, due on May 2, 2008; Answer to Petitioner's Petition for Writ of Habeas Corpus in Conroy v. Fizer, CV­07­2474­PHX­FJM (DKD), due on May 5, 2008; and Ninth Circuit Answering Brief in Williams v. Schriro, 07­ 16810, due on May 14, 2008. DATED this 10th day of April, 2008. Respectfully submitted, Terry Goddard Attorney General (Firm State Bar No. 14000) s/Katia Méhu Assistant Attorney General Criminal Appeals Section 1275 West Washington Phoenix, Arizona 85007­2997 Telephone: (602) 542­4686 State Bar Number 016992

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I hereby certify that on this 10th day of April, 2008, I electronically transmitted the attached document to the Clerk's Office using the ECF System for filing and transmittal of a Notice of Electronic Filing to the following ECF registrant: Jon M. Sands Federal Public Defender Michael L. Burke Justin F. Marceau Assistant Federal Public Defenders Office of the Federal Public Defender 850 West Adams Street, Suite 201 Phoenix, Arizona 85007 Attorneys for Petitioner s/L. Lopez CRM01­1224 179747

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