Free Motion for Extension of Time to File - District Court of California - California

Case 3:08-cv-00853-WHA

Document 10

Filed 05/19/2008

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Michael S. Romano Attorney at Law State Bar No. 232182 523 Octavia Street San Francisco, CA 94102 Telephone: (415) 431-3472 Attorney for Petitioner Travell Brown

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 On February 7, 2008, Travell Brown filed a Petition for Habeas Corpus Relief, alleging various violations of his federal constitutional rights. On February 20, 2008, this Court issued an Order to Show Cause requesting briefing from Respondent. On March 20, 2008, Respondent's brief was filed. Petitioner's counsel is representing Petitioner pro bono. (See Order Denying Petitioner's Motion for Appointment of Counsel, February 21, 2008.)
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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Travell Brown, Petitioner, vs. Robert Horel, Warden, Respondent. ) ) ) ) ) ) ) ) ) ) Case No. 3:08-cv-00853-WHA STIPULATION RE: EXTENSION OF TIME TO FILE A TRAVERSE AND PROPOSED ORDER

Due to a continuing family medical circumstance, Petitioner's counsel is unable to file a Traverse by May 21 that adequately addresses Respondent's brief. 1 Petitioner therefore respectfully moves for a 45-day extension to file a Traverse to and including Monday, July 7, 2008. This is Petitioner's second (and final) extension request. Counsel for Respondent, Supervising Deputy Attorney General Peggy Ruffra, stipulates to the proposed extension. Dated: May 19, 2008 Respectfully submitted,

/s/ Peggy Ruffra Supervising Deputy Attorney General Attorney for Respondent

/s/ Michael S. Romano Attorney for Petitioner Travell Brown

Case 3:08-cv-00853-WHA

Document 10

Filed 05/19/2008

Page 2 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ___________________________ Hon. William H. Alsup United States District Judge IT IS SO ORDERED. Petitioner's motion for an extension of time to file a Traverse is GRANTED. Petitioner's Traverse is now due July 7, 2008. vs. Robert Horel, Warden, Respondent. Travell Brown, Petitioner, UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) Case No. 3:08-cv-00853-WHA ) ) ) ) [PROPOSED] ORDER ) ) ) ) )