United States District Court, D. Nevada
H. DOWS, ESQ. Nevada Bar No. 010339 CORY READE DOWS &
SHAFER Attorneys for Petitioner GLENFORD BUDD.
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE SECOND
AMENDED PETITION FOR WRIT OF HABEAS CORPUS
RICHARD RBOLTLWARE, II, UNITED STATES DISTRICT JUDGE.
GLENFORD BUDD, by and through his counsel, Angela H. Dows,
Esq., hereby moves this Court for a 30-day enlargement of
time, up to and including January 22, 2020, by which to file
his Second Amended Petition for Writ of Habeas Corpus. This
is the fourth overall request for an extension of time. Said
request is brought in good faith and not for purposes of
OF POINTS AND AUTHORITIES
the instant matter involves a petition for writ of habeas
corpus filed by a Nevada state prisoner pursuant to 28 U.S.C.
on May 29, 2018, attorney Mary Lou Wilson filed a first
amended petition on behalf of Petitioner. (See
Docket No. 23).
attorney Mary Lou Wilson also filed 48 exhibits in support of
the first amended petition. (See Docket Nos. 25, 26,
27, 28, 29).
on October 9, 2018, the Court entered an order that dismissed
Ground 12 of the first amended petition, and ordered that
respondents have forty-five (45) days to answer or otherwise
respond to the amended petition. (See Docket No.
on February 8, 2019, Mary Lou Wilson filed a motion to
withdraw as counsel, and instant counsel was thereafter
appointed on February 25, 2019. (See Docket Nos. 36,
on March 7, 2019, the Court entered an order that allowed
Petitioner ninety (90) days, or on or before June 5, 2019, to
serve a motion or notice indicating how petitioner wishes to
proceed with this action.
on June 5, 2019, Petitioner filed a motion for leave to file
a second amended petition, along with a request for 60-days
by which to file said petition. (See Docket No. 41.)
Petitioner's motion was granted on July 3, 2019, with a
deadline to file said second amended petition of on or before
September 3, 2019. (See Docket No. 42.)
a previously-filed filed exhibit list containing forty-eight
(48) exhibits in total appeared to be on the low side for a
That in September of 2019, Petitioner was allowed a longer
continuance of approximately 90 days after delving into the
case and noticing that several exhibits as noted were not
included in the case, as well as mentioned in the petition.
As an ...