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

Case 1:07-cv-00012-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE NORMAN INGRAM, Petitioner, v. THOMAS CARROLL, Warden and JOSEPH R. BIDEN III, Attorney General for the State of Delaware Respondents. ) ) ) ) ) ) ) ) ) ) )

Civ.Act.No. 07-12-***

MOTION FOR EXTENSION OF TIME TO FILE CERTIFIED STATE COURT RECORDS 1. The petitioner, Norman Ingram, has applied for federal habeas relief,

alleging a variety of errors in his 2004 convictions. D.I. 2. The undersigned filed an answer to the petition on May 11, 2007. 2. By the terms of the Court's order, the respondents are directed to attach to

the answer certified copies of the state court records material to the questions raised in the petitioner's appeal. 3. Due to the large volume of record retrieval recently required by

prosecutors in the appeals division, the undersigned has been unable to obtain the certified state court records in order to file them contemporaneously with the answer. The undersigned anticipates obtaining and copying the records on or before July 11, 2007. 4. records. This is respondents' SECOND request for an extension of time to file

Case 1:07-cv-00012-GMS

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5.

Respondents submit that an extension of time to July 11, 2007 in which to

file certified copies of the material portions of the state court records in this case is reasonable. Respondents submit herewith a proposed order.

/s/ James T. Wakley Deputy Attorney General Department of Justice 820 N. French Street Wilmington, DE 19801 (302) 577-8500 Del. Bar. ID No. 4612 DATE: June 11, 2007

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RULE 7.1.1 CERTIFICATION I hereby certify that I have neither sought nor obtained the consent of the petitioner, who is incarcerated and appearing pro se, to the subject matter of this motion.

/s/ James T. Wakley Deputy Attorney General

Counsel for Respondents

Date: June 11, 2007

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CERTIFICATE OF SERVICE I hereby certify that on June 11, 2007, I electronically filed the attached documents with the Clerk of Court using CM/ECF. I also hereby certify that on June 11, 2007, I have mailed by United States Postal Service, the same documents to the following non-registered participant:

Norman Ingram SBI No. 00263838 Delaware Correctional Center 1181 Paddock Road Smyrna, DE 19977 /s/ James T. Wakley Deputy Attorney General Department of Justice 820 N. French Street Wilmington, DE 19801 (302) 577-8500 Del. Bar. ID No. 4612 [email protected] Date: June 11, 2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE NORMAN INGRAM, Petitioner, v. THOMAS CARROLL, Warden and JOSEPH R. BIDEN III, Attorney General for the State of Delaware Respondents. ) ) ) ) ) ) ) ) ) ) )

Civ.Act.No. 07-12-***

ORDER This _____day of _________________________, 2007, WHEREAS, respondents having requested an extension of time in which to file certified state court records, and, WHEREAS, it appearing to the Court that the requested extension is timely made and good cause has been shown for the extension, IT IS HEREBY ORDERED that certified state court records related to this matter shall be filed on or before July 11, 2007

____________________________ United States District Judge