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

Case 3:08-cv-00029-H-PCL

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Filed 03/17/2008

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1 EDMUND G. BROWN JR. Attorney General of the State of California 2 DANE R. GILLETTE Chief Assistant Attorney General 3 GARY W. SCHONS Senior Assistant Attorney General 4 KEVIN VIENNA Supervising Deputy Attorney General 5 DANIEL ROGERS, State Bar No. 204499 Deputy Attorney General 110 West A Street, Suite 1100 6 San Diego, CA 92101 P.O. Box 85266 7 San Diego, CA 92186-5266 Telephone: (619) 645-2283 8 Fax: (619) 645-2191 Email: [email protected] 9 10 Attorneys for Respondent 11 12 13 14 15 16 17 18 19 20 21 Daniel Rogers declares: I am the Deputy Attorney General assigned to prepare the Answer in this matter which v. JOHN SALAZAR, Warden, Respondent. MIKE BREWER, Petitioner, 08cv0029-H (PCL) RESPONDENT'S MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER TO PETITION FOR WRIT OF HABEAS CORPUS The Honorable Peter C. Lewis IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA

22 is due on March 17, 2008. I request time to file the Answer be extended thirty (30) days through 23 April 16, 2008, for the following reasons: 24 This Court ordered a response to the Petition on January 16, 2008. I have not previously

25 requested an enlargement of time in this matter. 26 I am currently preparing responses to petitions for writ of habeas corpus in Vasquez v.

27 County of San Bernardino, EDCV 07-1682-JVS (MAN); Evans v. Tilton, 07cv0791-JM (BLM); 28 Brewer v. Salazar, 08cv0029-H (PCL); Hollis v. People of the State of California, EDCV 07-150108cv0029-H (PCL)

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1 SVW (RC); Givens v. Martel, EDCV 08-0111-CAS (SH); Regalado v. Dexter, CV 08-672-DSF 2 (MAN); Crouse v. Marshall, 08-0166 IEG (LSP), and Johnson v. Sisto, EDCV 08-278-DDP (CT). 3 Since this Court ordered a response to the instant Petition, I have filed an Answer in

4 Robinson v. Yates, EDCV 07-1406-VBF (SH); Morgutia v. Wong, SACV 07-1161-PA (PJW); Pre 5 v. Almager, 07cv0890 W (W Mc); Ensworth v. Marshall, SACV 07-1372 SVW (CT), and Desper 6 v. Miguel, EDCV 07-1588 PSG (AJW). I have also filed a Second Supplemental Brief in Marquis 7 v. Iaria, 07cv0730 W (LSP) and an Opposition to a Motion to Expand the Record in Ruff v. Hall, 8 EDCV 04-01330 MMM (MAN). 9 In addition to the assignments described above, I advise district attorney personnel

10 throughout the state in executing their responsibilities in responding to international child abduction 11 matters under the Hague Convention on the Civil Aspects of International Child Abduction. 42 12 U.S.C. § 11601 et. seq.; Cal. Fam. Code § 3455. These are time-sensitive matters that arise 13 unpredictably and require immediate attention. I spend roughly one day per week on average 14 working on child abduction matters. 15 I generally work on cases in the order they are assigned to me. I am currently completing

16 a response in Hollis v. People of the State of California, due March 17, 2008, and for which I have 17 requested one enlargement of time. When I have filed my response in that matter, I will begin my 18 response in the instant matter. 19 20 I am currently working evenings and weekends to complete the above assignments. Granting of an enlargement of time will permit me to gather the necessary state court

21 records and allow my response to be prepared without impairing its quality and allow adequate time 22 for review and processing. 23 /// 24 /// 25 /// 26 /// 27 /// 28 ///
08cv0029-H (PCL)

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I declare under penalty of perjury under the laws of the United States of America that the

2 foregoing is true and correct. 3 4 5 6 7 8 9 10 11 12 13 14 DR:mgs 15 SD2008700053 16 17 18 19 20 21 22 23 24 25 26 27 28
08cv0029-H (PCL)

DATED: March 17, 2008 at San Diego, California. Respectfully submitted, EDMUND G. BROWN JR. Attorney General of the State of California DANE R. GILLETTE Chief Assistant Attorney General GARY W. SCHONS Senior Assistant Attorney General KEVIN VIENNA Supervising Deputy Attorney General

s/Daniel Rogers DANIEL ROGERS Deputy Attorney General Attorneys for Respondent
80217054.wpd

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