`
`Rene L. Valladares
`Federal Public Defender
`Nevada Bar No. 11479
`Heather Fraley
`Assistant Federal Public Defender
`Texas Bar No. 24050621
`heather_fraley@fd.org
`411 E. Bonneville, Ste. 250
`Las Vegas, Nevada 89101
`(702) 388-6577
`(702) 388-5819 (fax)
`
`Attorneys for Petitioner Michael J. Mulder
`
`UNITED STATES DISTRICT COURT
`
`DISTRICT OF NEVADA
`
`Michael J. Mulder,
`
`Petitioner
`
`v.
`
`William Gittere, Warden, Ely State
`Prison, et al.
`
`Respondents
`
`Case No. 3:09-cv-00610-CDS-CSD
`
`STIPULATION AND ORDER
`
`DEATH PENALTY CASE
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`Case 3:09-cv-00610-CDS-CSD Document 235 Filed 06/21/23 Page 2 of 3
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`STIPULATION
`
`Petitioner Michael Mulder, through counsel Heather Fraley, Assistant
`
`Federal Public Defender, and Respondent William Gittere, et al, through counsel
`
`Heather Procter, Chief Deputy Attorney General, hereby stipulate as follows:
`
`• On June 6, 2023, counsel for Mr. Mulder filed a Motion for Appointment of
`
`Counsel in a 42 U.S.C. § 1983 Proceeding and for Appointment as Guardian
`
`Ad Litem. The motion references numerous exhibits. The exhibits that were
`
`supposed to be filed with the motion were inadvertently not filed.
`
`• Counsel for Mr. Mulder did not realize the error until June 20, 2023 when
`
`counsel for the State filed their Opposition to Mr. Mulder’s motion.
`
`• Concurrently with the instant stipulation, counsel for Mr. Mulder are filing a
`
`Notice of Corrected Document that attaches the missing exhibits and corrects
`
`the numbering for those exhibits.
`
`•
`
`In the interest of fairness and professionalism, counsel for Mr. Mulder agree
`
`that the State should have the opportunity to file a revised opposition to the
`
`motion for appointment of counsel.
`
`• Accordingly, the parties hereby stipulate and agree that Respondents should
`
`have until July 18, 2023 to file a Revised Opposition to Motion for
`
`Appointment of Counsel. The parties further agree that Mr. Mulder should
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`Case 3:09-cv-00610-CDS-CSD Document 235 Filed 06/21/23 Page 3 of 3
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`have two weeks from the date Respondents file their Revised Opposition to
`
`file a Reply.
`
`DATED this 20th day of June 2023
`
`RENE L. VALLADARES
`Federal Public Defender
`/s/ Heather Fraley
`HEATHER FRALEY
`Assistant Federal Public Defender
`
`AARON FORD
`Nevada Attorney General
`/s/ Heather Procter
`HEATHER PROCTER
`Chief Deputy Attorney General
`
`IT IS SO ORDERED.
`
`U.S. District Judge Cristina D. Silva
`
`DATED ______________, 2023
`June 21
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