United States District Court, D. Nevada
& Altig Attorneys at Law STEVEN M. ALTIG, ESQ. Nevada
State Bar No. 6879 Attorney for Defendant
M. ALTIG, ESQ. Nevada State Bar No. 6879 Attorney for
NICHOLAS A. TRUTANICH, ESQ. United States Attorney ALLISON
REESE Assistant United States Attorney Attorney for Plaintiff
STIPULATION TO CONTINUE BENCH TRIAL (FIRST
IS HEREBY STIPULATED AND AGREED, by and between
NICHOLAS A. TRUTANICH, United States Attorney, and ALLISON
REESE, Assistant United States Attorney, counsel for the
United States of America, and STEVEN M. ALTIG, ESQ., for
TEDDY COOPER; that the bench trial currently scheduled for
June 5, 2019, at the hour of 9:00 a.m., be vacated and
continued for thirty (30) days or to a date thereafter which
is convenient to the court.
Stipulation is entered into for the following reasons:
Counsel needs additional time to potentially negotiate the
case and if not they will need adequate time to prepare for
parties agree to the continuance.
Defendant is not incarcerated and does not object to the
additional time requested herein is not sought for purposes
of delay, but merely to allow Counsel sufficient time within
which to review the file, and possibly negotiate the case or
adequately prepare for trial.
Denial of this request for continuance would deny Counsel
sufficient time within which to be able to effectively and
thoroughly research, prepare and submit for filing
appropriate pretrial motions and notices, taking into account
the exercise of due diligence.
Additionally, denial of this request for continuance could
result in a miscarriage of justice.
additional time requested by this Stipulation is excluded in
computing the time within which the trial herein must
commence pursuant to the Speedy Trial Act, Title 18, United
States Code, Section 3161(h)(7)(A), considering the factors
under Title 18, United States Code, Sections 3161
(h)(7)(B)(i) and 3161 (h)(7)(B)(iv).
the first request to continue bench trial date filed herein.
OF FACT, CONCLUSIONS OF LAW AND ...