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United States v. Cooper

United States District Court, D. Nevada

June 4, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
TEDDY COOPER, Defendant.

          Adras & Altig Attorneys at Law STEVEN M. ALTIG, ESQ. Nevada State Bar No. 6879 Attorney for Defendant

          STEVEN M. ALTIG, ESQ. Nevada State Bar No. 6879 Attorney for Defendant

          NICHOLAS A. TRUTANICH, ESQ. United States Attorney ALLISON REESE Assistant United States Attorney Attorney for Plaintiff

          STIPULATION TO CONTINUE BENCH TRIAL (FIRST REQUEST)

         IT 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.

         This Stipulation is entered into for the following reasons:

         1. That Counsel needs additional time to potentially negotiate the case and if not they will need adequate time to prepare for trial.

         2. The parties agree to the continuance.

         3. The Defendant is not incarcerated and does not object to the continuance.

         4. 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.

         5. 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.

         6. Additionally, denial of this request for continuance could result in a miscarriage of justice.

         7. The 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).

         This is the first request to continue bench trial date filed herein.

         FINDINGS OF FACT, CONCLUSIONS OF LAW AND ...


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