Opinion
CR-S-13-00085-MMD-PAL
03-15-2013
UNITED STATES OF AMERICA, Plaintiff, v. Marco Antonio Caballero-Perez, Defendant.
TODD M. LEVENTHAL, ESQ Attorney for Defendant Marco Antonio Caballero -Perez SUSAN CUSHMAN, ESQ. Assistant U.S. Attorney
TODD M. LEVENTHAL, ESQ
Attorney for Defendant
Marco Antonio Caballero -Perez
STIPULATION FOR CONTINUANCE
IT IS HEREBY STIPULATED AND AGREED by and between the Defendant, Marco Antonio Caballero-Perez, by and through his attorney, TODD M. LEVENTHAL, ESQ., by and between Plaintiff, the United States of America, by and through it's attorney, SUSAN CUSHMAN, ESQ., that the arraignment and plea now set for March 22, 2013 at 8:30 am , be continued to a date and time convenient to this court, preferably not on a Friday.
Based on the Stipulation of counsel, and good cause appearing, this Stipulation is entered into for the following reasons:
1. Counsel for the Defendant will be out of the jurisdiction on Friday March 22, 2013
2. Counsel for the defendant has spoken with Assistant U.S. Attorney, Susan Cushman, and she has no objections to the arraignment being continued.
3. Mr. Caballero-Perez is in custody.
4. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for defendant sufficient time, in light of the above, within which to be able to effectively and thoroughly review the evidence in the above-captioned matter.
5. This is the FIRST request to continue the arraignment in this matter.
______________________
TODD M. LEVENTHAL, ESQ.
Attorney for Defendant
______________________
SUSAN CUSHMAN, ESQ.
Assistant U.S. Attorney
ORDER
IT IS HEREBY ORDERED that the Arraignment shall be vacated, continued, and reset for Monday, 4/22/2013, at 3:00p.m., in Courtroom # _.