Opinion
2:12-cr-00485-GMN-PAL
03-22-2013
UNITED STATES OF AMERICA, Plaintiff, v. ROCCO LAZAZZARO, Defendant.
RENE L. VALLADARES Federal Public Defender SHARI L. KAUFMAN Assistant Federal Public Defender Counsel for Rocco Lazazzaro DANIEL BOGDEN United States of America CHRISTINA M. BROWN Assistant United States Attorney Counsel for the Plaintiff
RENE L. VALLADARES
Federal Public Defender
State Bar No. 11479
SHARI L. KAUFMAN
Assistant Federal Public Defender
State Bar No. 004461
411 E. Bonneville Avenue, Suite 250
Las Vegas, Nevada 89101
(702) 388-6577
(Fax) 388-6261
Attorneys for Rocco Lazazzaro
STIPULATION TO CONTINUE
MOTION HEARING
(First Request)
(Emergency Consideration Requested)
IT IS HEREBY STIPULATED AND AGREED, by and between Daniel Bogden, United States Attorney, and Christina M. Brown, Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Shari L. Kaufman, Assistant Federal Public Defender, counsel for defendant ROCCO LAZAZZARO, that the Motion hearing currently scheduled for March 25, 2013, at the hour of 10:00 a.m., be vacated and set to any day next week; however, in no event earlier than Tuesday, March 26, 2013.
This Stipulation is entered into for the following reasons:
1. Defense counsel will be out of the office on an office mandated furlough day during the presently scheduled hearing date and time.
2. Additionally, defense counsel is the attorney who has specific knowledge of the case and respectfully requests a resetting of the motion hearing in this matter.
3. The defendant Lazazzaro is incarcerated does not object to the continuance.
4. The parties agree to the continuance.
5. The additional time requested herein is not sought for purposes of delay, but merely to allow for a resetting in this matter.
6. Additionally, denial of this request for continuance could result in a miscarriage of justice.
7. The additional time requested by this Stipulation is excludable 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 the motion hearing date filed herein.
RENE L. VALLADARES
Federal Public Defender
By: __________
SHARI L. KAUFMAN
Assistant Federal Public Defender
Counsel for Rocco Lazazzaro
DANIEL BOGDEN
United States of America
By: __________
CHRISTINA M. BROWN
Assistant United States Attorney
Counsel for the Plaintiff
UNITED STATES OF AMERICA, Plaintiff,
vs.
ROCCO LAZAZZARO, Defendant.
2:12-cr-00485-GMN-PAL
ORDER
Based on the pending Stipulation of counsel, and good cause appearing therefore,
IT IS THEREFORE ORDERED that the motion hearing currently scheduled for Monday, March 25, 2013, at the hour of 10:00 a.m., be vacated and continued to Thursday, (3/28/2013 at the hour of 9: 0 0am
______________
UNITED STATES DISTRICT JUDGE