Opinion
2:16-cr-00044-JCM-BNW-1
10-30-2023
UNITED STATES OF AMERICA, Plaintiff, v. CHRISTIAN CONTRERAS, Defendant.
TANASI LAW OFFICES, RICHARD TANASI, ESQ. Counsel for Defendant JASON M. FRIERSON, ALLISON REESE Assistant United States Attorney
TANASI LAW OFFICES, RICHARD TANASI, ESQ. Counsel for Defendant
JASON M. FRIERSON, ALLISON REESE Assistant United States Attorney
STIPULATION TO CONTINUE REVOCATION HEARING (FIFTH REQUEST)
HONORABLE JAMES C. MAHAN, UNITED STATES DISTRICT JUDGE.
IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson, United States Attorney, and Allison Reese, Assistant United States Attorney, counsel for the United States of America, and Richard Tanasi, newly appointed counsel for Defendant Christian Contreras, that that the Revocation Hearing currently scheduled on January 29, 2024, (Doc. 101) be vacated and continued to a date and time convenient to the Court, but no sooner than thirty (30) days from April 8, 2024, which is the jury trial date for his new and pending criminal case. (See EM/CEF 2:22-CR-00278-CDS-DJA-1; Doc. 53.)
This Stipulation is entered into for the following reasons:
1) Defendant Christian Contreras was formally indicted in a new federal case on December 13, 2022. (See EM/CEF 2:22-CR-00278-CDS-DJA-1.) He is charged with one count of Carjacking in violation of 18 U.S.C. § 2119, one count of Discharging a Firearm During and in Relation to a Crime of Violence in violation of 18 U.S.C. § 924(c)(1)(A)(iii), and one count of Prohibited Person in Possession of a Firearm in violation of 18 U.S.C. § 922(g). (Id., Doc. 1.)
2) A Superseding Indictment was filed on January 4, 2023 (Id., Doc. 17.) and the arraignment for said Indictment was held on January 11, 2023 before the Honorable Magistrate Judge Nancy J. Koppe. (Id., Doc. 20.) New counsel Richard Tanasi was appointed on August 15, 2023. (Id., Doc. 41.) The trial in this pending case has been continued to April 8, 2024. (Id., Doc. 46.) Resolution of the trial case will affect the resolution of the pending revocation proceedings here.
3) A new counsel Richard Tanasi was also appointed in this instant case on August 28, 2023. (See Doc. 99). Counsel needs additional time to review the discovery, visit with the defendant, and conduct investigation in this case to determine whether there are any issues that must be litigated and whether the case will ultimately go to a contested revocation hearing or will be resolved through negotiations.
4) The defendant is incarcerated and does not object to continuance.
5) The parties agree to the continuance.
6) The additional time requested herein is not sought for purposes of delay.
ORDER
Based on the Stipulation of counsel and good cause appearing, IT IS THEREFORE ORDERED that the revocation hearing currently scheduled for Monday, January 29, 2024, at 10:30 a.m., be vacated and continued to May 13, 2024, at 10:00 a.m.