Opinion
2:11-cr-386-GMN-GWF C/W 2:11-cr-388-MMD-CWH
01-24-2013
UNITED STATES OF AMERICA Plaintiff, v. PAUL SEIFERT, Defendant.
RICHARD A. SCHONFELD, ESQ. Nevada Bar No. 6815 CHESNOFF & SCHONFELD Attorney for Defendant, PAUL SEIFERT NDREW DUNCAN, AUSA Attorney for Plaintiff
RICHARD A. SCHONFELD, ESQ.
Nevada Bar No. 6815
CHESNOFF & SCHONFELD
Attorney for Defendant, PAUL SEIFERT
STIPULATION TO CONTINUE CHANGE OF PLEA HEARING AND
ORDER
IT IS HEREBY STIPULATED and AGREED by and between Andrew Duncan, Assistant United States Attorney, Richard A. Schonfeld, attorney for Defendant Paul Seifert, that the Change of Plea hearing scheduled January 29, 2013 at 3:00 p.m. be continued to February 12, 2013 at 2:30 p.m. or a time thereafter convenient to the Court.
This Stipulation is entered into for the following reasons:
1. That counsel for Defendant has a scheduling conflict and has to be in Reno, Nevada on January 29 and 31, 2013, for pretrial evidentiary hearings and arguments in a multiple defendant case;
2. That counsel for Defendant has been in communication with Assistant United States Attorney Andrew Duncan and there is no objection to the continuance as outlined above;
3. Additionally, denial of this request for continuance would result in a miscarriage of justice;
4. The additional time requested in this Stipulation is excludable in computing the time within which the trial must commence pursuant to the Speedy Trial Act, Title 18, United States Code, Sections 3161(h)(1)(D) and 3161(h)(7)(A) when considering the factors under Title 18, United Slates Code. Sections 33161(h)(7)(B)(I) and 3161(h)(7)(B)(iv); UNITED STATES ATTORNEY _______________________
ANDREW DUNCAN, AUSA
Attorney for Plaintiff
CHESNOFF & SCHONFELD ________________________
RICHARD A. SCHONFELD, ESQ.
Attorney for Defendant, Paul Seifert
ORDER
IT IS HEREBY ORDERED that the Change of Plea hearing presently scheduled for Tuesday, January 29, 2013, at the hour of 3:00 p.m be vacated and the Change of Plea will now be on February 12, 2013, at 2:30 p.m.
________________________
Gloria M. Navarro
United States District Judge
Submitted by: ________________________
RICHARD A. SCHONFELD, ESQ.
Nevada Bar #6815
Attorney for Defendant, Paul Seifert