Case 2:16-cr-00046-GMN-PAL Document 3345 Filed 09/26/18 Page 1 of 3

1 DAYLE ELIESON
United States Attorney
2 STEVEN W. MYHRE
DANIEL R. SCHIESS
3 Nevada Bar No. 5483
NADIA J. AHMED
4 Assistant United States Attorneys
District of Nevada
5 501 Las Vegas Blvd. South, Suite 1100
Las Vegas, Nevada 89101
6 (702) 388-6336
dan.schiess@usdoj.gov
7
Representing the United States of America
8

9 UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
10
United States of America,
11 2:16-CR-0046-GMN-PAL
Plaintiff,
12 Motion for Downward Departure
v.
13
Blaine Cooper,
14
Defendant.
15

16 CERTIFICATION: This Motion is timely filed.

17 The United States by the undersigned attorneys files this Motion for

18 Departure pursuant to U.S.S.G. § 5K1.1. The United States seeks a departure of

19 six levels for defendant Blaine Cooper.

20 Section 5K1.1 of the United States Sentencing Guidelines permits the

21 government to file a motion for downward departure when a defendant provides

22 substantial assistance to the United States in the investigation or prosecution of a

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 Case 2:16-cr-00046-GMN-PAL Document 3345 Filed 09/26/18 Page 2 of 3

1 person. U.S.S.G. § 5K1.1. The section provides that the court may consider (1) the

2 significance and usefulness of the defendant’s assistance; (2) the truthfulness,

3 completeness, and reliability of the defendant’s information or testimony; (3) the

4 nature and extent of a defendant’s assistance; (4) any injury suffered or any danger

5 or risk of injury to the defendant from his assistance; and (5) the timeliness of the

6 assistance.

7 Cooper’s assistance meets the criteria for departure. He met with the

8 United States several times to provide information, provided information that was

9 significant, useful, reliable, and timely, and was willing to testify. By providing

10 information, he exposed himself to risk of injury by people opposed to the

11 government’s prosecution of the Bundys and the other defendants. In the

12 assessment of the United States, Cooper’s assessment merits a six-level departure.

13 Based on the foregoing, the government asks the Court to grant the

14 government’s motion and apply a six-level departure to Cooper’s sentencing

15 guideline calculations.

16
Respectfully,
17
DAYLE ELIESON
18 United States Attorney

19 / s / Daniel R. Schiess
______________________________
20 STEVEN W. MYHRE
DANIEL R. SCHIESS
21 NADIA J. AHMED
Assistant United States Attorneys
22

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 Case 2:16-cr-00046-GMN-PAL Document 3345 Filed 09/26/18 Page 3 of 3

1 CERTIFICATE OF SERVICE

2 I certify that I am an employee of the United States Attorney’s Office, and

3 that a copy of the foregoing Motion for Downward Departure was served upon

4 counsel of record, via Electronic Case Filing (ECF).

5 DATED this 26th day of September, 2018.

7 / s / Daniel R. Schiess
______________________________
8 DANIEL R. SCHIESS
Assistant United States Attorney
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