Coupar

MEMORANDUM *

Douglas Arthur Coupar appeals his third conviction and sentence following a guilty plea to three counts of bank robbery in violation of 18 U.S.C. § 2113 (a). Coupar argues that the district court erred in finding that he knowingly and intelligently waived the right to counsel and elected to proceed pro se. See Faretta v. California, 422 U.S. 806, 835 , 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975).

When determining whether a defendant’s Faretta waiver is knowing and intelligent, the district court is required to make the defendant aware of (1) the nature of the pending charges; (2) the potential penalties upon conviction; and (3) the dangers and disadvantages of self-representation. United States v. Erskine, 355 F.3d 1161, 1167 (9th Cir.2004). At the time that he waived his right to counsel, Coupar had been informed of all three. At his guilty plea hearing, prior to his waiver of counsel, the prosecution explained the pending charges and the potential penalties available. Then, upon Coupar’s request to proceed without counsel, the district court judge informed him of the potential pitfalls of self-representation. Given these circumstances, Coupar was sufficiently informed…