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United States v. Thompson

United States District Court, D. Nevada

February 23, 2018

THE UNITED STATES OF AMERICA, Plaintiff,
v.
BOBBY THOMPSON and RANDY HUMPHREY, Defendants.

          FOR THE DEFENDANTS NICHOLAS WOOLRIDGE, ESQ. COUNSEL FOR BOBBY THOMPSON MATTHEW LAY, ESQ. COUNSEL FOR RANDY HUMPHREY

          FOR THE UNITED STATES CRISTINA D. SILVA COUNSEL FOR UNITED STATES

          STIPULATION TO CONTINUE PRELIMINARY HEARING

          HONORABLE PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE

         IT IS HEREBY STIPULATED AND AGREED, by and between DAYLE ELIESON, United States Attorney for the District of Nevada, and CHRISTINA SILVA, Assistant United States Attorney, counsel for United States of America, and Nicholas Woolridge, Esq., counsel for Defendant, BOBBY THOMPSON, and Matthew Lay, Esq., counsel for Defendant, RANDY HUMPHREY, that the preliminary hearing date in the above-captioned matter, currently scheduled for February 16, 2018, at 4:00 p.m., be vacated and continued for thirty (30) days, at a date and time convenient to this Court.

         This Stipulation is entered into for the following reasons:

         1. The parties have initiated discussions regarding resolving the case pre-indictment, and negotiations have been ongoing. Additional time is needed for defense counsel to review discovery, including the defendants' statements, and for counsel to discuss the discovery with their clients. Additionally, the parties requested certain items of discovery from law enforcement, and were awaiting the production of that discovery. Law enforcement recently determined that the requested discovery does not exist.

         2. The Defendants also need additional time to discuss a potential pre-indictment resolution with their clients.

         3. All parties agree to the continuance.

         4. The Defendants are currently detained pending trial but do not object to a continuance.

         5. Denial of this request for continuance could result in a miscarriage of justice.

         6. The additional time requested herein is not sought for the purposes of delay, but to allow for a potential pre-indictment resolution of the case.

         7. The additional time requested by this stipulation is allowed, with the Defendants' consent, under Federal Rule of Procedure 5.1(d).

         8. This is the third (3rd) request for a continuation of the ...


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