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United States v. Tyson

United States District Court, D. Nevada

February 28, 2018

UNITED STATES OF AMERICA,
v.
JEREMY TYSON, DEANDRE SPENCER, and SHAKEYA JOSEPH, Defendants.

          DAYLE ELIESON United States Attorney

          CRISTINA D. SILVA Assistant United States Attorney

          RACHEL M. KORENBLAT Counsel for Defendant, JEREMY TYSON

          RICHARD A. WRIGHT Counsel for Defendant, DEANDRE SPENCER

          WILLIAM H. BROWN Counsel for the Defendant, SHAKEYA JOSEPH

          STIPULATION TO CONTINUE THE PRELIMINARY HEARING

          HONORABLE PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE.

         IT IS HEREBY STIPULATED AND AGREED, by and between DAYLE ELIESON, United States Attorney, and CRISTINA D. SILVA, Assistant United States Attorney, counsel for the United States of America, RACHEL KORENBLAT, ESQ., counsel for Defendant JEREMY TYSON, RICHARD A. WRIGHT, ESQ., counsel for Defendant DEANDRE SPENCER and WILLIAM H. BROWN, ESQ., counsel for Defendant SHAKEYA JOSEPH, that the preliminary hearing date in the above-captioned matter, currently scheduled for March 1, 2018, at 4:00 pm, be vacated to a date and time convenient to this Honorable Court but in any event no sooner than 45 days.

         This stipulation is entered into for the following reasons:

         1. The parties have continued discussions regarding possibly resolving the case pre-indictment. Additional time is needed for defense counsel to review the discovery they have received in order to engage in negotiations.

         2. The parties agree to the continuance.

         3. Defendant SPENCER is in custody and TYSON and JOSEPH are both released on a personal recognizance bonds. No defendant objects to the continuance.

         4. Additionally, denial of this request for continuance could result in a miscarriage of justice.

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

         6. The additional time requested by this stipulation, is allowed, with the defendant's consent under the ...


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