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United States v. Thompson

United States District Court, D. Nevada

March 20, 2018

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

          FOR THE DEFENDANTS NICHOLAS WOOLRIDGE, ESQ. COUNSEL FOR DEFENDANT - THOMPSON, DENNIS MATTHEW LAY, ESQ. COUNSEL FOR DEFENDANT - HUMPHREY

          FOR THE UNITED STATES DAYLE ELIESON UNITED STATES ATTORNEY, CRISTINA D. SILVA ASSISTANT UNITED STATES ATTORNEY

          STIPULATION TO CONTINUE THE PRELIMINARY HEARING

          HON. 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, and Nicholas Wooldridge, Esq., counsel for Defendant BOBBY THOMPSON, and Dennis Matthew Lay, Esq., counsel for defendant RANDY HUMPHREY, that the preliminary hearing date in the above-captioned matter, currently scheduled for March 19, 2018, at 4:00 p.m., be vacated and continued for forty-five (45) days, to a date and time to be set by this Honorable Court.

         This stipulation is entered into for the following reasons:

         1. Defendant Humphrey has entered into a formal plea agreement with the United States. Additional time is needed to file the plea agreement and schedule the change of plea.

         2. Defendant Thompson has been presented a written, formal plea agreement. Counsel for Defendant Thompson anticipates resolving the case pre-indictment, however, the Defendant and his counsel need additional time to review the plea agreement and its potential implications.

         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 purposes of delay, but to allow for Defendant Humphrey to enter his change of plea, and Defendant Thompson to potentially resolve the case pre-indictment.

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

         . . .

         8. This is the fourth request for a continuation of the preliminary ...


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