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United States v. Thompson

United States District Court, D. Nevada

May 8, 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

          THE 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, 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 May 4, 2018, at 4:00 pm, 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 agreed to enter into a formal plea agreement with the United States. However, since making that agreement he has filed a motion for a new attorney. As a result, that issue must be resolved before (and if) a formal change of plea is to take place.
2. Defendant Thompson has been presented a written, formal plea agreement. 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 Defendnat 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 ...

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