United States District Court, D. Nevada
the Defendants:NICHOLAS WOOLRIDGE, ESQ. Counsel for Defendant
MATTHEW LAY, ESQ. Counsel for Defendant - Humphrey.
the United States: DAYLE ELIESON United States Attorney.
CRISTINA D. SILVA Assistant United States Attorney.
STIPULATION TO CONTINUE THE PRELIMINARY
HONORABLE PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE.
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
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
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