STIPULATION TO CONTINUE PRELIMINARY HEARING (First Request)

GEORGE FOLEY, Jr., Magistrate Judge.

IT IS HEREBY STIPULATED AND AGREED, by and between Daniel G. Bogden, United States Attorney, and Brandon C. Jaroch, Assistant United States Attorney, counsel for the United Stated of America, and Rene L. Valladares, Federal Public Defender, and Monique Kirtley, Assistant Federal Public Defender, counsel for Timothy Ryan, that the Preliminary Hearing currently scheduled on Thursday, November 12, 2015 at 4:00 p.m., be vacated and continued to a date and time convenient to the Court, but no earlier than thirty (30) days.

This Stipulation is entered into for the following reasons:

1. Undersigned defense counsel was only recently assigned this case and filed her notice of appearance on October 30, 2015.

2. Defendant is detained at Pahrump and defense counsel needs additional time to schedule a visit to meet with the defendant to discuss the details of this case.

3. The parties have entered negotiations and need the additional time to resolve this matter.

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

This is the first request for continuance filed herein.

ORDER

Based on the Stipulation of counsel and good cause appearing,

IT IS THEREFORE ORDERED that the Preliminary Hearing currently scheduled on November 12, 2015 at the hour of 4:00 p.m., be vacated and continued to at December 14, 2015 at the hour of 4:00 p.m.