Opinion
2:18-CR-00213-APG-EJY
11-22-2022
UNITED STATES OF AMERICA, Plaintiff v. BOBBY THOMPSON, Defendant.
WRIGHT MARSH & LEVY MONTI JORDANA LEVY, ESQUIRE ATTORNEY ATTORNEY FOR BOBBY THOMPSON JAMES M. FRIERSON UNITED STATES ATTORNEY PETER S. LEVITT ASSISTANT U.S. ATTORNEY DISTRICT OF NEVADA COUNSEL FOR THE UNITED STATES OF AMERICA
WRIGHT MARSH & LEVY MONTI JORDANA LEVY, ESQUIRE ATTORNEY ATTORNEY FOR BOBBY THOMPSON
JAMES M. FRIERSON UNITED STATES ATTORNEY
PETER S. LEVITT ASSISTANT U.S. ATTORNEY DISTRICT OF NEVADA COUNSEL FOR THE UNITED STATES OF AMERICA
STIPULATION TO DISMISS PETITION FOR REVOCATION OF SUPERVISED RELEASE
HONORABLE ANDREW P. GORDON UNITED STATES DISTRICT JUDGE
IT IS HEREBY STIPULATED AND AGREED, between the United States of America, by and through its attorney, Jason M. Frierson, United States Attorney, and Peter S. Levitt, Assistant United States Attorney; and Defendant Bobby Thompson, by and through his counsel, Monti J ordana Levy, Esquire, of Wright Marsh & Levy, that the pending Petition for Revocation for Supervised Release be dismissed and for Supervised Release to continue.
The request to dismiss the Petition is based upon the following:
1. On February 16, 2021, Bobby Thompson was sentenced to Time Served followed by three (3) years supervised release.
2. On May 25, 2021, Mr. Thompson's supervising officer filed a Petition for Summons as the probation officer believed Mr. Thompson violated conditions of release related to positive drug tests; a new offense for convicted person fail/change address and open alcoholic container in vehicle; and possession of marijuana.
3. On June 17, 2021, Mr. Thompson appeared for his Revocation of Supervised Release hearing. Mr. Thompson waived an evidentiary hearing on the allegations, and, after hearing from the parties, the Court ordered that the Petition would be held in Abeyance for 6 months for Mr. Thompson to continue on the terms of Supervised Release.
4. On December 13, 2021, the parties entered into a stipulation to continue the status hearing to allow Mr. Thompson to complete CDL school and obtain employment.
5. On March 23, 2022, at the request of the parties the hearing was again continued for
Mr. Thompson to comply with drug testing and employment requirements.
6. On April 14, 2022, Mr. Thompson passed his CDL licensing test. Mr. Thompson was hired as a driver; however, he was laid off after working successfully for several months.
7. Mr. Thompson has not had any positive drug tests since July 6, 2021- 16 months ago.
8. Mr. Thompson is currently looking for new employment and has started making payments toward his financial obligations in this matter.
9. Mr. Thompson is making positive progress and maintaining communication with his supervising officer.
10. Mr. Thompson's Probation Officer, Annis Seopaul Sones has been consulted regarding this stipulation and does not oppose the requested dismissal.
ORDER
Pursuant to the Stipulation of the Parties, for good cause appearing, and the best interest of justice being served:
IT IS HEREBY ORDERED THAT the revocation of supervised release hearing in the above captioned matter currently scheduled for January 10, 2023 at 9:00 am., be vacated and that the Petition and all addenda pending before the court for Revocation of Supervised Release are dismissed.