Defendants' Motion for Stay — U.S. v. Bailey

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Defendants' Motion for Stay filed by Ryan Bailey and RKB, Inc. through counsel G. Todd Houck in the United States District Court for the Southern District of West Virginia, Beckley, Case No. 5:24-cv-00456 (Doc. 16). The motion states that the matter is cojoined to a parallel criminal action involving substantially similar issues to those alleged in the instant civil action. It says a co-defendant in the criminal matter has filed a motion for stay in a separate civil matter, 5:24-cv-00455, and that the Defendants rely on the same legal authorities as outlined in the attached memorandum in support. The certificate of service is dated November 22, 2024.

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IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA
BECKLEY
UNITED STATES OF AMERICA, 
PLAINTIFF,
V. 
CRIMINAL CASE NO. 
5:24-cv-00456
RYAN BAILEY and RKB, 
INC., 
DEFENDANTS.
DEFENDANT'S MOTION FOR STAY
Comes now Defendants, Ryan Bailey and RKB, 
Inc. (collectively, "Defendants"), by
counsel, G. Todd Houck, and hereby moves this Honorable Court to grant unto Defendant stay in
the instant matter. Defendant would state that this matter is cojoined to a parallel criminal action
involving substantially similar issues to those alleged in the instant civil action. Defendant's Co-
Defendant, in said criminal matter, has filed a motion for stay [see 5:24-cv-00455, Page ID# 36-
41] in his likewise separate civil matter, and Defendant relies on the same legal authorities as
outlined in the attached memorandum in support of this instant motion.
RESPECTFULLY SUBMITTED,
RYAN BAILEY
By Counsel
G. TODD HOUCK
COUNSEL FOR DEFENDANT
/s/G. Todd Houck 
5674
Hrko Building
105 Guyandotte Avenue
Mullens, WV 25882
T: (304)294-8055
F: (304)294-8077
gthouck@aol.com
Case 5:24-cv-00456     Document 16     Filed 11/22/24     Page 1 of 2 PageID #: 70

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA
BECKLEY
UNITED STATES OF AMERICA, 
PLAINTIFF,
V. 
CRIMINAL CASE NO. 5:24-cv-00456
RYAN BAILEY and RKB, INC., 
DEFENDANTS.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that the foregoing "DEFENDANT'S MOTION FOR
STAY" has been electronically filed with the Clerk of this Court, this 22"'' day of November,
2024, using the CM/ECF system and served upon opposing counsel as follows:
VIA CM/ECF: 
Fred B. Westfall, Jr.
Assistant United States Attorney
300 Virginia Street East, Room 4000
Charleston, WV 25301
DATE: November 22, 2024
/s/G.ToddHouck 
5674
Counsel for Defendant
Hrko Building
105 Guyandotte Avenue
Mullens, WV 25882
T: (304)294-8055
F: (304)294-8077
gthouck@aol.com
Case 5:24-cv-00456     Document 16     Filed 11/22/24     Page 2 of 2 PageID #: 71

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