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Home Source documents Stipulation to Dismiss Petition Without Prejudice — United States v. Arian Bailey, No. 2:21-CR-00208-GMN-DJA (Dkt. 26, D. Nev.)

Stipulation to Dismiss Petition Without Prejudice — United States v. Arian Bailey, No. 2:21-CR-00208-GMN-DJA (Dkt. 26, D. Nev.)

Summary

A stipulation in United States v. Arian Bailey, 2:21-CR-00208-GMN-DJA, in the U.S. District Court for the District of Nevada, submitted under the Court's February 7, 2022 Minute Order by Assistant U.S. Attorney Simon F. Kung and Assistant Federal Public Defender Aden Kebede. It recites that Bailey admitted the allegations in the original petition and addendum on September 2, 2021, and that the Court stayed sentencing for six months for Bailey to complete treatment and get back into compliance. The parties state that Bailey has since stayed in compliance and completed outpatient treatment, and they agree to dismiss the petition without prejudice and continue Bailey on the current term of supervision. They ask that the March 2, 2022 hearing be vacated. The stipulation is dated February 16, 2022 and has a signature block for Judge Gloria M. Navarro.

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Full text

        Case 2:21-cr-00208-GMN-DJA Document 25
                                            26 Filed 02/16/22
                                                     02/17/22 Page 1 of 3




1    RENE L. VALLADARES
     Federal Public Defender
2    Nevada State Bar No. 11479
     ADEN KEBEDE
3    Assistant Federal Public Defender
     411 E. Bonneville, Ste. 250
4    Las Vegas, Nevada 89101
     (702) 388-6577/Phone
5    (702) 388-6261/Fax
     Aden_Kebede@fd.org
6
     Attorney for Arian Bailey
7

8                         UNITED STATES DISTRICT COURT

9                                DISTRICT OF NEVADA

10
     UNITED STATES OF AMERICA,                      2:21-CR-00208-GMN-DJA
11                                                  STIPULATION TO DISMISS
                  Plaintiff,
                                                    PETITION WITHOUT
12                                                  PREJUDICE
           v.
13   ARIAN BAILEY,

14                Defendant.

15

16         Pursuant to the Court’s February 7, 2022, Minute Order, Christopher

17   Chiou, Acting United States Attorney, and Simon F. Kung, Assistant United

18   States Attorney, counsel for the United States of America, and Rene L.

19   Valladares, Federal Public Defender, and Aden Kebede, Assistant Federal Public

20   Defender, counsel for Arian Bailey, hereby submit the following stipulation.

21

22

23
        Case 2:21-cr-00208-GMN-DJA Document 25
                                            26 Filed 02/16/22
                                                     02/17/22 Page 2 of 3




1          1.     On September 2, 2021, Mr. Bailey admitted to the allegations in the

2    original petition and addendum. The Court stayed sentencing for six months in

3    order for Mr. Bailey to complete treatment and get back into compliance.

4          2.     Since that hearing, Mr. Bailey has only had negative tests and has

5    stayed in compliance. He also successfully completed outpatient treatment

6    through the Freedom House.

7          3.     The parties have agreed to dismiss the petition without prejudice

8    and continue Mr. Bailey on his current term of supervision.

9          4.     The parties move to dismiss the petition and the addendum at this

10   time. The parties request that the March 2, 2022, hearing be vacated because of

11   the joint resolution.

12         DATED this 16th day of February 2022.

13    RENE L. VALLADARES                    CHRISTOPHER CHIOU
      Federal Public Defender               Acting United States Attorney
14

15       /s/ Aden Kebede                      /s/ Simon F. Kung
      By_____________________________       By_____________________________
16
      ADEN KEBEDE                           SIMON F. KUNG
      Assistant Federal Public Defender     Assistant United States Attorney
17

18                 17 day of _______________,
      DATED this _____          February      2022
                                             By: ___________________________
19
                                             JUDGE GLORIA M. NAVARRO
                                             UNITED STATES DISTRICT COURT
20

21
                                              2
22

23
        Case 2:21-cr-00208-GMN-DJA Document 25
                                            26 Filed 02/16/22
                                                     02/17/22 Page 3 of 3




1                             CERTIFICATE OF SERVICE

2          The undersigned hereby certifies that he is an employee of the Federal

3    Public Defender for the District of Nevada and is a person of such age and

4    discretion as to be competent to serve papers.

5          That on February 16, 2022 he served an electronic copy of the above and

6    foregoing, STIPULATION TO DISMISS PETITION WITHOUT

7    PREJUDICE, by electronic service (ECF) to the person named below:

8
                        CHRISTOPHER CHIOU
9                       Acting United States Attorney
                        SIMON F. KUNG
10                      Assistant United States Attorney
                        501 Las Vegas Blvd. South
11                      Suite 1100
                        Las Vegas, NV 89101
12
                                               /s/Brandon Thomas
13                                             Federal Public Defender Employee
14

15

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                                               3
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