USA v. Tolentino et al

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Rene L. Valladares
Federal Public Defender
Nevada Bar No. 11479
Rebecca A. Levy
Assistant Federal Public Defender
Oregon State Bar No. 044058
Email: Rebecca_Levy@fd.org
411 E. Bonneville Ave., Ste. 250
Las Vegas, NV 89101
(702) 388-6577
(702) 388-6261 (Fax)
Attorneys for Coy Mobley
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
COY MOBLEY,
Defendant.
Case No. 2:25-cr-00247-DJC-7
STIPULATION AND PROPOSED
ORDER
1. 	By previous order this case was set for detention hearing on November 4, 2025.
2. 	By this Stipulation the defendant asks to move both the initial and detention
hearing to November 12, 2025 and for counsel to appear via video.
3. 	The parties agree and stipulate, and request that the Court find the following:
(a) Counsel for the defendant has not been able to speak with her client. Thursday,
November 6, 2025, is the earliest that that can occur. That is also the date Pretrial Services will
first be able to interview Mr. Mobley for purposes of making a recommendation. After that
occurs, counsel will need time to confirm Mr. Mobley’s personal information.

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(b) Counsel for the defendant believe failure to grant the above-requested
continuance would deny them the reasonable time necessary for effective preparation, taking
into account the exercise of due diligence.
(c) The government does not object to the continuance.
IT IS SO STIPULATED.
Dated: November 3, 2025. 	RENE A. VALLADARES
Federal Public Defender
/s/ Rebecca A. Levy
REBECCA A. LEVY
Assistant Federal Public Defender
Dated: November 3, 2025. 	ERIC GRANT
United States Attorney
/s/ Robert Abendroth
ROBERT ABENDROTH
Assistant United States Attorney

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[PROPOSED] ORDER
Good cause appearing, the hearing set for November 4, 2025, is vacated. The initial
appearance and detention hearing is set for November 12, 2025.
IT IS SO ORDERED.
Dated: November 3, 2025