Plea resolution

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SIM GILL, 6389 District Attorney for Salt Lake County R. Josh Player, 7768 Adam Blanch, 14135 Deputy District Attorneys 111 East Broadway Salt Lake City, Utah 84111 Telephone: (385) 468-7600 ___________________________________________________________________________ IN THE THIRD DISTRICT COURT, SALT LAKE DEPARTMENT

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IN AND FOR SALT LAKE COUNTY

STATE OF UTAH,

STIPULATED MOTION TO DISMISS (CONDITIONS SATISFIED)

Plaintiff,

vs.

Case No. 151912501

SHAMUS HAWS,

Defendant.

Hon. E. Hruby-Mills District Court Judge

R. Josh Player and Adam Blanch, Deputy District Attorneys, and Defendant, represented by counsel, Tara Isaacson and Walter Bugden, hereby join and submit the following Stipulated

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Motion to Dismiss (Conditions Satisfied) to the Court.

This matter came before the court pursuant to the Defendant's Appeal of a jury conviction

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1.

MOTION TO DISMISS

of four counts of class C misdemeanor animal cruelty based upon a reckless or criminally negligent mental state. The Jury acquitted the Defendant of 7 counts and convicted on 4 counts

after a 4 day trial including extended deliberations. During the course of the trial both the Prosecution and Defense presented multiple expert witnesses. In the Justice Court, 1

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the Defendant, having no prior criminal history, and based upon the nature of the charges was

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sentenced to probation and a requirement that he complete 50 community service hours. 2.

Mr. Haws appealed the convictions and is entitled to a new trial in the District Court.

3.

Since the incident that gave rise to the charges in this case, Mr. Haws took steps to fix the

watering problem. Mr. Haws altered the watering system in the pasture at issue at the cost of

several thousand dollars. The Defendant has also increased and improved the supervision over his horses as a result of this matter.

Pursuant to the agreement of the parties, the Defendant has provided proof of completion

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4.

of 50 community service hours and has donated $10,000 to the Utah Horse Council to be used to further the welfare of horses in the State of Utah. 5.

In the interests of justice, the State moves to dismiss the charges against Mr. Haws with

prejudice. Mr. Haws stipulates to the State’s motion.

Dated this 25th day of January, 2016.

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/S/ R. Josh Player R. Josh Player Deputy District Attorney

Approved:

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/S/ Tara Isaacson (signed with permission) Tara Isaacson Attorney for Shamus Haws

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