Motion by Carlos Smith for extension of time to self-surrender unopposed — USA v. Smith (Dkt. 61, N.D. Ill.)

Summary

Unopposed Motion to Extend Time for Self-Surrender, Document #61, filed 04/10/23 in No. 20CR00922, United States v. Carlos Smith, Northern District of Illinois, Eastern Division, three pages. Through his counsel at Bedi & Singer, LLP, Smith asks to move his self-surrender from before 2:00 pm on 4/25/2023 to June 5, 2023, after being sentenced on February 23, 2023 to 48 months (Dkt. 57). He gives two reasons: his family is arranging for a relative to help his mother while he is incarcerated, which can be in place by the first week of June, and he wants to attend a meeting with Social Security. Counsel says the government does not object and that Smith had not yet learned his designation; it is signed s/ Dena M. Singer.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA
)
)
20CR00922
v.
)
)
)
CARLOS SMITH
)
UNOPPOSED MOTION TO EXTEND TIME FOR SELF-SURRENDER
Defendant, CARLOS SMITH, through his attorney, Bedi & Singer, LLP, respectfully
requests that this Court extend the time for self-surrender until June 5, 2023. In support,
Defendant, states as follows:
1. On June 22, 2023 Mr. Smith pled guilty.
2. On February 23, 2023, Mr. Smith was sentenced to 48 months BOP. (Dkt.
57).
3. Mr. Smith was ordered to self-surrender to the Bureau of Prisons: before
2:00 pm on 4/25/2023 (Dkt. 59).
4. Mr. Smith’s family is making arrangements for a family member to come
help his mother while Mr. Smith is incarcerated. The family will be able to
have those arrangements in place by the first week of June. Furthermore,
Mr. Smith has a meeting with Social Security that he would like to attend
before he surrenders.
5. Mr. Smith requests his self-surrender date be continued to June 5, 2023.1
6. The undersigned counsel has conferred with the government who does not
object to this request.
1 As of the date of this filing Mr. Smith has not been made aware of his designation.
Case: 1:20-cr-00922 Document #: 61 Filed: 04/10/23 Page 1 of 3 PageID #:429

Wherefore, it is respectfully requested the Court extend the time for
self-surrender until June 5, 2023.
By: s/ Dena M. Singer
Dena M. Singer
Bedi & Singer, LLP
53 West Jackson Blvd, Suite 1505
Chicago, IL 60604
Phone: (312) 525-2017
dsinger@bedisinger.com
Attorney for Defendant
Case: 1:20-cr-00922 Document #: 61 Filed: 04/10/23 Page 2 of 3 PageID #:430

Certificate of Service
I, Dena M. Singer, hereby certify I caused a copy of the foregoing Motion to be served on upon
the Assistant United States Attorney by causing it to be electronically filed with the Clerk of the
Court using the CM/ECF system.
/s/ Dena M. Singer
Dena M. Singer
Case: 1:20-cr-00922 Document #: 61 Filed: 04/10/23 Page 3 of 3 PageID #:431

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