Unopposed Motion to Continue Sentencing Hearing by Christopher Leo Daragjati — USA v. Daragjati (Dkt. 33, M.D. Fla.)

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Defendant Christopher Leo Daragjati's unopposed motion to continue sentencing in United States of America v. Christopher Leo Daragjati, Case No. 3:23-cr-00048-TJC-LLL, in the U.S. District Court for the Middle District of Florida, Jacksonville Division, filed October 18, 2023 as Document 33. The motion states that on July 20, 2023 Daragjati entered a plea of guilty to Counts One, Four, Eleven, Twelve, and Thirteen of the Indictment under a plea agreement, and that sentencing was set for October 26, 2023. It says Daragjati questions some of the intended and actual loss amounts in the presentence report, which will most likely affect the guidelines calculations under USSG § 2B1.1(b)(1). It asks for a continuance of at least 30 days and states that AUSA Kevin Frein and the probation officer do not oppose. It is signed by Assistant Federal Defender Scott T. Schmidt.

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
JACKSONVILLE DIVISION 
 
UNITED STATES OF AMERICA 
 
v. 
 
 
 
 
 
Case No. 3:23-cr-48-TJC-LLL  
 
 
 
 
 
 
 
 
 
 
 
 CHRISTOPHER LEO DARAGJATI 
________________________________________________________________________ 
 
UNOPPOSED MOTION TO CONTINUE SENTENCING 
 
 
Defendant, Christopher Daragjati, by and through undersigned counsel, 
files this unopposed motion to continue the Sentencing Hearing currently set 
for October 26, 2023, and states the following: 
1. 
On July 20, 2023, Mr. Daragjati entered a plea of guilty as to Counts 
One, Four, Eleven, Twelve, and Thirteen of the Indictment, pursuant 
to a plea agreement.  This Court accepted the plea and set a Sentencing 
Hearing for October 26, 2023.  On September 21, 2023, the Initial 
Presentence Investigation Report (“PSR”) was received by the parties.  
(Doc. 32).   
2. 
Since that time, the parties reviewed the Initial PSR and undersigned 
counsel reviewed it with Mr. Daragjati.  Given the nature of this case, 
the PSR contains information about intended and actual loss amounts 
attributable to Mr. Daragjati’s conduct.  Mr. Daragjati questions some 
of these amounts.  The accuracy of these amounts is essential for 
Case 3:23-cr-00048-TJC-LLL     Document 33     Filed 10/18/23     Page 1 of 3 PageID 151

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determining restitution owed and will most likely affect the guidelines 
calculations under USSG § 2B1.1(b)(1).   
3. 
The parties have been working diligently on verifying the exact loss 
amounts but have not been able to complete this work.  There are over 
2,000 pages of discovery, several law enforcement agencies, and various 
victims involved in this case.  The parties therefore believe that more 
time is necessary before a Final PSR is filed and a Sentencing Hearing 
is held. 
4. 
Undersigned counsel discussed the matter with AUSA Kevin Frein, 
Esq., and Probation Officer Joshua Blakely, and they do not oppose this 
request.   
5. 
This Motion is not made for the purpose of unduly delaying the 
proceedings, but to provide Mr. Daragjati with full and fair 
representation, and to provide Probation Officer Blakely ample time to 
review and respond to any PSR objections filed by undersigned counsel.  
 
THEREFORE, Mr. Daragjati requests that this Honorable Court 
continue the Sentencing Hearing in this case for a period of at least 30 days, 
on or after the week of November 27, 2023.  
 
Dated: October 18, 2023 
 
 
Case 3:23-cr-00048-TJC-LLL     Document 33     Filed 10/18/23     Page 2 of 3 PageID 152

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Respectfully submitted, 
 
  
 
 
A. FITZGERALD HALL, ESQ. 
Federal Defender, MDFL  
 
s/ Scott T. Schmidt 
 
 
 
Scott T. Schmidt, Esq.  
Assistant Federal Defender 
Florida Bar No. 92534  
200 West Forsyth Street, Suite 1240 
Jacksonville, FL 32202 
Telephone: (904) 232-3039 
Fax: (904) 232-1937 
Email: scott_schmidt@fd.org 
 
CERTIFICATE OF SERVICE  
I hereby certify that on this 18th day of October, 2023, a true copy of the 
foregoing was served by electronic notification to Assistant United States 
Attorney Kevin Frein, Esq., and to United States Probation Officer Joshua 
Blakely. 
 
/s/ Scott Schmidt 
 
 
 
Scott T. Schmidt, Esq.  
Assistant Federal Defender  
 
 
Case 3:23-cr-00048-TJC-LLL     Document 33     Filed 10/18/23     Page 3 of 3 PageID 153

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