Unopposed Motion (Second) to Continue Sentencing Hearing by Christopher Leo Daragjati — USA v. Daragjati (Dkt. 35, M.D. Fla.)

Record facts

U.S. District Court for the Middle District of Florida · No. 3:23-cr-00048-TJC-LLL · Doc. 35 · 2023-12-22 · Docket on CourtListener

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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 
______________________________________/ 
 
SECOND UNOPPOSED MOTION TO 
CONTINUE SENTENCING HEARING 
 
Defendant, Christopher Daragjati, pursuant to Local Rule 3.08, 
Middle District of Florida, requests this Court to continue the Sentencing 
Hearing scheduled for Wednesday, January 17, 2024, at 3:00 PM, and as 
grounds states the following: 
1. 
On July 20, 2023, Mr. Daragjati entered pleas of guilty to Counts 
One, Four, Eleven, Twelve, and Thirteen of the Indictment, pursuant to a plea 
agreement.  (Doc. 26).  This Court accepted the plea and set a Sentencing 
Hearing for October 26, 2023.  (Doc. 29).  On October 19, 2023, this Court 
granted Mr. Daragjati’s Unopposed Motion to Continue the Sentencing 
Hearing due the parties needing further time to prepare.  (Doc. 34).  The 
Sentencing Hearing was reset to January 17, 2024, at 3:00 PM. 
2. 
Undersigned counsel is an expectant father and due to a recent 
change in medical circumstances, his daughter will be born earlier than 
originally anticipated.  As a result, he will be on leave starting at the end of 
Case 3:23-cr-00048-TJC-LLL     Document 35     Filed 12/22/23     Page 1 of 3 PageID 157

 
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December 2023, until early February 2024.  Undersigned will then return to 
work for a period ending Friday, March 22, 2024.  Starting on Monday, March 
25, 2024, undersigned will be begin an additional eight weeks of leave, with a 
planned return to work on Monday, May 20, 2024. 
3. 
Undersigned respectfully requests that this Court continue the 
Sentencing Hearing to a date falling within the period that he returns to work 
after the first part of his leave.  This Motion is made in good faith and not for 
the purpose of unduly delaying the proceedings. 
4. 
Undersigned discussed this matter with Mr. Daragjati and 
provided him with a few options, including having another attorney handle 
the Sentencing Hearing.  Mr. Daragjati would like undersigned to represent 
him at sentencing and consents to the Sentencing Hearing being delayed. 
5. 
Undersigned discussed this matter with Assistant United States 
Attorney Kevin Frein, Esq., and he does not oppose a continuance of the 
Sentencing Hearing.   
THEREFORE, undersigned counsel respectfully requests that this 
Court continue the Sentencing Hearing to a date sometime between 
Monday, February 12, 2024, and Friday, March 22, 2024.   
MEMORANDUM OF LAW 
 
Local Rule 3.08(a), Middle District of Florida, provides that a party must 
timely move for a continuance and explain in detail the reason a continuance is 
Case 3:23-cr-00048-TJC-LLL     Document 35     Filed 12/22/23     Page 2 of 3 PageID 158

 
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warranted and the effort to resolve any scheduling conflict. 
 
      A. FITZGERALD HALL, ESQ. 
      FEDERAL DEFENDER 
      MIDDLE DISTRICT OF FLORIDA 
 
      Respectfully Submitted By: 
 
 
                                                            
                                                                 Scott T. Schmidt, Esq. 
     Assistant Federal Defender 
     Fla. Bar No. 92534 
     200 West Forsyth Street        
     Suite 1240 
     Jacksonville, Florida 32202 
     Telephone: (904) 232 3039 
     Fax: (904) 232 1937 
     Email: Scott_Schmidt@fd.org 
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that undersigned electronically filed the foregoing 
with the Clerk of Court and sent notice to Assistant U.S. Attorney Kevin Frein, 
Esq., and Probation Officer Joshua, this the 22nd day of December, 2023.    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
                                                
 
 
 
 
 
 
 
Assistant Federal Defender 
 
Case 3:23-cr-00048-TJC-LLL     Document 35     Filed 12/22/23     Page 3 of 3 PageID 159

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