Unopposed Motion to Continue Sentencing by USA as to Christopher Leo Daragjati — USA v. Daragjati (Dkt. 38, M.D. Fla.)

Record facts

U.S. District Court for the Middle District of Florida · No. 3:23-cr-00048-TJC-LLL · Doc. 38 · 2024-03-04 · 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 
 
 
UNOPPOSED MOTION TO CONTINUE SENTENCING 
 
The United States of America, by Roger B. Handberg, United States Attorney 
for the Middle District of Florida files this unopposed motion to continue the 
sentencing hearing in this case, now set for March 13, 2024, and in support of its 
motion states as follows: 
 
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, which has subsequently been rescheduled to January 17, 2024, and 
February 28, 2024.   
 
2. 
The undersigned now expects to be out of the state from March 8 – 
March 15, 2024, and seeks a short continuance of the sentencing hearing until the 
following week, if the Court is available, based on this recent development.  
 
3. 
The undersigned discussed the matter with defense counsel, Scott T. 
Schmidt, Esq., and he does not oppose this request.  
 
Case 3:23-cr-00048-TJC-LLL     Document 38     Filed 03/04/24     Page 1 of 4 PageID 163

 
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4. 
Assuming the motion is granted the parties recognize that the Court 
will decide a new sentencing date and time. To the extent the Court is available the 
undersigned and Mr. Schmidt discussed proposed dates and times both parties are 
available for a rescheduled sentencing hearing. In an effort to resolve potential 
scheduling conflicts and make the continuance as short as practicable, those dates 
and times are listed below: 
 
Monday, March 18th, 2024, any time before 12:00; 
 
Tuesday, March 19th, any time after 1:00; and  
 
Wednesday, March 20th, any time after 3:00.    
 
5. 
This motion is not made for the purpose of unduly delaying the 
sentencing proceeding. Local Rule 3.08 provides that a party may move for a 
continuance by explaining the reason a continuance is warranted.  
 
 
 
 
 
 
 
 
 
 
Case 3:23-cr-00048-TJC-LLL     Document 38     Filed 03/04/24     Page 2 of 4 PageID 164

 
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WHEREFORE, the United States requests that the Court grant a short 
continuance of the sentencing hearing scheduled for March 13, 2024.  
Respectfully submitted, 
 
ROGER B. HANDBERG 
United States Attorney 
 
 
By: 
 /s/ Kevin C. Frein                 
KEVIN C. FREIN 
Assistant United States Attorney 
Florida Bar No. 0149144 
300 N. Hogan Street, Suite 700 
Jacksonville, Florida 32202 
Telephone: (904) 301-6300 
Facsimile: 
(904) 301-6310 
E-mail:  
Kevin.Frein@usdoj.gov 
 
Case 3:23-cr-00048-TJC-LLL     Document 38     Filed 03/04/24     Page 3 of 4 PageID 165

 
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U.S. v. Christopher Leo Daragjati 
 
 
Case No. 3:23-cr-48-TJC-LLL 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that on March 4, 2024, I electronically filed the foregoing with 
the Clerk of the Court by using the CM/ECF system which will send a notice of 
electronic filing to the following: 
 
Scott T. Schmidt, Esquire. 
 
 
 
/s/ Kevin C. Frein               
KEVIN C. FREIN 
Assistant United States Attorney 
 
Case 3:23-cr-00048-TJC-LLL     Document 38     Filed 03/04/24     Page 4 of 4 PageID 166

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