Consent Motion to Continue Sentencing Hearing by Craig David Davis — USA v. Davis (Dkt. 42, E.D. Va.)

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IN THE UNITED STATES DISTRICT COURT FOR THE 
EASTERN DISTRICT OF VIRGINIA 
Alexandria Division 
 
UNITED STATES OF AMERICA 
v. 
 
CRAIG DAVIS, 
Defendant. 
Case No.: 1:24CR-40 
 
 
 
UNOPPOSED MOTION TO CONTINUE SENTENCING HEARING 
 
COMES NOW, the defendant, Craig Davis, by and through counsel, and hereby 
respectfully moves this Honorable Court to continue his sentencing date currently scheduled for 
December 12, 2024. In support of his Motion, the defendant hereby states as follows: 
On August 28, 2024 the defendant appeared before this court and entered a guilty plea to 
one count of wire fraud. On the same date, this Court scheduled Mr. Davis’ sentencing hearing 
for December 12, 2024. 
Since his plea agreement, Mr. Davis has been actively working on several different areas 
of mitigation that would be relevant to his sentencing factors. Mr. Davis is requesting additional 
time to continue with these efforts in preparation of his sentencing hearing. Due to the nature of 
the mitigation, Mr. Davis is requesting additional time to ensure that he is able to maximize his 
efforts.  
Mr. Davis has been fully compliant with all terms of his pre-trial release and plea 
agreement. In addition, Mr. Davis has had continuous communication with defense counsel. 
Defense Counsel has advised the Government of this motion and they have indicated that 
they have no objection to this request to continue the sentencing hearing.  
WHEREFORE, the Defendant respectfully prays that this Honorable Court grant his 

Motion to Continue the sentencing hearing to a date consistent with the Court’s availability and 
parties’ schedule. After conferring, the parties believe that a sentencing in February or early 
March would be sufficient.   
 
 
 
 
 
 
 
Respectfully submitted, 
    
 
 
 
 
 
 
CRAIG DAVIS 
 
 
 
 
 
 
 
By Counsel 
 
 
By:_ ______________ 
     
 
 
 
 
 
 
Jonathan A. Simms, Esq 
 
                                                    
 
 
The Simms Firm, PLC 
 
 
 
 
 
     
 
11325 Random Hills Road 
 
 
 
 
 
     
 
Suite 360 
 
 
 
 
 
     
 
Fairfax, Virginia 22030 
 
 
 
 
 
    
 
(703) 383-0636 
 
 
 
 
 
                        (703) 225-3333 (Fax)  
 
 
 
 
 
  
                        jsimms@simmsfirm.com 
 
 
 
CERTIFICATE OF SERVICE 
 
 
I hereby certify that on December 1, 2024 I will electronically file the foregoing pleading 
with the Clerk of the Court using the CM/ECF system, which will then send notification of such 
filing (NEF) to the following, or in the alternative, will deliver the foregoing to: 
 
AUSA David Peters 
U.S. Department of Justice  
Criminal Division 
Fraud Section  
Market Integrity & Major Frauds Unit 
(202) 616-5420 (o)  
David.Peter2@usdoj.gov 
 
 
 
 
 
 
/s/__________ 
 
 
 
 
 
 
Jonathan A. Simms, Esq 
 
The Simms Firm, PLC 
11325 Random Hills Road 
Suite 360 
Fairfax, Virginia 22030 
P:(703) 383-0636 
F:( 703) 225-3333 
jsimms@simmsfirm.com

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