Second Motion to Continue Sentencing Hearing by Craig David Davis — USA v. Davis (Dkt. 47, E.D. Va.)

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U.S. District Court for the Eastern District of Virginia · No. 1:24-cr-00040-PTG · Doc. 47 · 2025-01-12 · Docket on CourtListener

Full text

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 
 
 
 
SECOND 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 
January 16, 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. 
On December 1, 2024, Mr. Davis, through counsel, filed a Motion to Continue his 
sentencing hearing. The motion was granted and his hearing was reset for January 16, 2025.  
Mr. Davis and his family both reside in Los Angeles, California. Although Mr. Davis 
resides in a separate residence from his children, he is a frequent visitor to their home.  
On January 7, 2025 a severe wildfire started in the Palisades area of Los Angeles, 
California. High winds, draught conditions, and other factors caused the fire to rapidly spread 
throughout the area. The firefighters have struggled to contain the fire and it continues to spread 
into additional areas of the city. As a result, county officials have issued mandatory evacuation 
orders to residents in harms way.   
Case 1:24-cr-00040-PTG     Document 47     Filed 01/12/25     Page 1 of 3 PageID# 265

Mr. Davis and his children were evacuated from their homes and were forced to take 
shelter away from the area. The evacuation occurred on Thursday and his children have not been 
allowed to return home. According to reports, the fire is only 11% contained as of the filing of 
this motion. Considering the ongoing emergency, Mr. Davis requests that this Court continue his 
sentencing hearing, so that he can tend to and support his family during this extremely difficult 
time. To be clear, Mr. Davis is now allowed to return to his residence, but has been staying at an 
Airbnb with his ex-wife and three children. Neither location has electricity at this time. Mr. 
Davis nor his e- wife have fire insurance and are distraught about the possibility that the fire may 
destroy their homes and personal property.  
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.  
 
 
 
 
 
 
 
Respectfully submitted, 
    
 
 
 
 
 
 
CRAIG DAVIS 
 
 
 
 
 
 
 
By Counsel 
 
 
By:_ ___/s/___________ 
     
 
 
 
 
 
 
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 January 12, 2025 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  
Case 1:24-cr-00040-PTG     Document 47     Filed 01/12/25     Page 2 of 3 PageID# 266

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  
 
 
 
 
Case 1:24-cr-00040-PTG     Document 47     Filed 01/12/25     Page 3 of 3 PageID# 267

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