Unopposed MOTION for Additional Time Before Sentencing by Daniel Joseph Tisone. (Eiglarsh,… — USA v. Tisone (Dkt. 58)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:22-cr-00039-SPC-NPM · Doc. 58 · 2022-08-29 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
FORT MYERS DIVISION 
 
UNITED STATES OF AMERICA  
CASE NO.: 2:22-CR-39-SPC-NPM 
 
vs. 
 
 
 
 
 
 
 
DANIEL JOSEPH TISONE 
 
 
 
 
 
/ 
 
UNOPPOSED MOTION FOR ADDITIONAL TIME BEFORE SENTENCING 
COMES NOW the defendant, Daniel Joseph Tisone, by and through undersigned 
counsel, pursuant to the Federal Rules of Criminal Procedure, and files this, his Unopposed 
Motion for Additional Time before Sentencing.   In support thereof, the defendant alleges 
the following: 
1. On August 26, 2022, Mr. Tisone pled guilty to counts two, eight, fourteen, and 
eighteen of the indictment.  
2. By pleading guilty, Mr. Tisone admitted, amongst other things, that he 
fraudulently obtained Government loan funds, in violation of 18 U.S.C, 1344.  
3. As the Government is aware, Mr. Tisone utilized a significant portion of the 
fraudulently obtained funds to purchase two pieces of Naples real estate. 
4. The two pieces of property are located at:  1) 550 Starboard Drive Naples, FL 
34103 and 2) 1001 10th Avenue South #10 Naples, FL 34102.  
5. With the approval and supervision of the Government, both properties were 
recently listed on the real estate market. 
6. Mr. Tisone expects the properties to be sold soon with the proceeds going directly 
to the Government to cover the full amount of restitution owed.  
7. Primarily due to summer travel, the properties have yet to be sold. The majority of 
potential purchasers have been away, yet are expected to return shortly.  
8. Mr. Tisone is requesting that sentencing be set in 90-120 days, to afford him a 
few additional months to sell the properties and to be able to inform the Court at 
sentencing that restitution has been paid in full.  
9. This motion is being filed in good faith without the intent to unnecessarily seek a 
delay in Mr. Tisone’s sentencing date.  
10. The Government does not oppose this motion.  
Case 2:22-cr-00039-SPC-NPM     Document 58     Filed 08/29/22     Page 1 of 2 PageID 239

WHEREFORE, based upon the above and foregoing, the Defendant respectfully 
requests this Court to grant the instant motion. 
 
I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically 
filed this 29th day of August, 2022.  
Respectfully submitted, 
 
 
 
 
 
LAW OFFICES OF MARK EIGLARSH 
 
 
 
 
 
3107 Stirling Road 
 
 
 
 
 
Suite 207 
 
 
 
 
 
Fort Lauderdale, Florida 33312 
 
 
 
 
 
Telephone: (954) 500-0003 
 
 
 
 
 
Facsimile:  (305) 674-0102 
 
 
 
 
 
Email: Mark@EiglarshLaw.com  
 
 
 
 
 
 
BY: _/S/_MARK EIGLARSH______________ 
 
 
 
 
 
 
MARK EIGLARSH 
 
 
 
 
 
 
Florida Bar No.: 956414 
 
 
Case 2:22-cr-00039-SPC-NPM     Document 58     Filed 08/29/22     Page 2 of 2 PageID 240

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