Court filing
Motion to Continue sentencing date by Daniel Joseph Tisone — USA v. Tisone (Dkt. 62, M.D. Fla. No. 2:22-mj-01043, docketed in No. 2:22-cr-00039)
Filed October 25, 2022 in USA v. Tisone; one of 73 filings from this case.
Record facts
| Court | U.S. District Court for the Middle District of Florida |
|---|---|
| Filed | 2022-10-25 |
U.S. District Court for the Middle District of Florida · No. 2:22-cr-00039-SPC-NPM · Doc. 62 · 2022-10-25 · Docket on CourtListener
Full text
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 / MOTION TO CONTINUE SENTENCING DATE COMES NOW the defendant, Daniel Joseph Tisone, by and through undersigned counsel, pursuant to the Federal Rules of Criminal Procedure and files this, his Motion to Continue Sentencing Date. In support thereof, the defendant alleges the following: 1. This matter is currently set for sentencing on December 5, 2022, at 10:00 am. 2. Since the inception of this case, Mr. Tisone’s plan is to sell two properties that he currently has listed on the market, in order to pay back to the Government the entire amount of restitution owed in this case. 3. Unfortunately, Hurricane Ian caused both properties significant damage. Additionally, it’s shaken up the real estate market. 4. Mr. Tisone is requesting additional time to repair both properties and to get them sold in order to pay back full restitution. 5. On October 19, 2022, undersigned was contacted by probation officer Nick Stevens, who is preparing the PSI in this case. He explained to undersigned how the storm adversely affected him and that he would be greatly assisted if the Court granted a continuance. That would afford him additional time to prepare the PSI that is due on October 31, 2022. 6. AUSA Trent Reichling has no objection to a continuance of the sentencing. However, Mr. Reichling is only willing to agree to an additional 30 days. 7. Undersigned is requesting a 90 day continuance. 8. Mr. Tisone continues to abide by all the terms of his release. Case 2:22-cr-00039-SPC-NPM Document 62 Filed 10/25/22 Page 1 of 2 PageID 245 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 25th day of October, 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 62 Filed 10/25/22 Page 2 of 2 PageID 246
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