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Home Court filings USA v. Lattany Stipulation and Motion for Extension of Self Surrender Date by Dejane Reaniece Lattany — USA v. Lattany (Dkt. 37, D. Colo.)

Court filing

Stipulation and Motion for Extension of Self Surrender Date by Dejane Reaniece Lattany — USA v. Lattany (Dkt. 37, D. Colo.)

Filed September 19, 2023 in USA v. Lattany; one of 77 filings from this case.

Record facts

CourtU.S. District Court for the District of Colorado
Filed2023-09-19

U.S. District Court for the District of Colorado · No. 1:23-cr-00074-NYW · Doc. 37 · 2023-09-19 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR DENVER DISTRICT OF COLORADO  
UNITED STATES OF AMERICA, 
  )     No. 1:23CR00074-1 
PlainƟff,          
  ) 
v.     
  )       STIPULATION AND ORDER FOR 
   )    EXTENSION OF SELF SURRENDER DATE    
DEJANE REANIECE LATTANY    
 ) 
Defendant.         
 )   
 Judge: Nina Y. Wang 
   ) 
   ) 
MOTION TO EXTEND SELF-SURRENDER DATE PURSUANT TO FEDERAL RULE 38 
Ms. DEJANE REANIECE LATTANY, Defendant, Pro se [HERINAFTER REFERRED TO AS DEFENDANT].COMES 
NOW, and respecƞully requests this Honorable Court to grant the MoƟon to extend the self-surrender 
date FROM SEPTEPMBER 28,2023 TO November 30th, 2023 based on FEDERAL RULE 38 and other 
following circumstances.  
1.
Background: On August 15, 2023 this Court sentenced me to surrender to the insƟtuƟon
designated by the United States Bureau of Prisons for service of sentence of 48 months
imprisonment and ordered the Defendant to voluntarily surrender to the designated insƟtuƟon
of FCI Victorville Satellite Camp, 13777 Air Expressway, Victorville, California on September 28,
2023, by 12:00pm.
2.
Reason for Extension:
A) The defendant is a single mother of 3 minor children ranging from 1 year to 11 years old.
Therefore, in order to arrange for the defendant’s children to receive the proper care and
environment during the defendant’s absence, it is necessary for such extension to be granted in
order to arrange the preparaƟon of their stay with family. In order for the children to go through
this separaƟon from the defendant, it is imperaƟve that the Ɵme to prepare the defendant’s
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 1
of 17
FILED 
UNITED STATES DISTRICT COURT 
DENVER, COLORADO 
 
JEFFREY P. COLWELL, CLERK 
8:32 am, Sep 19, 2023

children and family is granted. In addiƟon, the defendant’s 1 year old is in need of the Ɵme to 
properly wean off of his regular supply and comfort of breasƞeeding. The defendant also has a 
series of court hearings to protect her children. (See Exhibit A with case number for children) 
B) The defendant is scheduled to graduate from University of Phoenix on October 7th 2023. 
GraduaƟon represents not only the culminaƟon of more than 4 years of rigorous academic work 
but also a significant milestone for her children and family. The defendant wishes to parƟcipate 
in the graduaƟon ceremony which would provide a sense of closure and fulfillment before 
serving the imposed sentence. Upon the exit of the defendant’s sentence, the earned degree 
will enable the defendant to be a producƟve member of society, become an asset to her 
community and obtain and maintain employment to support her children and family. In addiƟon 
to graduaƟon, the defendant has had the honor of being inducted into the NaƟonal Honors 
Society chapter of the University of Phoenix. The defendant would like Ɵme to complete the 
outstanding required tasks for the inducƟon to take place before serving the sentence. The 
defendant will uƟlize the skills learned from the inducƟon to become a posiƟve leader and 
ciƟzen while helping others to make posiƟve changes in their lives. (See EXHIBIT B1-B2 for proof 
of graduaƟon and inducƟon)  
C) In addiƟon, the defendant asks that the court take into consideraƟon that the defendant’s 
pervious counsel Jason Flores Williams completed duty in informing the defendant that she 
would be sentenced to a facility located in Colorado, where the defendant’s family and children 
are. Upon receiving the order from the court that defendant would be sentenced in a completely 
different state, the defendant requests to have Ɵme to help children and family to wrap up 
personal and family affairs for the well-being of the defendant’s children. In addiƟon, As 
previously stated, the defendant received noƟce that the former atorney Jason Flores-Williams 
terminated their representaƟon without providing defendant with crucial documents necessary 
for the defendant’s CASE and APPEAL.  Specifically, the defendant was not provided with the 
needed Judgement and Commit Order, Pre-Sentence Report (PSR) prior to sentencing, and only 
received both the PSR and sentencing memorandum aŌer the sentencing had taken place. 
Defendant received the Judgement and Comment order and BOP designaƟon in the mail on 
September 12th. Within the event of the defendant’s atorney withdrawing without proper 
communicaƟon, the defendant has been leŌ to put together this moƟon and appeal without 
understanding important elements of the case. The defendant understands the importance of 
adhering to the court's schedule and procedures. If there are specific steps or formaliƟes 
necessary to grant an extension to surrender, please let the defendant know, and the defendant 
will ensure prompt compliance. 
3. No Prior Requests: This is the defendant’s first request for an extension of the self-surrender 
date, and it is based on a unique, non-recurring event. 
4. Request for Extension: Respecƞully, the Defendant humbly requests the court to grant this 
moƟon for extension of the self-surrender date September 28, 2023 to November 30, 2023. If 
this moƟon is granted, the defendant will uƟlize the extended Ɵme to ensure that upon the exit 
of the sentence, the defendant will be a guaranteed asset to the community and a producƟve 
ciƟzen of society.  
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 2
of 17

5. No Risk to the Community or Flight Risk: The defendant has complied with all condiƟons of 
pretrial release, has no history of failing to appear, and poses no risk to the community. The 
defendant’s commitment to compleƟng the educaƟonal program and achieving this milestone 
demonstrates a dedicaƟon to personal development and societal contribuƟons. GranƟng this 
moƟon would not diminish the seriousness of the offense or the imposed sentence, but instead 
allow the defendant to achieve important personal and academic milestones. 
6. Federal Rule 38: Pursuant to Federal Rule of Criminal Procedure 38(b)(2), the Court has the 
discreƟon to order a defendant's self-surrender at a later date. Given the unique and significant 
nature of her children, college graduaƟon, naƟonal honors society inducƟon and terminaƟon of 
counsel, the Defendant believes the circumstances warrant the Court's gracious consideraƟon of 
this request. 
 
WHEREFORE, the Defendant DEJANE REANIECE LATTANY, respecƞully requests that this Honorable Court 
grant the MoƟon to Extend Self-Surrender Date, allowing the Defendant to properly prepare children 
and family for the defendant’s absence, to ensure a healthy and safe environment for the children and to 
parƟcipate in the graduaƟon ceremony, complete Chapter inducƟon and family business and thereaŌer 
voluntarily surrender to the designated insƟtuƟon on November 30th 2023. 
 
Respecƞully submited, 
DEJANE REANIECE LATTANY, Pro se 
11125 Quintero Ct Commerce City Colorado 80022 
720-318-0173 
dejane_latany@msn.com 
 
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 3
of 17

EXHIBIT A 
 
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 4
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EXHIBIT A 
This is the case number that is atached to the set of hearings menƟoned to 
protect my children.  
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 5
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Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CSKRGNDQW
Name
Dejane Lattany
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
1 / 10
EXHIBIT B1
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 6
of 17

Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CPVH1F8XT
Name
Matt Hogan
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
2 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 7
of 17

Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CVXCDP08S
Name
Jaraine Lattany
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
3 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 8
of 17

Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CDWL9SHP8
Name
Floritta Lattany
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
4 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 9
of 17

Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CSMR61W2Y
Name
Ty Lattany
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
5 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 10
of 17

Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CDT7N63SX
Name
Nova Hogan
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
6 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 11
of 17

Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CHYZD971J
Name
Anezshe Lattany
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
7 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 12
of 17

Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CBLQSXCFP
Name
Tenea Lattany
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
8 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 13
of 17

Your tickets
Organized by
University of Phoenix
University of Phoenix Southern California Commencement -
3:30pm
Honda Center
2695 E Katella Ave, Anaheim, CA 92806, USA
CK6230WCM
Name
Dejane Lattany
Ticket type
General Admission
Purchased by
dejane_lattany@msn.com
Ticket description
There will be no assigned seating.
Event Note
University of Phoenix, Inc. shall have the unrestricted right, and such right shall not be revoked by Holder, to use and
exploit without any further obligation to Holder, the Holder's image, voice, and likeness, actions and statements (and
to edit each and all in any manner fiction or non-fiction) as it appears in any film, photograph, broadcast, telecast,
and/or recording made in connection with the Event in any manner, in all media, worldwide, in perpetuity, including
without limitation, in any advertisements or promotional materials for University of Phoenix, Inc. or any of its
subsidiaries or affiliates without further authorization.
9 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 14
of 17

Your order receipt
Order details
Buyer
Dejane Lattany
Event
University of Phoenix Southern California Commencement - 3:30pm
Location
2695 E Katella Ave, Anaheim, CA 92806, USA
Payment Information
Items
Unit price
Quantity
Total
General Admission
Free
9
$0.00 USD
Total
Free
Reference ID: 6505bf73b1ac4043b4686f7a
We have sent you a confirmation email to dejane_lattany@msn.com
10 / 10
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 15
of 17

 
EXHIBIT B2 
 
 
 
 
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 16
of 17

 
Case No. 1:23-cr-00074-NYW     Document 37     filed 09/19/23     USDC Colorado     pg 17
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  1. Proposed Order (PDF Only) — USA v. Lattany (Dkt. 37.1)same docket · 2023-09-19
  2. Order Granting 34 Leave to Proceed in Forma Pauperis as to Dejane Reaniece Lattany — USA v. Lattany (Dkt. 35, D. Colo.)same docket · 2023-09-11
  3. Notice of Appearancesame docket · 2023-09-20
  4. Motion and Affidavit for Leave to Proceed on Appeal Pursuant to 28 U.S.C. § 1915 and Fed — USA v. Lattany (Dkt. 34, D. Colo.)same docket · 2023-09-06
  5. Response to Motion by USA as to Dejane Reaniece Lattany re 37 Motion for Order — USA v. Lattany (Dkt. 40, D. Colo.)same docket · 2023-09-22
  6. Minute Order on Pro Se Extension Letter — USA v. Lattany (D. Colo.)same docket · 2023-09-01
  7. Order on Motion for Extension of Self-Surrender Date as to Dejane Reaniece Lattany — USA v. Lattany (Dkt. 41, D. Colo.)same docket · 2023-09-25
  8. Voluntary Surrender ORDER Supplementing Judgment as to Dejane Reaniece Lattany;… — USA v. Lattany (Dkt. 32)same docket · 2023-09-01
  9. AMENDED VOLUNTARY SURRENDER ORDER SUPPLEMENTING JUDGMENT as to Dejane Reaniece Lattany;… — USA v. Lattany (Dkt. 42)same case · 2023-09-25
  10. Letter re: Request for Extension of Appeal Response Deadline by Dejane Reaniece Lattany — USA v. Lattany (Dkt. 30, D. Colo.)same case · 2023-08-29
  11. Motion to Modify 42 Order to Surrender, by Dejane Reaniece Lattany — USA v. Lattany (Dkt. 43, D. Colo.)same case · 2023-10-26
  12. Motion to Withdraw as Counselsame case · 2023-08-21
  13. Order on Motion to Modify Self-Surrender Order by Judge Nina Y. Wang — USA v. Lattany (Dkt. 44, D. Colo.)same case · 2023-10-27
  14. Judgment as to defendant Dejane Reaniece Lattany — USA v. Lattany (Dkt. 27, D. Colo.)same case · 2023-08-21
  15. SECOND AMENDED VOLUNTARY SURRENDER ORDER SUPPLEMENTING JUDGMENT By Judge Nina Y.… — USA v. Lattany (Dkt. 45)same case · 2023-10-27
  16. Courtroom Minutes for Sentencing Hearing — USA v. Lattany (Dkt. 25, D. Colo.)same case · 2023-08-15
  17. Motion to Vacate, Set Aside, Or Correct Sentence Pursuant to 28 U.S.C. — USA v. Lattany (Dkt. 46, D. Colo.)same docket · 2023-11-13
  18. Exhibit 2 — USA v. Lattany (Dkt. 24.2)same docket · 2023-08-08
  19. Motion for Appointment of Counsel by Dejane Reaniece Lattany — USA v. Lattany (Dkt. 47, D. Colo.)same docket · 2023-11-13
  20. Exhibit 1 — USA v. Lattany (Dkt. 24.1)same docket · 2023-08-08

Part of: U.S. District Court for the District of Colorado · Paycheck Protection Program (PPP) · COVID Economic Injury Disaster Loans (EIDL) · Criminal prosecutions · Motions · 2023 · Court filings

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