Unopposed Motion to Continue Sentencing Hearing by Derek James Acree. Responses due by 1/3/2023 — USA v. Acree (Dkt. 20, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 9:22-cr-80157-AHS · Doc. 20 · 2022-12-20 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.:  22-CR-80157-AHS 
 
UNITED STATES OF AMERICA, 
 
 
Plaintiff, 
vs. 
 
DEREK JAMES ACREE, 
 
 
 Defendant. 
___________________________________/ 
 
UNOPPOSED MOTION TO CONTINUE SENTENCING 
 
 
COMES NOW, the Defendant, DEREK JAMES ACREE, by and through his 
undersigned counsel, and hereby respectfully submits the instant unopposed motion to continue 
sentencing of the Sentencing Hearing set for January 4, 2023 at 10:00 AM and as grounds 
therefore would state as follows:   
 
1. 
The defendant is charged with conspiracy to commit wire fraud, 18 U.S.C. § 
1349.  A change of plea was heard before this Honorable Court on October 11, 2022.   
2. 
The Government and the defense agree that a postponement of the sentencing for 
approximately 60 days will provide additional time to address ongoing matters of concern to all 
parties, including, but not limited to, the ongoing prosecution, and the satisfaction of  financial 
matters important to both parties.   
3. 
Mr. Acree is currently receiving mental health and substance abuse counselling 
and achieving excellent results.   
4. 
This additional time will also provide the benefit of affording the Defendant the 
opportunity to address significant restitution/forfeiture demands.   
 
Case 9:22-cr-80157-AHS   Document 20   Entered on FLSD Docket 12/20/2022   Page 1 of 2

5. 
Defense counsel has been in contact with Robin Waugh, AUSA who is in 
agreement with the requested continuance of 60 days or whatever the Court deems appropriate.   
6. 
Defense counsel has spoken with his client about the instant request for a 
continuance, and Mr. Acree concurs with the request.    
 
WHEREFORE, Defendant, DEREK JAMES ACREE, respectfully requests a 
continuance of the sentencing in this matter for a period of 60 days or for whatever period of 
time the Court deems appropriate. 
 
I HEREBY CERTIFY that on December 20, 2022, I electronically filed the foregoing 
document with the Clerk of Court using CM/ECF.  I also certify that the foregoing document is 
being served this day on all counsel of record via transmission generated by CM/ECF.   
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
CHRISTOPHER A. HADDAD 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
chris@chrishaddad.com 
 
 
 
 
 
 
319 Clematis Street, Suite 812 
 
 
 
 
 
 
West Palm Beach, FL   33401 
 
 
 
 
 
 
(561) 832-1126 
 
 
 
 
 
 
chris@chrishaddad.com 
 
 
 
 
 
 
 
 
 
 
 
BY: /s/ Christopher  A. Haddad                                  
 
 
 
 
 
 
         CHRISTOPHER A. HADDAD    
 
 
 
 
 
 
         Florida Bar No.: 0879592 
Case 9:22-cr-80157-AHS   Document 20   Entered on FLSD Docket 12/20/2022   Page 2 of 2

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