Agreed Motion for Extension of Time to File Objections to PSI re 232 Order — USA v. Sheppard (Dkt. 233, S.D. Fla.)

Summary

Sheppard's Unopposed Motion to Extend Time (Until May 9, 2024) to File Objections to the Presentence Investigation Report and a Sentencing Memorandum, Document 233, filed April 26, 2024, in United States of America v. Eric Dean Sheppard, No. 1:22-cr-20290-BB, U.S. District Court for the Southern District of Florida. The motion states that sentencing is scheduled for June 7, 2024, and asks for an 8-day extension of the current deadlines. It gives as the reason that undersigned counsel was engaged in a two-plus week trial that ended on April 23, 2024, and has a May 1, 2024, brief deadline in another case. It states that government counsel has no objection and concurs in a schedule of May 9, 2024, and May 23, 2024.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FORIDA 
CASE No. 22-20290-CR-BLOOM 
 
UNITES STATES OF AMERICA, 
v.  
ERIC DEAN SHEPPARD, 
 
Defendant. 
_________________________________/ 
 
SHEPPARD’S UNOPPOSED MOTION TO EXTEND TIME  
(UNTIL MAY 9, 2024) TO FILE OBJECTIONS TO THE  
PRESENTENCE INVESTIGATION REPORT AND  
A SENTENCING MEMORANDUM 
 
Defendant Eric Dean Sheppard’s sentencing is scheduled for June 7, 2024. 
DE#231. Currently, Sheppard’s objections and sentencing memorandum are due on 
May 1; the government’s response and sentencing memorandum are due on May 15. 
DE#232.  
Defendant is moving this court for an 8-day extension of the current deadlines 
because, for the last several weeks, undersigned counsel (Srebnick) was fully 
engaged in a two-plus week trial before Judge Williams, which ended on Tuesday 
April 23, 2024. U.S. v Polit, 22-20114-KMW (S.D. Fla.). Judge Williams required 
the defendant to voluntarily surrender (which he did) and invited undersigned to file 
a post-verdict motion for release pending sentencing, which undersigned has been 
working on since Tuesday. Moreover, undersigned has a May 1, 2024, deadline to 
finalize and file a 20,000-word brief in the U.S. Court of Appeals for the Tenth 
Circuit in U.S. v. Dermen, 23-4074 (10th Cir.), in which the defendant-appellant is 
Case 1:22-cr-20290-BB   Document 233   Entered on FLSD Docket 04/26/2024   Page 1 of 2

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in custody, and the Court has advised that no extensions will be granted absent 
“extraordinary circumstances.” 
Government counsel advised that they have no objection to this motion and 
concur in the following schedule: objections to the PSI by either party and 
Sheppard’s sentencing memorandum shall be filed by May 9, 2024; responses to the 
objections by either party and the government’s sentencing memorandum shall be 
filed by May 23, 2024. Sentencing would remain scheduled for June 7, 2024. 
BLACK SREBNICK 
201 South Biscayne Boulevard, Suite 1300  
Miami, Florida 33131 / Tel. (305) 371-6421  
 
/s/ Howard Srebnick             
HOWARD SREBNICK  
  Florida Bar No. 919063  
  E-mail: HSrebnick@RoyBlack.com  
 
 
Case 1:22-cr-20290-BB   Document 233   Entered on FLSD Docket 04/26/2024   Page 2 of 2

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