Court filing

Consent Motion to Continue Sentencing — USA v. Stanley et al. (Dkt. 35, N.D. Fla.)

Filed September 28, 2022 in Felicia Stanley; one of 29 filings from this case.

Record facts

Court	U.S. District Court for the Northern District of Florida
Filed	2022-09-28

U.S. District Court for the Northern District of Florida · No. 4:22-cr-00032-MW-MAF · Doc. 35 · 2022-09-28 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF FLORIDA
TALLAHASSEE DIVISION

UNITED STATES OF AMERICA,

vs.

CASE NO.: 4:22-cr-32-MW/MAF

FELICIA JACKSON STANLEY
and
WILBERT JEAN STANLEY, III,

Defendants.
______________________________/

UNOPPOSED MOTION TO CONTINUE SENTENCING

COMES NOW the undersigned attorney and files this Unopposed Motion to Continue
Sentencing on behalf of the Defendants and would state as follows:
1) The above-styled matter is presently calendared for sentencing the afternoon of October 7,
2022.
2) Mr. Stanley is in the process of being evaluated by Dr. Stephen Zieman. Dr. Zeiman is a
neuro-psychologist who practices in Pensacola, Florida.
3) Counsel has undertaken this evaluation because of brain damage Mr. Stanley suffered at a
relatively young age in conjunction with other major trauma (electrocution, months long
hospitalization, skin grafts, death of mother and death of sister all within 9-12 month period
of time during formative teen years).
4) It goes without saying that this information is important for the Court’s consideration of
the §3553(a) factors, but the undersigned has asked an expert to participate in order to
better explain Mr Stanley’s cognition and overall circumstances.
Case 4:22-cr-00032-MW-MAF Document 35 Filed 09/28/22 Page 1 of 3

5) Dr. Zieman generally advised counsel that his schedule was such that late November or
early December would be the soonest he could have everything accomplished to testify
before the Court.
6) The undersigned is scheduled to be in a 2 ½ week First Degree Murder trial in State of
Florida v. Zachary Abell in Franklin County, Florida that will commence after the
Thanksgiving holiday. This is a matter specially set with witnesses from across the country
and a co-defendant with their counsel. The case is a 2018 case where the Defendants are
in custody.
7) The foregoing is a long way of requesting a continuance until January. This will allow for
a proper sentencing presentation that contemplates the individual circumstances of each
Defendant as well as their respective roles and culpabilities.
8) The undersigned has conferred with Assistant United States Attorney Justin Keen and he
has no objection. The request for a continuance is made in good faith and not solely for
the purposes of delay.
9) United States Probation Officer April McCommon has been incredibly patient with the
undersigned because of her own obligations to the Court.

CERTIFICATE OF COMPLIANCE
The undersigned Counsel certifies, pursuant to Rule 7.1(B), Local Rules, United States
District Court for the Northern District of Florida, that he has conferred with Assistant United
States Attorney Justin Keen, and he has no objection to the relief sought in this motion. This
pleading is 484 words.

Case 4:22-cr-00032-MW-MAF Document 35 Filed 09/28/22 Page 2 of 3

RESPECTFULLY SUBMITTED,

/s/ Robert A. Morris

ROBERT A. MORRIS, ESQUIRE

Florida Bar No. 0144680
The Law Offices of Robert A. Morris, LLC

911 East Park Avenue

Tallahassee, Florida 32301

(850) 792-1111 Facsimile (850) 792-1113

ATTORNEY FOR DEFENDANTS

alex@ramlawyer.com

efiling@ramlawyer.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy hereof has been furnished by Electronic Mail to: Justin
M. Keen, Assistant United States Attorney, United States Attorney's Office, 111 N. Adams Street,
Tallahassee, Florida 32301 at justin.keen@usdoj.gov on this 28th day of September, 2022.