Court filing

Motion to Continue Sentencing by Wilbert Jean Stanley — USA v. Stanley et al. (Dkt. 48, N.D. Fla.)

Filed January 19, 2023 in Felicia Stanley; one of 29 filings from this case.

Record facts

Court	U.S. District Court for the Northern District of Florida
Filed	2023-01-19

U.S. District Court for the Northern District of Florida · No. 4:22-cr-00032-MW-MAF · Doc. 48 · 2023-01-19 · 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 February
9, 2023.
2) Mr. Stanley has been evaluated by Dr. Stephen Zieman. Dr. Zeiman is a neuropsychologist
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) Sentencing was previously scheduled in January and was moved to the present date due to
the Court’s busy calendar. The undersigned neglected to confer with Dr. Zieman as to his
availability for the newly scheduled date. Dr. Zieman is unavailable on February 9, 2023,
due to a memorial service for a family member in North Carolina.
Case 4:22-cr-00032-MW-MAF Document 48 Filed 01/19/23 Page 1 of 3

5) Counsel believes Dr. Zieman’s testimony is important for the Court’s consideration of the
§3553(a) factors. Dr. Zieman’s testimony applies directly to Mr. Stanley, but it also applies
to Ms. Stanley because it explains how she became involved in the conduct at issue.
6) Given the foregoing, the undersigned respectfully requests a continuance of the sentencing
presently scheduled for Mr. and Ms. Stanley.
7) Counsel understands the Court has an upcoming trial that is expected to be lengthy. To
that end, Counsel will coordinate with the Court’s Courtroom Deputy as well as Assistant
United States Attorney Justin Keen to secure an appropriate date on the Court’s calendar.
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.
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.
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

Case 4:22-cr-00032-MW-MAF Document 48 Filed 01/19/23 Page 2 of 3

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 19th day of January, 2023.

RESPECTFULLY SUBMITTED,