Motion to Continue Plea Hearing as to Tiffany Bowlin — United States v. Bowlin (Dkt. 12, S.D. W. Va.)

Record facts

U.S. District Court for the Southern District of West Virginia · No. 2:22-cr-00205 · Doc. 12 · 2023-01-10 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF WEST VIRGINA 
CHARLESTON DIVISION 
 
 
UNITED STATES OF AMERICA 
 
v. 
 
 
 
 
 
 
 
Criminal No. 2:22-00205 
 
TIFFANY BOWLIN 
 
 
 
MOTION TO CONTINUE PLEA HEARING 
 
The defendant, Tiffany Bowlin, by her attorney, Assistant Federal Public 
Defender Rachel E. Zimarowsi, respectfully requests that this Honorable Court 
continue the plea hearing and, in support thereof, respectfully represents: 
1. 
By Order entered January 6, 2023, a plea hearing in the above-styled 
matter was scheduled for January 12, 2023, at 10:00 a.m. before Senior United States 
District Court Judge John T. Copenhaver, Jr. Dkt. No. 9. 
2. 
By Order entered this date, the plea hearing was continued, sua sponte, 
to January 13, 2023, at 1:30 p.m. Dkt. No. 11. 
3.   
In preparation for the anticipated plea hearing, the United States 
Probation Office prepared a pretrial services report recommending that Ms. Bowlin 
be released on bond under the standard conditions set by this Court.   
4.  Ms. Bowlin is gainfully employed full-time and supports two minor 
children as a single mother. Upon receipt of the Order setting the plea hearing, Ms. 
Bowlin requested the date off through her employer. Her employer denied her request 
because it requires at least fourteen days of advance notice for approved leave.  
Case 2:22-cr-00205     Document 12     Filed 01/10/23     Page 1 of 2 PageID #: 28

Absent a continuance of the plea hearing, Ms. Bowlin will have no alternative but to 
take absence without approved leave and jeopardize a full-time position she has held 
for over one year.  
5.  Undersigned counsel is authorized to that that Assistant United States 
Attorney Monica D. Coleman does not oppose a continuance of this proceeding.  
WHEREFORE, considering these circumstances, counsel respectfully requests 
that the plea hearing in the instant matter be continued to the week of January 30, 
2023, so that Ms. Bowlin can make the necessary arrangements with her employer 
in advance to attend. 
Date: January 10, 2023.  
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
TIFFANY BOWLIN 
 
 
 
 
 
 
 
 
By Counsel 
 
WESLEY P. PAGE 
FEDERAL PUBLIC DEFENDER 
 
s/Rachel E. Zimarowski______________ 
Rachel E. Zimarowski, WV Bar No. 11415 
Office of the Federal Public Defender 
300 Virginia Street, East, Room 3400 
Charleston, WV 25301 
Telephone: (304) 347-3350 
Facsimile: (304) 347-3356 
E-mail: Rachel_Zimarowski@fd.org 
 
Case 2:22-cr-00205     Document 12     Filed 01/10/23     Page 2 of 2 PageID #: 29

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