Motion to Continue Self-Surrender Date — United States v. Kao, No. 1:21-cr-00061 (D. Haw.), Dkt. 162

Summary

Counsel for Martin Kao asks the Court to move his self-surrender date from March 25, 2025 to a date in June 2025, calling it a single continuance. The motion recites that Kao was sentenced on February 13, 2025 to an 87-month term of imprisonment and has a Bureau of Prisons facility designation on the West Coast. It states that he awaits sentencing in a Washington D.C. case, for which no date is set and a draft presentence investigation report is complete. The motion says Kao wants to start his time as soon as possible. It is signed /s/ Randall K. Hironaka and dated March 14, 2025.

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Full text

Case 1:21-cr-00061-LEK    Document 162   Filed 03/14/25   Page 1 of 3 PageID.1405



MIYOSHI & HIRONAKA, LLLC
Attorneys at Law

RANDALL K. HIRONAKA 7444
City Financial Tower
201 Merchant Street, Suite 2240
Honolulu, Hawaii 96813
Telephone: (808) 888-2595
E-mail: randy@808-law.com

Attorneys for Defendant
MARTIN KAO


                 IN THE UNITED STATES DISTRICT COURT

                         FOR THE DISTRICT OF HAWAII

 UNITED STATES OF AMERICA                CR. No. 21-00061 LEK
                                         CR. No. 23-00003 LEK
       vs.

 MARTIN KAO,                             MOTION TO EXTEND SELF-
                                         SURRENDER DATE and
             Defendant.                  CERTIFICATE OF SERVICE



              MOTION TO EXTEND SELF-SURRENDER DATE
Case 1:21-cr-00061-LEK     Document 162     Filed 03/14/25   Page 2 of 3 PageID.1406



               MOTION TO EXTEND SELF-SURRENDER DATE

      Martin Kao is respectfully seeking a single continuance of the self-surrender

date imposed by this Honorable Court.

      On February 13, 2025, the Court sentenced Mr. Kao to an 87-month term of

imprisonment. The Court also allowed Mr. Kao to self-surrender and imposed a

self-surrender date of March 25, 2025. Mr. Kao has received his Bureau of Prisons

facility designation. He has been designated to a facility on the West Coast.

      The Court is aware that Mr. Kao is pending sentencing in another case in

Washington D.C. Unfortunately, there is no pending sentencing date for that case.

Counsel undersigned spoke with Mr. Kao’s attorney for the Washington D.C. case

on March 13, 2025. A draft presentence investigation and report has been

completed in that matter. Mr. Kao’s attorney indicated to Counsel that a reasonable

estimate of when the Washington D.C. Court will conduct his sentencing is

sometime in May.

      This Court is also aware of the time-consuming and physical, mental and

emotional rigors of custody travel. Mr. Kao has no desire to unnecessarily delay his

mittimus. To the contrary, he wants to start his time as soon as possible. However,

that is balanced against the aforementioned rigors and difficulties of traveling via

BOP custody. As such, Mr. Kao is respectfully requesting a single continuance of

his self-surrender date to a date in June 2025.
Case 1:21-cr-00061-LEK     Document 162      Filed 03/14/25   Page 3 of 3 PageID.1407



      It is Mr. Kao’s hope that a self-surrender date in June in these cases will

serve as positive motivation for the Court in Washington D.C. to set a sentencing

date in that case prior to a June self-surrender date herein. If a sentencing date in

the D.C. case is not established prior to the continued self-surrender date, Mr. Kao

does not intend to pursue additional continuances.

      DATED: Honolulu, Hawaii, March 14, 2025.

                                                  Respectfully submitted,

                                                  MIYOSHI & HIRONAKA, LLLC
                                                  Attorneys at Law


                                                  By:    /s/ Randall K. Hironaka
                                                         RANDALL K. HIRONAKA

                                                  Attorneys for Defendant
                                                  MARTIN KAO


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