Motion of Defendant, Aleta Necole Thomas, for Continuance of Sentencing Hearing

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Case 4:21-cr-00239-GKF       Document 106 Filed in USDC ND/OK on 06/02/22          Page 1 of 2




                      IN THE UNITED STATES DISTRICT COURT
                    FOR THE NORTHERN DISTRICT OF OKLAHOMA

  UNITED STATES OF AMERICA,                 )
                                            )
                Plaintiff,                  )
                                            )
  vs.                                       )      Case No. 21-CR-239-GKF
                                            )
  ALETA NECOLE THOMAS,                      )
                                            )
                Defendant.                  )

                 MOTION OF DEFENDANT, ALETA NECOLE THOMAS
                  FOR CONTINUANCE OF SENTENCING HEARING

         The defendant, Aleta Necole Thomas (“Ms. Thomas”), moves this Court for a

  continuance of her sentencing hearing as more particularly set forth herein.

         1.     AUSA Kristin Harrington objects to the relief requested in this motion.

         2.     Sentencing is presently set for June 7, 2022 at 11:00 am. No previous

  requests for continuance have been requested.

         3.     The factual reasons for this motion are as follows:

         •      The sentencing issues in this case are sharply divided. Ms. Thomas has
                filed objections to the PSR, each of which the government contests;

         •      Numerous supporters of Ms. Thomas have provided information to the
                undersigned which cannot be easily formatted for the Court by the present
                sentencing date;

         •      The undersigned has received and continues to receive information that is
                highly relevant to Ms. Thomas’s motion for variance. This information
                cannot be easily formatted for the Court by the present sentencing date; and

         •      A continuance of approximately two weeks will allow the undersigned to
                provide evidence that is relevant to Ms. Thomas’s PSR objections and to
                her motion for variance.
Case 4:21-cr-00239-GKF         Document 106 Filed in USDC ND/OK on 06/02/22                 Page 2 of 2




         WHEREFORE, Ms. Thomas requests that this Court grant a continuance of Ms.

  Thomas’s sentencing hearing for a period of approximately two weeks.



                                                Respectfully submitted,


                                                 S/ Keith A. Ward
                                                Keith A. Ward, PLLC
                                                1874 S. Boulder
                                                Tulsa, OK 74119
                                                (918) 764-9011 Voice
                                                keith@keithwardlaw.com

                                                Attorney for Aleta Thomas

                                   CERTIFICATE OF SERVICE

        I certify that I served all registrants in the above-captioned case by submitting this
  document to the Clerk of the Court using the ECF System for filing and transmittal.


                                                 S/ Keith A. Ward




                                                   2


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