Response in Opposition to Defendant's Motion to Continue Sentencing Hearing — United States v. Aleta Necole Thomas

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Case 4:21-cr-00239-GKF       Document 110 Filed in USDC ND/OK on 06/02/22        Page 1 of 3




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


  UNITED STATES OF AMERICA,

                        Plaintiff,

  v.                                                   Case No. 21-CR-239-GKF


  ALETA NECOLE THOMAS,

                       Defendant.



                         Response in Opposition to Defendant’s
                         Motion to Continue Sentencing Hearing

       The Court should deny Aleta Thomas’s request for a continuance of her

  Sentencing Hearing because Ms. Thomas has had ample time to file objections and

  motions, gather letters from supporters, and present other information to the Court

  related to her sentencing. More than six months ago, Ms. Thomas entered guilty

  pleas in this case before the Honorable Judge Billy Roy Wilson. During her change

  of plea hearing, the Court advised Ms. Thomas of her first sentencing date set May

  25, 2022, at 1:15 p.m. before the Honorable Judge Wilson.

       In anticipation of this first sentencing hearing date, on May 16, 2022, Ms.

  Thomas filed an extensive Motion for Sentencing Variance of Defendant, Aleta

  Necole Thomas, Doc. 97, along with 16 letters of support. Two days later, she filed

  her Presentence Report Objections of Aleta Necole Thomas. Doc. 98. On May 20,

  2022, the Court reset Ms. Thomas’s sentencing from May 25 to June 7, 2022.
Case 4:21-cr-00239-GKF      Document 110 Filed in USDC ND/OK on 06/02/22          Page 2 of 3




     Ms. Thomas has had ample opportunity to file motions, to gather letters of

  support, and present information to the Court. Ms. Thomas’s request to continue her

  sentencing hearing does not sufficiently describe or explain how this newly

  discovered information will aid the Court in determining an appropriate sentence. It

  is difficult to understand how Ms. Thomas has not yet gathered and provided all the

  information that is “highly relevant to Ms. Thomas’s motion for variance[.]” and

  “evidence that is related to Ms. Thomas’s PSR objections” given Ms. Thomas’s

  extensive filings to date. Doc. 106 p. 1. Moreover, it is unclear why Ms. Thomas

  needs to format this information to present it to the Court. Finally, in the event the

  Court grants Ms. Thomas’s motion for continuance, the Government requests the

  Court set deadlines for Ms. Thomas to file her additional filings and for the

  Government to respond.



                                           Respectfully submitted,

                                           CLINTON J. JOHNSON
                                           UNITED STATES ATTORNEY

                                           /s/ Kristin F. Harrington
                                           Kristin F. Harrington, OBA No. 21185
                                           Assistant United States Attorney
                                           110 West Seventh Street, Suite 300
                                           Tulsa, Oklahoma 74119
                                           (918) 382-2785




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Case 4:21-cr-00239-GKF     Document 110 Filed in USDC ND/OK on 06/02/22       Page 3 of 3




                                 Certificate of Service

     I hereby certify that on the day of June 2, 2022, I served the foregoing document
  via electronic email, on the following:

      Keith A. Ward
      Keith@keithwardlaw.com
      Counsel for Ms. Aleta Thomas



                                         /s/ Kristin F. Harrington
                                         Kristin F. Harrington
                                         Assistant United States Attorney




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