Defendant’s Unopposed Motion for Continuance of Entry of Plea — United States v. Wills (Dkt. 9, M.D. Fla.)

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Defendant Kevin Karl Wills, Jr.'s unopposed motion for continuance of entry of plea in United States v. Kevin Karl Wills, Jr., Case No. 3:24-cr-166-TJC-LLL, in the U.S. District Court for the Middle District of Florida, Jacksonville Division, filed November 18, 2024 as Document 9. It states that Wills is charged by information with conspiracy to defraud the United States, that a signed plea agreement has been reached, and that the entry of plea hearing is set for November 19, 2024 at 2:00 p.m. Citing Fed. R. Crim. P. 45(b), it asks the court to continue the hearing because Wills's wife has tested positive for Covid-19 and Wills is experiencing abdominal distress, and notes that the government does not oppose and that counsel conferred about availability on Monday, November 25, 2024.

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Case 3:24-cr-00166-TJC-LLL Document 9 Filed 11/18/24 Page 1 of 3 PageID 18




                      UNITED STATES DISTRICT COURT
                       MIDDLE DISTRICT OF FLORIDA
                         JACKSONVILLE DIVISION

UNITED STATES OF AMERICA,

v.                                           CASE NO.: 3:24-cr-166-TJC-LLL

KEVIN KARL WILLS, JR.,

         Defendant.


                  DEFENDANT’S UNOPPOSED MOTION FOR
                    CONTINUANCE OF ENTRY OF PLEA

         Defendant, Kevin Karl Wills, Jr., by and through undersigned counsel and

pursuant to Fed. R. Crim. P. 45(b) and Local Rule 3.08 hereby moves this Honorable

Court for a continuance of the plea hearing in this cause, presently set for Tuesday,

November 19, 2024, at 2:00 p.m. In support thereof, Defendant states:

         1.    Defendant is charged by Information with Conspiracy to Defraud the

United States. (Doc. 1).

         2.    The Government and Defendant have reached a plea agreement, which

has been signed, and an Entry of Plea hearing has been scheduled for Tuesday,

November 19, 2024 at 2:00 p.m. (Dkt. Entry 7).

         3.    Defendant’s wife has tested positive for Covid-19 and Defendant is

experiencing abdominal distress.

 Case 3:24-cr-00166-TJC-LLL Document 9 Filed 11/18/24 Page 2 of 3 PageID 19




                   LOCAL RULE 3.01(g) CERTIFICATION

      Pursuant to Local Rule 3.01(g), undersigned counsel certifies that he has

conferred with Assistant United States Attorney Arnold Corsmeier and is authorized

to represent that the Government does not oppose the relief requested herein. In

conferring with Mr. Corsmeier, he advises that he is available all day, Monday,

November 25, 2024.

      WHEREFORE, Defendant, Kevin Karl Wills, Jr., respectfully requests this

Honorable Court enter its Order continuing the Entry of Plea hearing.

                              MEMORANDUM OF LAW

      Fed. R. Crim. P. 45(b)(1)(A) provides in pertinent part: “When an act must or

may be done within a specified period, the court on its own may extend the time, or

for good cause may do so on a party’s motion made: before the originally prescribed

or previously extended time expires….”

      Local Rule 3.08(a) provides: “[a] party must timely move for a continuance

and explain in detail the reason a continuance is warranted and the effort to resolve

any scheduling conflict.” Good cause for the continuance is set forth above.




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 Case 3:24-cr-00166-TJC-LLL Document 9 Filed 11/18/24 Page 3 of 3 PageID 20




                                 Respectfully submitted,

                                       /s/ Elizabeth L. White
                                 Elizabeth L. White, Esquire
                                 Florida Bar No.: 314560
                                 Matthew R. Kachergus, Esquire
                                 Florida Bar No.: 503282
                                 Bryan E. DeMaggio, Esquire
                                 Florida Bar No.: 055712
                                 Camille Sheppard, Esquire
                                 Florida Bar No.: 124518
                                 Hannah B. Dunathan, Esquire
                                 Florida Bar No.: 1058025
                                 Sheppard, White, Kachergus, & DeMaggio, P.A.
                                 215 Washington Street
                                 Jacksonville, Florida 32202
                                 Telephone: (904) 356-9661
                                 Facsimile: (904) 356-9667
                                 Email: sheplaw@sheppardwhite.com
                                 COUNSEL FOR DEFENDANT

                        CERTIFICATE OF SERVICE

      I HEREBY CERTIFY that a copy of the foregoing has been furnished Arnold

B.    Corsmeier,      Esquire,       Assistant     United    States   Attorney,

chip.corsmeier@usdoj.gov, and Jennifer Michele Harrington, Esquire, Assistant

United States Attorney, Jennifer.harrington2@usdoj.gov, via the CM/ECF system,

this 18th day of November, 2024.

                                           /s/ Elizabeth L. White
                                       ATTORNEY




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