Letter from Kelly O. Hayes to Judge Matthew J. Maddox, April 3, 2025 — United States v. Henson (Dkt. 230, D. Md.)

Summary

A letter dated April 3, 2025 from the U.S. Attorney's Office for the District of Maryland to Judge Matthew J. Maddox in United States v. Nichelle Henson, MJM-21-470, filed April 4, 2025 as Document 230. The Government asks the Court to extend Probation's deadline to file the final presentence report from May 16, 2025 to June 23, 2025, and the initial presentence report from April 21, 2025 to May 23, 2025. The letter says Government counsel has not yet drafted the facts proven at trial and anticipated guidelines for Probation, and that Probation agrees to the request. Sentencing is set for August 5, 2025. The judge's signature appears under the notation APPROVED 4/4/25.

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Case 1:21-cr-00470-MJM       Document 230         Filed 04/04/25      Page 1 of 1
                                                          U.S. Department of Justice
                                                          United States Attorney
                                                          District of Maryland

     Paul Riley                                           Suite 400                    DIRECT: 410-209-4959
     Assistant United States Attorney                     36 S. Charles Street           MAIN: 410-209-4800
     Paul.Riley@usdoj.gov                                 Baltimore, MD 21201-3119        FAX: 410-962-3091


                                                          April 3, 2025
     BY ECF

     The Honorable Matthew J. Maddox
     United States District Judge
     United States Courthouse
     101 West Lombard Street
     Baltimore, MD 21201

     Re:        United States v. Nichelle Henson, MJM-21-470

     Dear Judge Maddox:
             I write on behalf of the Government in the above-referenced case to respectfully request
     that the Court extend the deadline for United States Probation (“Probation”) to file the final
     presentence report from May 16, 2025 to June 23, 2025 and, accordingly, adjust the due date for
     the preparation of the initial presentence report to May 23, 2025. See ECF No. 227. Sentencing
     is currently set for August 5, 2025 at 10:00 am.
              Due to the press of obligations from other matters, Government counsel has not yet had
     occasion to draft the facts proven at trial/anticipated guidelines and provide them to Probation.
     Accordingly, the Government now seeks an extension of Probation’s deadline to file the
     presentence report to allow the Government additional time to draft the facts proven at
     trial/anticipated guidelines. The Government has conferred with Probation concerning this
     request; they agree to it.
            Accordingly, the Government respectfully requests that the Court extend the deadline for
     Probation to file the final presentence report from May 16, 2025 to June 23, 2025 and extend the
     deadline for the filing of the initial presentence report from April 21, 2025 to May 23, 2025.
                                                          Respectfully submitted,

                                                          Kelly O. Hayes
                                                          United States Attorney
APPROVED 4/4/25
/S/ Matthew J. Maddox                                       /s/
United States District Judge                      By:     Paul A. Riley
                                                          Joseph Wenner
                                                          Assistant United States Attorneys

     CC: All Counsel (by ECF)

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