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Consent Motion to Continue Sentencing — No. 1:21-cr-00284 (Dkt. 18, D.D.C.)

Summary

A consent motion to continue sentencing filed December 2, 2021 as Document 18 in United States v. James Kyle Bell, No. 21 CR 284 (JDB), in the U.S. District Court for the District of Columbia. Defense counsel moves to continue the sentencing scheduled for 2 p.m. on Friday, December 3, 2021, stating that a scheduling conflict leaves counsel unable to handle it that day. The motion states that the government has no objection to appearing virtually for sentencing at 2 p.m. on Monday, December 6, 2021, and asks the court to reset the hearing to that date and time.

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Cite this document

“Consent Motion to Continue Sentencing — No. 1:21-cr-00284 (Dkt. 18, D.D.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/consent-motion-to-continue-sentencing-no-1-21-cr-00284-dkt-18-d-d-c-29b2362e42/, SHA-256 19a6dbce4f1e900bbe9b9d217de922a92500ade4259a6f7c64b4b0dd3be0e8a1.

Full text

            Case 1:21-cr-00284-JDB Document 18 Filed 12/02/21 Page 1 of 3




                              UNITED STATES DISTRICT COURT
                              FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA                            :
                                                    :
                                                    :
       v.                                           :       No. 21 CR 284 (JDB)
                                                    :
                                                    :       Sentencing Date: 12/3/21
JAMES KYLE BELL,                                    :
    Defendant.                                      :

                    CONSENT MOTION TO CONTINUE SENTENCING

       James Bell, by and through undersigned counsel, respectfully moves this Court to continue

the sentencing currently scheduled for Friday December 3, 2021.

       In support of the motion, counsel states the following:

       1. Mr. Bell’s sentencing is scheduled for 2 p.m., Friday, December 3, 2021.

       2. Counsel’s mother (79) has an appointment for an eye injection related to a retinal

            vitreous hemorrhage also scheduled for December 3, 2020. Counsel is her mother’s

            sole caregiver.

       3. Based on the medical situation, and scheduling conflict, counsel will be unable to

            handle Mr. Bell’s sentencing on December 3, 2021.

       4. Counsel contacted the USAO regarding its consent to rescheduling the sentencing date.

            The government has no objection to appearing virtually for sentencing at 2 p.m. on

            Monday December 6, 2021.

       5. For good cause shown, Mr. Bell requests that the Court continue his sentencing hearing

            to December 6, 2021.

       WHEREFORE, Mr. Bell respectfully requests that the Court continue the sentencing

hearing scheduled for December 3, 2021, to 2 p.m. December 6, 2021.

                                             Respectfully submitted,
Case 1:21-cr-00284-JDB Document 18 Filed 12/02/21 Page 2 of 3




                           /s/ Brandi Harden
                           Brandi Harden, Esq.
                           Counsel for James K. Bell
                           Bar No. 470-706
                           Harden & Pinckney, PLLC
                           400 7th Street NW, Suite 604
                           Washington, DC 20004
                           202.390.0374
                           bharden@hardenpinckney.com
         Case 1:21-cr-00284-JDB Document 18 Filed 12/02/21 Page 3 of 3




                                CERTIFICATE OF SERVICE

I hereby certify that on December 2, 2021, I caused a copy of the foregoing motion to be served

on counsel of record via ECF.


                                                    /s/ Brandi Harden
                                                    _______________________________
                                                    Brandi Harden, Esq.

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