Motion to Extend Surrender Date — United States v. Sherrie Bryant (D. Md., Dkt. 63)

Summary

Motion to Extend Surrender Date, filed April 17, 2023 as Document 63, Case 8:22-cr-00308-DLB, United States v. Sherrie Bryant, District of Maryland. Defendant Sherrie Bryant moves to extend her BOP surrender date 30-45 days; the motion states that the Court granted until April 17 to surrender, that Ms. Bryant understood she was designated to surrender to Alderson prison in West Virginia, and that Alderson personnel told her she had not been designated there. It states that pretrial explained there was some kind of paperwork mix-up that was not Ms. Bryant's fault, and that without an extension she will be received by the U.S. Marshals and go through a lengthy classification process in custody. It is signed /s/ Charles Burnham, Attorney for the Accused.

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      Case 8:22-cr-00308-DLB Document 63 Filed 04/17/23 Page 1 of 3



    IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF
                           MARYLAND


                                    )
United States                       )
                                    )
                v.                  )                No. 8:22cr308
                                    )
Sherrie Bryant,                     )
                                    )
                                    )
       Defendant.                   )

                     MOTION TO EXTEND SURRENDER DATE

     Comes now the Defendant Sherrie Bryant and moves to extend her BOP surrender

date 30-45 days. Ms. Bryant submits as follows:

   1. This Court sentenced Ms. Bryant to a term of imprisonment on February 8, 2023

   2. The Court granted Ms. Bryant until April 17 to surrender to a designated BOP

       facility or the Marshals in Greenbelt. ECF 61.

   3. After meeting with pretrial Ms. Bryant was under the understanding that she was

       designated to surrender to Alderson prison in West Virginia on April 17 (today).

   4. Ms. Bryant traveled to Alderson. Alderson personnel informed Ms. Bryant that she

       had not in fact been designated there. Ms. Bryant contacted undersigned counsel.

   5. Undersigned counsel contacted Ms. McWilson at pretrial who explained there was

       some kind of paperwork mix-up that was not Ms. Bryant’s fault.

   6. If Ms. Bryant’s surrender date is not extended she will have to be received by the

       U.S. Marshals and go through a lengthy classification process in custody.

   7. Ms. Bryant submits that a brief extension of her mandatory surrender date of 30-45

       days is reasonable under the circumstances.
      Case 8:22-cr-00308-DLB Document 63 Filed 04/17/23 Page 2 of 3



   8. An email to counsel for the government requesting their agreement was not

       immediately responded to.

      For the foregoing reasons Ms. Bryant requests the Court to extend her surrender date

by 30-45 days.



                                                    Respectfully Submitted,

                                                    By:



                                                    /s/ Charles Burnham
                                                    Charles Burnham, DC # 1003464
                                                    Attorney for the Accused
                                                    Burnham & Gorokhov, PLLC
                                                    1424 K St. NW, Suite 500
                                                    Washington, DC 20005
                                                    (202) 386-6920 (phone)
                                                    (202) 765-2173 (fax)
                                                    charles@burnhamgorokhov.com




                             CERTIFICATE OF SERVICE

       I hereby certify that a copy of this pleading was filed on opposing counsel through

the Court’s electronic filing system.

By: /s/ Charles Burnham
Charles Burnham
D.C. Bar 1003464
Attorney for Defendant
BURNHAM & GOROKHOV, PLLC
     Case 8:22-cr-00308-DLB Document 63 Filed 04/17/23 Page 3 of 3



1424 K Street NW, Suite 500
Washington, DC 20005
(202) 386-6920 (phone)
(202) 265-2173 (fax)
Charles@burnhamgorokhov.com


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