United States' Response in Opposition to Defendants' Motion to Extend Surrender Date (M.D. Fla., Dkt. 123)

Summary

The United States' Response in Opposition to Defendants' Motion to Extend Surrender Date in United States v. Timothy Craig Jolloff and Lisa Ann Jolloff, Case No. 2:23-cr-79-TPB-NPM, Document 123, filed 04/18/25, in the U.S. District Court for the Middle District of Florida, Fort Myers Division. The government asks the court to deny the request to move the April 23, 2025 surrender date, arguing that the defendants had ample time to arrange their affairs before sentencing. It sets out a timeline of the charges, guilty pleas and continued sentencing dates. It states that the court sentenced Lisa Ann Jolloff to 36 months and Timothy Jolloff to 97 months on April 10, 2025. The signature block names Jesus M. Casas, Assistant United States Attorney.

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“United States' Response in Opposition to Defendants' Motion to Extend Surrender Date (M.D. Fla., Dkt. 123).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-m-d-fla-no-2-23-cr-00079-dkt-123-m-d-fla-e3c818c63d/, SHA-256 d480dc7a398820c72c34506e8c952c9349fd158bb7768c804d0d395c839f8c8f.

Full text

Case 2:23-cr-00079-TPB-NPM Document 123 Filed 04/18/25 Page 1 of 6 PageID 615

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
FORT MYERS DIVISION

UNITED STATES OF AMERICA

v. CASE NO. 2:23-cr-79-TPB-NPM

TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF

UNITED STATES’ RESPONSE IN OPPOSITION TO
DEFENDANTS’ MOTION TO EXTEND SURRENDER DATE

The defendants, Timothy Craig Jolloff and Lisa Ann Jolloff

(collectively, “the Jolloffs”), have filed a motion1 to extend their surrender

date, currently scheduled for April 23, 2025. Doc. 122. As grounds for the

Jolloffs request, they assert the need “to finish getting their affairs in order as

they have encountered several difficulties in doing so.” Id. The Court should

deny the Jolloffs’ request based upon the ample amount of time they were

afforded prior to their sentencing to arrange their affairs in contemplation of a

prison sentence.

BACKGROUND

The Jolloffs were originally charged by criminal complaint on June 16,

2023. Doc. 3. The Jolloffs were then charged by indictment on July 12, 2023.

Doc. 27. Almost a year later, the Jolloffs entered guilty pleas on April 24,

1
The motion references Local Rule numbers that are not applicable to the Middle District of
Florida.
Case 2:23-cr-00079-TPB-NPM Document 123 Filed 04/18/25 Page 2 of 6 PageID 616

2024. Docs. 79 and 83. The Court then scheduled the sentencing hearing for

August 23, 2024. Doc. 90.

Unopposed by the United States, the Jolloffs requested a continuance of

the sentencing hearing to allow for medical records to be collected for the

presentence investigation. Doc. 91. The sentencing was then continued to

October 21, 2024. Doc. 93. The initial presentence reports were made

available to the Jolloffs on September 18, 2024. Docs. 98, 99.

On October 3, 2024, the sentencing hearing scheduled for October 21,

2024, was rescheduled to December 12, 2024. Doc. 100. On November 13,

2024, the sentencing hearing scheduled for October 21, 2024, was rescheduled

to January 17, 2025. Doc. 101. The final presentence reports were filed on

January 8 (Timothy Jolloff) and 9 (Lisa Ann Jolloff), 2025. Docs. 102, 104.

On January 9, 2025, unopposed by the United States, the Jolloffs

requested a continuance of the sentencing hearing from January 17, 2025.

Doc. 106. The sentencing was continued to February 14, 2025. Doc. 108.

On February 14, 2025, the Court commenced the sentencing hearing for

the Jolloffs. Doc. 112. Following an exchange between Defendant Lisa Ann

Jolloff and the Court, the Court continued the sentencing hearing to April 17,

2025. Doc. 113. The Court then rescheduled the sentencing hearing to April

10, 2025. Doc. 115.
Case 2:23-cr-00079-TPB-NPM Document 123 Filed 04/18/25 Page 3 of 6 PageID 617

On April 10, 2025, the Court sentenced the Jolloffs to terms of

incarceration – 36 months for Lisa Ann Jolloff and 97 months for Timothy

Jolloff. Doc. 117. The Court granted self-surrender to the Jolloffs on April

23, 2025, at the Federal Detention Center in Miami, Florida. Id.

On April 17, 2025, the Jolloffs requested an extension of their self-

surrender date to May 23, 2025. Doc. 91.

ARGUMENT

The Jolloffs request for an extension of their self-surrender date for an

additional month due to difficulties in getting their affairs in order fails to

explain what difficulties they are having and why it necessitates that both of

the Jolloffs extend their surrender dates. The Jolloffs have been aware of the

likelihood of their incarceration since the issuance of the initial presentence

report in September 2024. In early January, following the issuance of the final

presentence reports, the guideline range for the Jolloffs contemplated several

years of incarceration. The Jolloffs had many months to arrange their affairs

prior to each of their scheduled sentencing hearings. It is unknown what the

Jolloffs did to prepare for that eventuality.

The Jolloffs final presentence reports, Docs. 102, 104, do not reflect a

complicated set of life circumstances for the Jolloffs. The Jolloffs were renting

a home in Fort Myers, had purchased a car in 2023 during the pendency of the
Case 2:23-cr-00079-TPB-NPM Document 123 Filed 04/18/25 Page 4 of 6 PageID 618

case and were employed at a mobile home sales business. The Jolloffs

reported no other active business concerns, family concerns involving minor

children or medical appointments. The Jolloffs had also claimed they had

sold the assets they acquired with the fraudulent proceeds they obtained.

¶ 142, Doc. 102. The Jolloffs had numerous liens and judgments levied

against them. Id. at ¶ 143. The Jolloffs bankruptcy filing was previously

withdrawn. Id. at ¶ 144. While the Jolloffs acknowledged that they had not

filed taxes since 2019, there was no indication that they planned to do so. Id.

at ¶ 145. The Jolloffs have a life insurance policy with no cash surrender

value. Id. at 147. The Jolloffs own a storage building in Indiana, but during

the sentencing hearing Timothy Jolloff claimed that there was little to no

equity in the property.

The Jolloffs’ request does not indicate what affairs they are having

difficulty arranging, but in light of the presentence report, and the substantial

amount of fraud they have already committed, it is likely they do not have

any. Moreover, there is no indication in the request why it would take both of

the Jolloffs to get their affairs in order, if that is even possible.
Case 2:23-cr-00079-TPB-NPM Document 123 Filed 04/18/25 Page 5 of 6 PageID 619

CONCLUSION

The United States respectfully requests that the Court deny the Jolloffs’

motion for extension of time to self-surrender.

Respectfully submitted,

GREGORY W. KEHOE
United States Attorney

By: /s/Jesus M. Casas
Jesus M. Casas
Assistant United States Attorney
Chief, Fort Myers Division
Florida Bar No. 0152110
2110 First Street, Suite 3-137
Ft. Myers, Florida 33901
Telephone: (239) 461-2200
Facsimile: (239) 461-2219
E-mail: Jesus.m.Casas@usdoj.gov
Case 2:23-cr-00079-TPB-NPM Document 123 Filed 04/18/25 Page 6 of 6 PageID 620

U.S. v. Timothy Craig Jolloff, et al. Case No. 2:23-cr-79-TPB-NPM

CERTIFICATE OF SERVICE

I hereby certify that on April 18, 2025, I electronically filed the

foregoing with the Clerk of the Court by using the CM/ECF system which

will send a notice of electronic filing to the following:

Paul D. Petruzzi
Petruzz-law@msn.com

/s/ Jesus M. Casas
Jesus M. Casas
Assistant United States Attorney
Chief, Fort Myers Division

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