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Court filing — No. 1:25-cr-00211 (Dkt. 14, D.D.C.)

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       Case 1:25-cr-00211-CRC           Document 14       Filed 11/25/25      Page 1 of 2




                           UNITED STATES DISTRICT COURT
                           FOR THE DISTRICT OF COLUMBIA

 UNITED STATES OF AMERICA

              v.                                      Case No. 25-CR-211 (CRC)

 JENNIFER MAY,

                   Defendant.


GOVERNMENT=S MOTION TO CONTINUE DEADLINE FOR MEMORANDA IN AID
                        OF SENTENCING

       The United States, by and through its attorney, the United States Attorney for the District

of Columbia, hereby respectfully moves to continue the deadline for the parties to file memoranda

in aid of sentencing in the above-captioned matter. In support of its motion, the government states

as follows:

   1. On August 27, 2025, Defendant Jennifer May (hereinafter, “the Defendant”), entered a plea

       of guilty to one count of Wire Fraud in violation of 18 U.S.C. § 1343.

   2. The Court set the Defendant’s sentencing for December 9, 2025. As part of the Court’s

       order, the Court also required that the parties submit any memoranda in aid of sentencing

       by no later than December 2, 2025.

   3. The United States would ask that the deadline be extended by 48 hours so that memoranda

       are due by no later than December 4, 2025. Due to a calendaring oversight by undersigned

       counsel, the government did not realize until November 24, 2025 that the Court’s deadline

       conflicted with pre-planned, international travel in which undersigned counsel will not

       have access to government-furnished devices authorized to be taken outside of the United

       States, and thus will be unable to complete the sentencing memoranda by the Court’s

       deadline.
        Case 1:25-cr-00211-CRC        Document 14       Filed 11/25/25       Page 2 of 2




   4.   Undersigned counsel attempted to contact counsel for the Defendant on November 24,

        2025 and November 25, 2025, but was unable to do so and thus does not know the position

        of the Defendant on the government’s motion.

        WHEREFORE, the government respectfully requests that the deadline within which to

submit memoranda in aid of sentencing is extended to December 4, 2025.



                                                   Respectfully submitted,


                                                   JEANINE FERRIS PIRRO
                                                   UNITED STATES ATTORNEY


                                                   ________________________
                                                   WILL HART
                                                   Assistant United States Attorney
                                                   U.S. Attorney’s Office for the
                                                   District of Columbia
                                                   D.C. Bar No. 1029325
                                                   601 D. St., N.W.,
                                                   Washington, D.C. 20530
                                                   William.hart@usdoj.gov
                                                   (202)-252-7877


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