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Defendant Philossaint's Unopposed Motion to Continue Sentencing Hearing — United States v. Philossaint

Summary

Defendant Philossaint's Unopposed Motion to Continue Sentencing Hearing, entered on the docket April 4, 2023, in United States of America v. Joff Stenn Wroy Philossaint, Case No. 22-CR-80144-RS, Southern District of Florida. The hearing is currently set for Wednesday, April 19, 2023. The motion states that counsel was appointed on March 16, 2023, that there are 33 funded loans in question, and that Assistant United States Attorney Marc Osborne agrees a continuance is appropriate. It asks for a 60-day continuance to a date at the end of June, 2023, or thereafter, and is signed /s Scott W. Sakin, CJA counsel.

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“Defendant Philossaint's Unopposed Motion to Continue Sentencing Hearing — United States v. Philossaint.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-fla-no-9-22-cr-80144-dkt-255-s-d-fla-a83fee07bd/, SHA-256 ec1d51631e1f47afcccfaf46cbafc5492a956757b6ec4c5d9b81cae7d4a7ea23.

Full text

Case 9:22-cr-80144-RS Document 255 Entered on FLSD Docket 04/04/2023 Page 1 of 3




                      UNITED STATES DISTRICT COURT
                      SOUTHERN DISTRICT OF FLORIDA

                            CASE NO. 22-CR-80144-RS

 UNITED STATES OF AMERICA,

       Plaintiff,
 vs.

 JOFF STENN WROY PHILOSSAINT,

       Defendant.
  __________________________________/

            DEFENDANT PHILOSSAINT’S UNOPPOSED MOTION
                 TO CONTINUE SENTENCING HEARING

       The Defendant, JOFF STENN WROY PHILOSSAINT, through undersigned

 counsel, moves this Court to continue the sentencing hearing currently set for

 Wednesday, April 19, 2023, and in support thereof, states the following:

       1.     Defendant has pled guilty or has been convicted by a jury, of conspiracy

 to commit wire fraud, two counts of conspiracy to commit money laundering, and

 one count of obtaining citizenship by fraud.

       2.     On March 16, 2023, counsel was appointed pursuant to the Criminal

 Justice Act (CJA) as Defendant’s new attorney to represent Defendant for purpose

 of sentencing. Counsel has met with Defendant’s prior attorney and Defendant, has

 reviewed the Presentence Investigation Report, and has spoken with the Prosecutor,

 Marc Osborne.


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Case 9:22-cr-80144-RS Document 255 Entered on FLSD Docket 04/04/2023 Page 2 of 3




       3.     Based on the above conversations, it is clear this is a procedurally and

 substantively complex case. There are 33 funded loans in question. Discovery is

 voluminous. Counsel needs to determine the correct and proper objections to file

 regarding the Presentence Investigation Report. Counsel also needs to spend

 additional time becoming familiar with the case.

       4.     Counsel has conferred with Assistant United States Attorney, Marc

 Osborne, who agrees that a continuance is appropriate in light of the complexity of

 the case.

       5.     Accordingly, Defendant moves for a 60-day continuance of

 Defendant’s sentencing hearing to a date at the end of June, 2023, or thereafter. This

 will allow sufficient time to file the necessary responsive pleadings to complete the

 sentencing process.

       WHEREFORE, Defendant respectfully moves the Court to continue the

 sentencing hearing as requested herein.

                                            Respectfully Submitted,

                                            SCOTT W. SAKIN, P.A.
                                            CJA Counsel for Defendant Philossaint
                                            2883 Executive Park Drive, Suite 200
                                            Weston, Florida 33331-3662
                                            Tel. (954) 779-7879
                                            scott@sakinlaw.com

                                               By: ___/s Scott W. Sakin___________
                                                       SCOTT W. SAKIN, ESQ.
                                                       Fla. Bar No. 349089
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Case 9:22-cr-80144-RS Document 255 Entered on FLSD Docket 04/04/2023 Page 3 of 3




                          CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that a true and correct copy of the foregoing

 DEFENDANT PHILOSSAINT’S UNOPPOSED MOTION TO CONTINUE

 SENTENCING HEARING was filed electronically with the Clerk of the Court

 through the CM/ECF system and copies of same distributed to all counsel of record

 and known interested parties on this 4th day of April, 2023.

                                               By: ___/s Scott W. Sakin___________
                                                       SCOTT W. SAKIN, ESQ.
                                                       Fla. Bar No. 349089




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