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Defendant’s Motion to Extend the Time to File Objections to the Presetencing Investigation Report and Motion to Continue Sentencing — No. 0:21-cr-60020 (Dkt. 296, S.D. Fla.)

Summary

A defense motion to extend the time to file objections to the presentence investigation report and to continue sentencing, filed September 12, 2021 as Dkt. 296 in United States v. Mario Kustura, et al., Case No. 21-60020-CR-DIMITROULEAS, in the U.S. District Court for the Southern District of Florida. The motion states that Kustura pleaded guilty on July 15, 2021 to Count 10 of a 35-count Indictment, conspiracy to offer and pay kickbacks prohibited by the Eliminating Kickbacks and Recovery Act (EKRA), in violation of 18 U.S.C. § 371. It notes that the report was disclosed on August 17, 2021, that sentencing is set for September 23, 2021 at 1:15 p.m., and that he is expected to testify at his co-defendants' trial beginning September 13, 2021. It asks for a 70-day continuance and states that the government does not object.

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Cite this document

“Defendant’s Motion to Extend the Time to File Objections to the Presetencing Investigation Report and Motion to Continue Sentencing — No. 0:21-cr-60020 (Dkt. 296, S.D. Fla.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/defendant-s-motion-to-extend-the-time-to-file-objections-to-the-preset-2a5ac25481/, SHA-256 47f728484500fa814c305c55b323e47433d24810af08e84280723774895c5bc7.

Full text

Case 0:21-cr-60020-WPD Document 296 Entered on FLSD Docket 09/12/2021 Page 1 of 3




                            UNITED STATES DISTRICT COURT
                            SOUTHERN DISTRICT OF FLORIDA

                           CASE NO. 21-60020-CR-DIMITROULEAS


  UNITED STATES OF AMERICA,

              Plaintiff,

  vs.

  MARIO KUSTURA, et al,

          Defendant.
  ________________________________/

    DEFENDANT’S MOTION TO EXTEND THE TIME TO FILE OBJECTIONS
    TO THE PRESETENCING INVESTIGATION REPORT AND MOTION TO
                     CONTINUE SENTENCING

           The Defendant, Mario Kustura, through counsel, files this Motion to Continue

  Sentencing in this matter that is currently scheduled for September 23, 2021 and in

  support states the following:

        1. On July 15, 2021, Mr. Kustura pled guilty to Count 10 of a 35-count

           Indictment. Count 10 charged him with conspiracy to offer and pay kickbacks

           prohibited by the Eliminating Kickbacks and Recovery Act (EKRA), in

           violation of 18 U.S.C. § 371.

        2. The Presentencing Investigation Report was disclosed on August 17, 2021 by

           United States Probation.

        3. Sentencing is currently scheduled for September 23, 2021 at 1:15 p.m.

        4. Mr. Kustura is expected to testify in his co-defendants’ trial which is

           scheduled to commence on September 13, 2021, before this Honorable Court.
Case 0:21-cr-60020-WPD Document 296 Entered on FLSD Docket 09/12/2021 Page 2 of 3




     5. Undersigned counsel needs more time to focus on and prepare for sentencing

        with her client.

     6. Undersigned counsel has discussed this request with SAUSA, Jamie deBoer,

        and SAUSA James Hayes, and they do not have an objection to this request.


     Accordingly, Mr. Kustura respectfully asks the Court to continue his sentencing

  for a period of 70 days.


                                              Respectfully submitted,

                                              MICHAEL CARUSO
                                              FEDERAL PUBLIC DEFENDER

                                              By: s/ Huda Ajlani-Macri
                                              Huda Ajlani-Macri
                                              Assistant Federal Public Defender
                                              Florida Bar No. 27831
                                              1 E. Broward Boulevard, Suite 1100
                                              Fort Lauderdale, Florida 33301
                                              Tel: (954) 356-7436
                                              E-mail: Huda_Ajlani-Macri@fd.org
Case 0:21-cr-60020-WPD Document 296 Entered on FLSD Docket 09/12/2021 Page 3 of 3




                                 CERTIFICATE OF SERVICE

        I HEREBY certify that on September 12, 2021, I electronically filed the

        foregoing document with the Clerk of the Court using CM/ECF. I also certify

        that the foregoing document is being served this day on all counsel of record

        via transmission of Notices of Electronic Filing generated by CM/ECF or in

        some other authorized manner for those counsel or parties who are not

        authorized to receive electronically Notices of Electronic Filing.

                                                By: s/Huda Ajlani-Macri
                                                Huda Ajlani-Macri

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