Defendant's Motion to Extend Self-Surrender Date; Proposed Order — United States v. Cassie Will-Darnall (Dkt. 118)
Summary
Defendant Cassie Will-Darnall, through the Federal Public Defender, moves to extend her self-surrender date from January 12, 2026, by 60 days to March 13, 2026, and attaches a proposed order. The motion states that the caregiver for her mother unexpectedly quit, leaving the defendant as sole caregiver, and that the extension would allow time to hire and train a replacement. It says the court sentenced her on September 24, 2025, to 18 months in custody and that she has been designated to the Victorville Satellite Camp. Counsel asks that the motion be decided on the papers and says defense counsel is available on January 14, 2026, if a hearing is needed. The proposed order requires surrender by 2:00 p.m. on March 13, 2026, and its date line is blank.
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“Defendant's Motion to Extend Self-Surrender Date; Proposed Order — United States v. Cassie Will-Darnall (Dkt. 118).”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-118-0-91094a9c13/
, SHA-256 d580ef1603983af9bbcea685d22b36ef86b97ac8d791ce338060f408c5cc64db.Full text
Case 5:24-cr-00292-PCP Document 118 Filed 01/06/26 Page 1 of 2
1 JODI LINKER, Bar No. 230273
Federal Public Defender
2 Northern District of California
VARELL L. FULLER, Bar No. 202680
3 Assistant Federal Public Defender
55 South Market Street, Suite 820
4
San Jose, CA 95113
5 Telephone: (408) 291-7753
Facsimile: (408) 291-7399
6 Email: Varell_Fuller@fd.org
7
Counsel for Defendant WILL-DARNALL
8
9
IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
12
13
UNITED STATES OF AMERICA, Case No. CR 24–00292 PCP
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Plaintiff, DEFENDANT’S MOTION TO EXTEND
15 SELF-SURRENDER DATE;
v. [PROPOSED] ORDER
16
CASSIE WILL-DARNALL,
17
Defendant.
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19
MOTION
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Defendant Cass Will-Darnall, by and through counsel, respectfully requests that the Court
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extend her self-surrender date, currently scheduled for January 12, 2026, by 60 days to March 13,
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2026. The reason for this request is that the caregiver for Ms. Will-Darnall’s mother unexpectedly
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quit, leaving Ms. Will-Darnell as the sole caregiver. Ms. Will-Darnall requests this extension to allow
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her time to hire and train a replacement caregiver.
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On September 24, 2025, this Court sentenced Ms. Will-Darnall to 18 months in custody. See
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Dkt. No. 98. She has been designated to the Victorville Satellite Camp.
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Ms. Will-Darnall’s mother, Sandra Will, is unable to care for herself independently. She is
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unable to dress, bathe, or manage her medications without assistance. In addition, she requires
MOTION TO EXTEND SELF-SURRENDER DATE; [PROPOSED] ORDER
WILL-DARNALL, CR 24–00292 PCP
1
Case 5:24-cr-00292-PCP Document 118 Filed 01/06/26 Page 2 of 2
1 assistance with tasks such as scheduling and keeping track of appointments, paying bills, making
2 telephone calls, and interpreting email and voicemail messages. See Declaration of Cassie Will-
3 Darnall and accompanying documents, attached hereto as Exhibit A. Ms. Will-Darnall is actively
4 working to hire and train a replacement caregiver for her mother. See id. In the meantime, Ms. Will-
5 Darnall is the sole caregiver. Id. A 60-day extension of Ms. Will-Darnall’s self-surrender date should
6 provide enough time for her to hire and train a new caregiver before beginning her prison term.
7 For the reasons set forth above, Ms. Will-Darnall respectfully requests that the Court grant a
8 60-day extension of her self-surrender date to March 13, 2026. In addition, it is requested that this
9 motion be considered and decided on the papers without the need for a hearing. If the Court
10 determines that a hearing is necessary, defense counsel is available on January 14, 2026.
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12 Dated: January 6, 2026 Respectfully submitted,
13 JODI LINKER
Federal Public Defender
14 Northern District of California
15 /S
VARELL L. FULLER
16
Assistant Federal Public Defender
17
18 [PROPOSED] ORDER
19 GOOD CAUSE APPEARING, upon motion of defendant Cassie Will-Darnall, IT IS HEREBY
20 ORDERED that the defendant’s self-surrender date is extended from January 12, 2026, to March 13,
21 2026.
22 IT IS FURTHER ORDERED that Ms. Will-Darnall shall surrender on March 13, 2026, to the
23 Bureau of Prisons facility to which she has been designated, Victorville Satellite Camp, or the the
24 U.S. Marshal’s Service office in San Jose, California, no later than 2:00 p.m.
25 IT IS SO ORDERED.
26 Dated: __________________________________________
27 THE HONORABLE P. CASEY PITTS
United States District Court Judge
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MOTION TO EXTEND SELF-SURRENDER DATE; [PROPOSED] ORDER
WILL-DARNALL, CR 24–00292 PCP
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