United States' Opposition to Defendant's Motion to Extend Self-Surrender Date — United States v. Cassie Will-Darnall (Dkt. 119)

Summary

The United States opposes Defendant Cassie Will-Darnall's Motion to Extend Self-Surrender Date (Doc. 118), saying circumstances have not materially changed since sentencing. It states that the defendant seeks 60 more days to hire and train a replacement caregiver for her mother, who purportedly requires daily care, and that her earlier unopposed request to extend by five days did not mention a caregiver need. The brief says a Pretrial Services Officer confirmed the defendant traveled to Colorado from December 17 through 23, 2025, on a court-approved ski trip without her mother. It states that the request appears to be an effort to delay surrender and asks that the motion be denied. The signature block shows /s/ above Sarah E. Griswold.

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“United States' Opposition to Defendant's Motion to Extend Self-Surrender Date — United States v. Cassie Will-Darnall (Dkt. 119).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-119-0-0bf5694d8a/, SHA-256 88f51f4a81515c2dafa22b30a20dd4ffdacb3004f1222acc3ad973302506460f.

Full text

Case 5:24-cr-00292-PCP Document 119 Filed 01/07/26 Page 1 of 3

1 CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
2
MARTHA BOERSCH (CABN 126569)
3 Chief, Criminal Division

4 SARAH E. GRISWOLD (CABN 240326)
Assistant United States Attorney
5
60 South Market Street, Suite 1200
6 San Jose, California 95113
Telephone: (408) 535-5061
7 FAX: (408) 535-5081
sarah.griswold@usdoj.gov
8
Attorneys for United States of America
9
UNITED STATES DISTRICT COURT
10
NORTHERN DISTRICT OF CALIFORNIA
11
SAN JOSE DIVISION
12

13 UNITED STATES OF AMERICA, ) Case No. 5:24-cr-292-PCP
)
14 Plaintiff, ) UNITED STATES’ OPPOSITION TO
) DEFENDANT’S MOTION TO EXTEND SELF-
15 v. ) SURRENDER DATE (DOC. 118)
)
16 CASSIE WILL-DARNALL, )
)
17 Defendant. )
)
18
19 The United States opposes Defendant Cassie Will-Darnall’s Motion To Extend Self-Surrender
20 Date (Doc. 118). Because circumstances have not materially changed since sentencing, the Motion

21 schedule denied.

22 The Defendant seeks to extend her self-surrender date by 60 days so she can “hire and train a
23 replacement caregiver for her mother,” who purportedly requires daily care. (Doc. 118.) The Defendant

24 claims that her mother Sandra Will “does not currently have a caregiver. Her caregiver left on Dec 9th

25 2025.” (Doc. 118-1 at 6.) She also claims that claims her mother “receives no daily care aside from my

26 assistance.” (Id.) The facts of this case show otherwise.

27 On December 18, 2025, the Defendant filed an unopposed motion seeking to extend her self-
28 surrender date by five so that she could participate in a mediation relating to child custody. (Doc. 113.)

U.S. OPP’N TO MOT. EXTEND SELF-SURRENDER 1
5:24-cr-292-PCP
Case 5:24-cr-00292-PCP Document 119 Filed 01/07/26 Page 2 of 3

1 The Court granted that motion. (Doc. 114.) In her first request to extend the self-surrender date, the

2 Defendant did not mention that her mother needed a new caregiver. U.S. Pretrial Services Officer

3 Yaneyla Arevalo Arellano confirmed to the undersigned that the Defendant travelled to Colorado from

4 December 17 through 23, 2025 for a ski trip approved by the Court. (See Doc. 107.) The Defendant’s

5 mother did not go on this trip. (Ex. 1 at 2.)

6 It appears that the current request is simply an effort to delay the Defendant’s inevitable self-

7 surrender. Other than the Defendant’s uncorroborated self-serving statements submitted in support of

8 the instant Motion, there is no evidence to support this request. Defense counsel told the undersigned he

9 was “advised that the former caregiver was Esther Moomjian.” (Ex. 2.) Ms. Moomjian spoke to the

10 Court in support of the Defendant at the sentencing on September 24, 2025. She described the

11 Defendant as her “best friend,” who she has known for over 25 years. Doc. 100 at 17:16.) At the time

12 of the sentencing, the Defendant was seeking a non-custodial sentence in part to care for her mother and

13 her son. (Doc. 84 at 27:9-24.)

14 Ms. Moomjian told the Court, “I actually live with Sandra, but I am not her caretaker. I am never

15 home. I have a completely separate life . . . . It is true, Cassie has been her primary caretaker. She’s been

16 very patient, more patient than I could be.” (Doc. 100 at 16:16-18, 23-24.) Ms. Moomjian moved out of

17 Ms. Will’s home in December and moved into the Defendant’s rental until attached to the Defendant’s

18 residence located at 111 Belwood Gateway, Los Gatos, CA. (Ex. 2.) The Court ordered Defendant to
19 forfeit her interest in that property at sentencing. (Docs. 100 at 40:17-20, 111 at 7.)

20 The Defendant claims that her mother is unable to dress, bathe, or manage her medications

21 without assistance. (Doc. 118 at 1: 27-28.) The Court has the opportunity to evaluate Ms. Will at the

22 Defendant’s sentencing. At that hearing, Ms. Will told the Court that she depends on the Defendant “not

23 just for everyday tasks, including reading the documents and bills, using technology and the phone,

24 organizing and attending doctor meetings and medicines and keeping me safe, but also for emotional

25 support.” (Doc. 100 at 14:3-7.) The Court considered this information when imposing its custodial

26 sentence. Moreover, Ms. Will apparently does not have a caregiver. (Ex. 1 at 2.) She lives alone and

27 golfs several times a week. (Id.) The Defendant’s ex-wife and the mother of her son informed law

28 enforcement that the Defendant took their son to the driving range in late December. (Id.)

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Case 5:24-cr-00292-PCP Document 119 Filed 01/07/26 Page 3 of 3

1 It is not credible that the Defendant’s best friend “unexpectedly quit” caring for Ms. Will and

2 moved into the Defendant’s rental unit, that the Defendant left her mother to go on a week-long ski trip

3 without any caregiver in place for a woman who purportedly cannot dress or bathe herself, and that her

4 mother is unable to care for herself. (See Doc. 118-1 at 6 (Defendant claims her mother “receives no

5 daily care aside from my assistance.”).

6 It appears that the Defendant may be seeking a 60-day continuance in the hope that she can again

7 take her son to spring training in Arizona in March. (Ex. 1 at 1.) The Defendant previously misled U.S.

8 Pretrial Services and the government by seeking permission to travel for a memorial service without

9 disclosing that the week-long the trip was to spring training in Arizona with her son. (Ex. 3.) The Court

10 subsequently approved the travel with more information. (Docs. 37, 28.) It also appears the Defendant

11 may be drinking alcohol in violation of her conditions of release. (Ex. 1 at 1-2.)

12 It is time for the Defendant to start serving her sentence. This Motion is a last-ditch effort to

13 delay serving her sentence. The Court previously considered the needs of the Defendant’s family in

14 fashioning its sentence. Nothing has materially changed since that decision in September. The Motion

15 should be denied.

17 DATED: January 7, 2026 Respectfully submitted,

18 CRAIG H. MISSAKIAN
United States Attorney
19

20
/s/
21 SARAH E. GRISWOLD
Assistant United States Attorney
22

U.S. OPP’N TO MOT. EXTEND SELF-SURRENDER 3
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