Unopposed Motion to Continue Sentencing Hearing — United States v. Crystal Denean Harvell (Dkt. 23)

Summary

Document 23, filed October 28, 2024 in Case No. 3:24-cr-179-WWB-LLL in the U.S. District Court for the Middle District of Florida, Jacksonville Division, is an Unopposed Motion to Continue Sentencing Hearing in United States of America v. Crystal Denean Harvell. She asks to continue the sentencing set for December 6, 2024 at 1:30 P.M. by ninety days. Her Federal Defender counsel says she began working with Ms. Harvell on September 12, 2024, that records requested from multiple facilities are still outstanding at at least three, and that Ms. Harvell has met with the government to fulfill her obligations under the Plea Agreement and expects more meetings. The motion says Assistant United States Attorney Kevin Frein has no objection and cites Local Rule 3.09.

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Cite this document

“Unopposed Motion to Continue Sentencing Hearing — United States v. Crystal Denean Harvell (Dkt. 23).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flmd-431431-23-0-b12bf6ff69/, SHA-256 f253ebecb9bf88a149236d7342f0198d687eae6de18cee8247259c4e8a7e060a.

Full text

Case 3:24-cr-00179-WWB-LLL     Document 23    Filed 10/28/24   Page 1 of 3 PageID 80




                       UNITED STATES DISTRICT COURT
                        MIDDLE DISTRICT OF FLORIDA
                           JACKSONVILLE DIVISION

 UNITED STATES OF AMERICA

 v.                                          Case No. 3:24-cr-179-WWB-LLL

 CRYSTAL DENEAN HARVELL
 ______________________________________

         UNOPPOSED MOTION TO CONTINUE SENTENCING HEARING

       The Defendant, Crystal Denean Harvell, pursuant to Local Rule 3.09,

Middle District of Florida, requests this Court to continue the Sentencing Hearing

presently scheduled for December 6, 2024 at 1:30 P.M. and as grounds, states the

following:

       1. The Office of the Federal Defender was appointed to represent Ms.

Harvell at her Initial Appearance, which also served as a Change of Plea Hearing

(Doc. 14). This Court’s Acceptance of Plea was entered on September 12, 2024

scheduling Ms. Harvell’s sentencing hearing for December 6, 2024 at 1:30 P.M.

(Doc. 18). Prior to the Office of the Federal Defender being appointed, Ms. Harvell

had been represented by private counsel. As such, undersigned counsel has only

been working with Ms. Harvell since September 12, 2024.

       2. Undersigned counsel and Ms. Harvell have met several times to discuss

 Ms. Harvell’s case and have begun working on gathering materials that they would

 like to present at the Sentencing Hearing. The Office of the Federal Defender has

 ordered records from multiple facilities, and while some of the requested records


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Case 3:24-cr-00179-WWB-LLL     Document 23     Filed 10/28/24   Page 2 of 3 PageID 81




 of been obtained, there are still at least three (3) facilities that have not yet

 responded to the records request.

       3. In addition to undersigned counsel’s mitigation efforts, Ms. Harvell has

 recently met with the government to fulfill her obligations under the Plea

 Agreement. It is likely that Ms. Harvell will need to have additional meetings for

 that purpose and would like to conduct those meetings prior to her sentencing.

       4. Wherefore, Ms. Harvell requests a continuance of the sentencing hearing

 for ninety (90) days in order to work on these matters.

       5. Undersigned counsel has contacted Assistant United States Attorney

 Kevin Frein and he has no objections.

       6.   This motion is made in good faith and not for the purpose of unduly

 delaying the proceedings.

      WHEREFORE, the Defendant requests that the Court continue the hearing

presently scheduled and set the hearing 90 days from the scheduled matter.

                          MEMORANDUM OF LAW

       Local Rule 3.09, Middle District of Florida, provides that a continuance may

 be allowed by Order of the Court for good cause shown. The defendant suggests

 the foregoing constitutes good cause for the requested continuance.


                                              Respectfully submitted,

                                              A. FITZGERALD HALL, ESQ.
                                              FEDERAL DEFENDER, MDFL

                                              s/ Sabra M. Barnett

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Case 3:24-cr-00179-WWB-LLL     Document 23    Filed 10/28/24   Page 3 of 3 PageID 82




                                             Sabra M. Barnett, Esq.
                                             Florida Bar No. 1058792
                                             Assistant Federal Defender
                                             200 West Forsyth Street, Suite 1240
                                             Jacksonville, FL 32202
                                             Telephone: (904) 232-3039
                                             Fax: (904) 232-1937
                                             Email: sabra_barnett@fd.org


                           CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that on this 28th day of October 2024, a true copy of

 the foregoing was served by electronic notification to Kevin Frein, Office of the

 United States Attorney.


                                             s/ Sabra M. Barnett
                                             Sabra M. Barnett, Esq.




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