Unopposed Motion for Extension of Time to Self-Surrender — United States v. Crystal Denean Harvell (Document 43)

Summary

Document 43, filed April 8, 2025 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 for Extension of Time to Self-Surrender in United States of America v. Crystal Denean Harvell. It states she was sentenced on March 10, 2025 to 24 months of incarceration with a self-surrender date of 5:00 p.m. on Friday, April 11, 2025 (Doc. 41). Because the Bureau of Prisons had not yet designated a facility, she asks for a fourteen day extension so she can report directly to the designated facility instead of being processed by the U.S. Marshals. The motion says she is not seeking delay and that Assistant United States Attorney Kevin Frein has no objection.

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Case 3:24-cr-00179-WWB-LLL      Document 43     Filed 04/08/25   Page 1 of 3 PageID 441




                        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 FOR EXTENSION OF TIME TO SELF-SURRENDER

        Defendant, Crystal Denean Harvell, by and through undersigned counsel,

 hereby moves this Court for a fourteen (14) day extension to self-surrender to the

 Bureau of Prisons (BOP) and as grounds, states the following:

   1. On March 10, 2025, Ms. Harvell came before this Court and was sentenced

       to 24 months of incarceration. She was given a self-surrender date of 5:00

       p.m. on Friday, April 11, 2025 (Doc. 41).

   2. Ms. Harvell is prepared to self-surrender. However, as of the filing of this

       Motion, the Bureau of Prisons has not provided her with a designated facility

       for her surrender.

   3. If the Bureau of Prisons does not provide Ms. Harvell and the U.S. Marshals

       with a designated facility prior to Friday, April 11, 2025, Ms. Harvell will be

       required to surrender to the United States Marshals office in Jacksonville,

       Florida. If Ms. Harvell is required to self-surrender to the United States


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Case 3:24-cr-00179-WWB-LLL      Document 43     Filed 04/08/25    Page 2 of 3 PageID 442



      Marshal at 5:00 on Friday, April 11, 2025, the Marshals will have to process

      her, place her in a local jail facility until such time that the Bureau of Prisons

      provides a designated facility, and will then have to transport her to that

      facility.

   4. This Court is familiar with Ms. Harvell’s medical and mental health struggles,

      which likely will be exacerbated if she is required to move to various facilities

      by bus or plane prior to being housed at the facility of designation.

   5. Ms. Harvell would like to begin her sentence and is not asking for this

      extension to delay her start date in anyway. The only reason for this request

      is to ensure that she can self-surrender directly to the designated facility to

      avoid having to be transported by the U.S. Marshals and the unknowns that

      exist with this type of surrender.

   6. The supervising Pretrial Officer, Kimberly Barrett, indicates that Ms. Harvell

      has remained complaint while awaiting her self-surrender date. It is

      undersigned counsel’s understanding from Ms. Barrett that the Pretrial

      Service Office does not take a position on requests to extend a self-surrender

      date.

   7. Assistant United States Attorney Kevin Frein has indicated that he has no

      objection to the extension request.

   8. This Motion is made in good faith and not for the purpose of delay.


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Case 3:24-cr-00179-WWB-LLL     Document 43       Filed 04/08/25   Page 3 of 3 PageID 443



       WHEREFORE, Ms. Harvell respectfully requests this Court grant a fourteen-

 day extension to 5:00 p.m. on Friday, April 19th, 2025 for Ms. Harvell to self-

 surrender to the Bureau of Prisons.

       Dated: April 8, 2025

                                               A. FITZGERALD HALL, ESQ.
                                               FEDERAL DEFENDER, MDFL

                                               s/ Sabra M. Barnett
                                               Sabra M. Barnett, Esq.
                                               Alabama Bar No. 8834R69W
                                               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 a copy of the foregoing has been furnished by

electronic notification to the Office of the United States Attorney, 300 N. Hogan St,

Suite 700, Jacksonville, Florida 32202, this 8th day of April 2025.


                                               s/ Sabra M. Barnett
                                               Sabra M. Barnett, Esq.
                                               Assistant Federal Defender




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