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Motion to Delay Surrender Date — United States v. Edward McCorkle (Dkt. 20)

Summary

Motion to Delay Surrender Date in United States v. Edward McCorkle, Docket No. 1:25-CR-00270-RDB, District of Maryland. Edward McCorkle, through attorney Matthew Zernhelt, requests that the Court delay his surrender date by 60 days, until March 28, 2026. The motion states that Mr. McCorkle entered a guilty plea on September 15, 2025, to one count of conspiracy to commit wire fraud, is set to be sentenced on January 27, 2026, and faces sentencing guidelines of 30 to 37 months. It states that he has remained in the community with Pretrial Services supervision without violating its terms, and that he needs additional time to get his affairs in order, including daycare for his children.

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“Motion to Delay Surrender Date — United States v. Edward McCorkle (Dkt. 20).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-590048-20-0-8c136734ed/, SHA-256 702a15b3cb00c41222066be42b09735e676c0e1f83a55fd4431eb6f8487aa052.

Full text

       Case 1:25-cr-00270-RDB         Document 20    Filed 01/08/26    Page 1 of 3



                       UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF MARYLAND

 UNITED STATES OF AMERICA,       *
                                 *
                                 *
                                 *
 v.                              *
                                 *
                                 *    Docket No.: 1:25-CR-00270-RDB
                                 *
  EDWARD MCCORKLE.               *
 * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
                     MOTION TO DELAY SURRENDER DATE

      Edward McCorkle, through his attorney, Matthew Zernhelt, respectfully requests

that this Honorable Court delay his surrender date by 60 days. In support of this Motion,

the Defendant states the following:

1.    Mr. McCorkle entered a plea of guilty before this Court on September 15, 2025, to

one count of conspiracy to commit wire fraud in violation of 18 U.S.C. §1349 and §1343.

Mr. McCorkle’s guilty plea was tendered pursuant to an agreement under the Federal

Rules of Criminal Procedure 11(c)(1)(B).

2.    Mr. McCorkle is set to be sentenced by this Court on January 27, 2026. He is

facing sentencing guidelines of 30 to 37 months.

3.    Mr. McCorkle has remained in the community during pretrial proceedings. He was

released on his own recognizance, with Pretrial Services supervision, on September 15,

2025. Mr. McCorkle has not violated any of the terms of his supervision.

4.    Mr. McCorkle requests additional time to get his affairs in order before his

incarceration. Mr. McCorkle watches his 4-year-old daughter and 6-year-old son daily as
       Case 1:25-cr-00270-RDB        Document 20      Filed 01/08/26     Page 2 of 3



Mr. McCorkle’s partner works. Mr. McCorkle drives the children to and from school and

to their activities outside of school. Mr. McCorkle and his partner are working to find

stable and reliable daycare to replace Mr. McCorkle’s care.


WHEREFORE, the Defendant prays this Honorable Court sign the attached Order

granting his request to delay his surrender date until March 28, 2026.


                                          Respectfully submitted,


                                          _______/s/_________________________
                                          Matthew Zernhelt
                                          Attorney number: 11613
                                          Zernhelt Law LLC
                                          9520 Berger Road, Suite 212
                                          Columbia, MD 21046
                                          Ph.: (443) 690-0870
                                          mz@zernheltlaw.com




                             CERTIFICATE OF SERVICE

I hereby certify that on the date of filing this motion, a copy of the foregoing was served

electronically by ECF to: Office of the United States Attorney.


                                          _______/s/_________________________
                                          Matthew Zernhelt
Case 1:25-cr-00270-RDB   Document 20   Filed 01/08/26   Page 3 of 3

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