Unopposed Motion to Extend the PSR Objections Deadline and Continue Sentencing — United States v. Dontrell Barnes (Dkt. 42)

Summary

Unopposed Motion to Extend the PSR Objections Deadline and Continue Sentencing in United States v. Dontrell Barnes, No. 5:23-CR-0094-D-1, Eastern District of North Carolina, Western Division, filed 07/07/23. Defendant Dontrell Barnes, through counsel, asks the Court to extend the draft presentence report objections deadline until September 18, 2023, and to continue the sentencing hearing currently scheduled for the August 28, 2023, term. The motion states that Mr. Barnes pled guilty pursuant to a plea agreement to one (1) count of Conspiracy to Commit Wire Fraud, and that undersigned counsel seeks additional time to review the draft PSR with him. The signature block names Jean-Paul E. Jacquet-Freese, Assistant Federal Public Defender.

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“Unopposed Motion to Extend the PSR Objections Deadline and Continue Sentencing — United States v. Dontrell Barnes (Dkt. 42).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-nced-200165-42-0-8cd600a729/, SHA-256 4e6dbba74ee1194478f97c65563faaaaefd30d8f788793e27e49c73ceff9b84c.

Full text

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NORTH CAROLINA
WESTERN DIVISION

NO. 5:23-CR-0094-D-1

UNITED STATES OF AMERICA
UNOPPOSED MOTION TO EXTEND THE PSR
v. OBJECTIONS DEADLINE AND CONTINUE
SENTENCING
DONTRELL BARNES

The defendant, Dontrell Barnes, by and through counsel, respectfully moves this

Honorable Court to extend the Objections to the draft presentence report deadline for and

additional twenty (21) days until September 18, 2023, and to continue the sentencing hearing

currently scheduled for August 28, 2023, term accordingly or to a date that the Court deems

appropriate. The following is offered in support of this request:

1. Mr. Barnes was named in a criminal complaint filed on March 23, 2023, alleging

Conspiracy to Commit Wire Fraud, in violation of 18 U.S. Code § 1349.

2. The Office of the Federal Public Defender was appointed to represent Mr. Barnes on

November 22, 2022. Defense counsel entered his Notice of Appearance on November

29. 2022.

3. On May 24, 2023, Mr. Barnes waived his right to prosecution by indictment and

consented to prosecution by criminal information. Mr. Barnes pled guilty pursuant to a

plea agreement to one (1) count of Conspiracy to Commit Wire Fraud.

4. Response of Objections to the draft PSR presently are due no later than July 10, 2023.

The sentencing hearing for this matter is currently set for the August 28, 2023, term in

Raleigh North Carolina.

Case 5:23-cr-00094-D Document 42 Filed 07/07/23 Page 1 of 4
5. Mr. Barnes is currently out of custody on conditions of release agreed upon by both

parties at his Plea hearing.

6. Undersigned counsel conferred with counsel for the government, Assistant United

States Attorney David G. Beraka, and both sides believe that a twenty-one (21) day

extension of the PSR response deadline and as well as a continuance of the sentencing

hearing.

7. Undersigned counsel seeks additional time to meet with Mr. Barnes to review the Draft

PSR and to prepare for the hearing. Moreover, undersigned counsel expects to be taking

a period of family medical leave beginning during the week of July 10, 2023.

8. This Motion is made in good faith and not for the purposes of delay. Neither the

Government nor the Defendant would be prejudiced by the extension and continuance

sought herein.

WHEREFORE, the Defendant respectfully requests that the deadline for filing Response

to the Objections of Draft PSR be extended for at least twenty-one (21) days, through and including

September 18, 2023, and that the sentencing in this matter be continued accordingly to a date that

the Court deems appropriate. The ends of justice served by this Motion outweigh the interests of

the public and the Defendant in a speedy trial as set forth in 18 U.S.C. § 3161(h)(7)(A).

Case 5:23-cr-00094-D Document 42 Filed 07/07/23 Page 2 of 4
Respectfully requested this 7th day of July 2023.

G. ALAN DuBOIS
Federal Public Defender

/s/ Jean-Paul E. Jacquet-Freese
JEAN-PAUL E. JACQUET-FREESE
Assistant Federal Public Defender
Attorney for Defendant
Office of the Federal Public Defender
150 Fayetteville Street, Suite 450
Raleigh, North Carolina 27601
Telephone: 919-856-4236
Fax: 919-856-4477
E-mail: Jean-Paul_Jacquet-Freese@fd.org
NC State Bar No. 57581
DC Bar No. 1619210
LR 57.1 Counsel Appointed

Case 5:23-cr-00094-D Document 42 Filed 07/07/23 Page 3 of 4
CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was served upon:

David G. Beraka
United States Attorney's Office
150 Fayetteville St, Suite 2100
Raleigh, NC 27601
919-856-4871
Email: david.beraka@usdoj.gov

by electronically filing the foregoing with the Clerk of Court on this date, using the CM/ECF

system which will send notification of such filing to the above, and on

This the 7th day of July 2023.

Case 5:23-cr-00094-D Document 42 Filed 07/07/23 Page 4 of 4

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