Motion to Continue Sentencing — United States v. Natosia Jerome Jenkins (Dkt. 21)

Summary

Motion to Continue Sentencing in United States v. Natosia Jerome Jenkins, No. 5:23-CR-167-D1, Eastern District of North Carolina, Western Division, filed 10/03/23. The defendant, through attorney William F. Finn Jr., asks the Court to continue sentencing, presently set for the October 30, 2023, term of court, for a period of thirty days. The motion states that on July 27, 2023, the defendant waived indictment and pled guilty to the criminal information, and it gives the defendant's medical treatment as the ground for the request. It states that AUSA David Beraka has been contacted about the motion and does not object.

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“Motion to Continue Sentencing — United States v. Natosia Jerome Jenkins (Dkt. 21).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-nced-202244-21-0-5ac4d6f6de/, SHA-256 a0b97582842e83a7f0d7c6e773b87170f1fe2f638488b273f2008f26592f3540.

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
WESTERN DIVISION
NO. 5:23-CR-167-D1

UNITED STATES OF AMERICA )
v. ) MOTION TO CONTINUE SENTENCING
)
)
NATOSIA JEROME JENKINS, )
_____________________________________________________________________________________

NOW COMES, the defendant, Natosia Jerome Jenkins, by and through his attorney William F. Finn Jr.,

and hereby moves this honorable court to continue his sentencing which is presently set for the October

30, 2023, term of court. In support of said motion, the defendant shows upon this court the following:

1. On June 2, 2023, the defendant was charged through criminal information with conspiracy to

commit wire fraud in violation of 18 USC § 1349. (D.E.1)

2. On July 27, 2023, the defendant waived indictment and pled guilty to the criminal information.

(D.E. 12).

3. Sentencing was set for the October 30, 2023, term of court.

4. The Government did not move for detention and the defendant was allowed to remain free

subject to the conditions set out in the order setting conditions of release. (D.E. 12)

5. Mr. Jenkins suffers from cancer and is undergoing outpatient chemotherapy treatment at Duke

University Hospital.

6. In December of 2017, when it was discovered that the cancer had metastasized, Mr. Jenkins had

his right hip replaced.

7. Recently, Mr. Jenkins has been experiencing pain in the same hip and there is a concern that the

cancer has returned to the hip.

8. Mr. Jenkins has been referred to additional physicians to evaluate his hip, which has resulted in a

pause in his chemotherapy treatments.

Case 5:23-cr-00167-D Document 21 Filed 10/03/23 Page 1 of 3
9. As of the writing of this motion, Mr. Jenkins is not scheduled to resume his chemotherapy

treatments until October 24, 2023.

10. Mr. Jenkins’ cancer is not curable but can be managed and maintained with the proper

combination of chemotherapy and bone marrow transplants.

11. Mr. Jenkins underwent his most recent bone marrow transplantation in March of this year.

12. If Mr. Jenkins receives an active sentence, a treatment plan will need to be put in place with the

Bureau of Prisons.

13. This is the Defendant’s first motion to continue sentencing.

14. AUSA David Beraka has been contacted about this motion and does not object.

Based on the foregoing, Mr. Jenkins now moves this Court to continue his sentencing for a period of

thirty days.

Respectfully submitted this the 3rd day of October 2023.

/s/ William F. Finn, Jr.
WILLIAM F. FINN, JR.
Retained Attorney for Defendant
Sandman, Finn & Fitzhugh, PLLC
7101 Creedmoor Road, Suite 122
Raleigh, North Carolina 27613
Telephone: 919-845-6688
Facsimile: 919-845-6639
Email: bill@ccdattorneys.com
N.C. State Bar NO. 26715

Case 5:23-cr-00167-D Document 21 Filed 10/03/23 Page 2 of 3
CERTIFICATE OF SERVICE

The undersigned certifies that on the date shown below the foregoing was served with the Clerk of Court
through the electronic filing system which will send notification to all registered participants and David
Beraka Assistant United States Attorney.

Respectfully submitted this the 3rd day of October 2023.

David Beraka
Assistant United States Attorney
United States Attorney’s Office
Eastern District of North Carolina
150 Fayetteville Street, Suite 2100
Raleigh, North Carolina 27601
david.beraka@usdoj.gov
Telephone: 919-856-4871
Facsimile: 919-856-4487

Case 5:23-cr-00167-D Document 21 Filed 10/03/23 Page 3 of 3

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