Motion to Continue Sentencing Date — United States v. Leslie Danielle Bethea (Eastern District of Tennessee)

Summary

A Motion to Continue Sentencing Date, Document 44, filed July 24, 2019 in United States of America v. Leslie Danielle Bethea, No. 2:18-CR-25 (Case 2:18-cr-00025-JRG-CRW), in the United States District Court for the Eastern District of Tennessee, Northeastern Division. Counsel for the Defendant requests an order continuing the sentencing hearing scheduled for August 5, 2019. The motion states that counsel was appointed on July 24, 2019 after the withdrawal of prior counsel and that it is not possible to review the file, develop rapport with the client and prepare a sentencing memorandum by the date set. It states that the Government and the Defendant have no objections, and the signature block names Douglas L. Payne.

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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TENNESSEE
NORTHEASTERN DIVISION

UNITED STATES OF AMERICA

v. No. 2:18-CR-25

LESLIE DANIELLE BETHEA
MOTION TO CONTINUE SENTENCING DATE

Comes now Counsel for the Defendant, Leslie Danielle Bethea, and would request
of this Court an Order continuing the sentencing hearing for the reasons set forth
hereinafter:

1. This Court appointed this attorney to represent the Defendant on July 24,
2019 after the withdrawal of prior counsel. The Defendant is housed in North Carolina.
The sentencing hearing is scheduled for August 5, 2019.

2. The Government and the Defendant have been consulted prior to the filing
of this motion and there are no objections.

3. This Defendant is entitled to competent representation at the sentencing
hearing. Based upon this attorney's experience in numerous federal cases over the past
20 plus years, it is not possible for this attorney to review the file, develop rapport with the
client, prepare a sentencing memorandum and be prepared by the date currently set.

WHEREFORE, the Movant respectfully prays for the relief set forth herein.

Case 2:18-cr-00025-JRG-CRW Document 44 _ Filed07/24/19 Pagelof2 PagelD
#: 378
Respectfully submitted,

Leslie Daniella Bethea

By: /s/Douglas L. Payne
DOUGLAS L. PAYNE

Attorney for Defendant, BPR # 013380
401 West Irish Street

Greeneville, Tennessee 37743

(423) 639-2220

CERTIFICATE OF SERVICE

|, Douglas L. Payne, do hereby certify that on July 24, 2019, a copy of the foregoing
Motion for Continuance was filed electronically. Notice of this filing will be sent by
operation of the Court’s electronic filing system to all parties indicated on the electronic
filing receipt. All other parties will be served by regular U.S. mail. Parties may access this
filing through the Court's electronic filing system.

/s/Douglas L. Payne
DOUGLAS L. PAYNE

#: 379


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