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Defendant Tamir Pratt's Motion to Continue Sentencing and All Related Deadlines — United States v. Tamir Pratt (Dkt. 21)

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Defendant Tamir Pratt's Motion to Continue Sentencing and All Related Deadlines in United States of America v. Tamir Pratt, Criminal Action No. 2:23-cr-00038, in the United States District Court for the Southern District of West Virginia, brought by counsel Paul E. Stroebel and Stroebel & Stroebel, P.L.L.C. The motion states that the sentencing hearing is scheduled for July 6, 2023 at 10:00 a.m. before the Honorable Joseph R. Goodwin, with a Presentence Investigation Report deadline of June 22, 2023 and sentencing memoranda due June 29, 2023. It asks for additional time to investigate and gather information regarding mitigating circumstances and requests a continuance of at least forty-five (45) days from the present scheduled date. The certificate of service is dated the 13th day June, 2023.

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“Defendant Tamir Pratt's Motion to Continue Sentencing and All Related Deadlines — United States v. Tamir Pratt (Dkt. 21).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-wvsd-236441-21-0-408abf6b5c/, SHA-256 1f30c9d1142e6bf705c9239cd1b8d00e7be2a77e10a9842070dbf6a96c2affc8.

Full text

                     IN THE UNITED STATES DISTRICT COURT
                 FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA


UNITED STATES OF AMERICA

               Plaintiff,

v.                                                            Criminal Action No. 2:23-cr-00038


TAMIR PRATT,

               Defendant.

       DEFENDANT TAMIR PRATT’S MOTION TO CONTINUE SENTENCING
                    AND ALL RELATED DEADLINES

       Comes now Defendant Tamir Pratt by counsel, Paul E. Stroebel and Stroebel & Stroebel,

P.L.L.C., and moves this Honorable Court for an Order continuing the sentencing hearing and all

related deadlines from the present scheduled date. In support thereof, counsel states as follows:

       1.      The sentencing hearing in this matter is scheduled for July 6, 2023 at 10:00 a.m.,

before the Honorable Joseph R. Goodwin.

       2.      The Presentence Investigation Report Deadline is June 22, 2023, and Sentencing

Memorandum are due by June 29, 2023.

       3.      In order to effectively and adequately represent the defendant, counsel for the

defendant requests additional time to further investigate and gather information regarding

mitigating circumstances in this matter and to support Mr. Pratt’s position at sentencing.

       4.      Defendant’s counsel has consulted with the defendant regarding the proposed

continuance and the defendant supports this motion to continue.

       5.      Counsel states that this request for additional time is not due to dilatory practice.
       WHEREFORE, the defendant respectfully requests that this Honorable Court enter an

Order continuing the Sentencing Hearing and all related deadlines, including the deadline for the

Final Presentence Investigation Report and the deadline to file Sentencing Memorandum for at

least forty-five (45) days from the present scheduled date.




                                             TAMIR PRATT,
                                             By Counsel,

                                             /s/Paul E. Stroebel
                                             Paul E. Stroebel, Esquire (WV BAR 13269)
                                             Stroebel & Stroebel, P.L.L.C.
                                             Post Office Box 2582
                                             Charleston, West Virginia 25329-2582
                   IN THE UNITED STATES DISTRICT COURT
               FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA


UNITED STATES OF AMERICA

             Plaintiff,

v.                                                      Criminal Action No. 2:23-cr-00038


TAMIR PRATT,

             Defendant.

                             CERTIFICATE OF SERVICE

       I, PAUL E. STROEBEL, hereby certify that a true and correct copy of the foregoing
“Defendant Tamir Pratt’s Motion to Continue Sentencing and all related deadlines” has been
served upon all counsel of record this 13th day June, 2023, to the following:

                                   Jonathan Storage, Esquire
                                Assistant United States Attorney
                               300 Virginia Street E.; Suite 4000
                                    Charleston, WV 25301



                                                        /s/Paul E. Stroebel
                                                        Paul E. Stroebel, Esquire

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