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Defendant Tamir Pratt's Motion to Continue Sentencing and All Related Deadlines — United States v. Tamir Pratt (Dkt. 24)

Summary

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. The motion states that the sentencing hearing is scheduled for August 24, 2023 at 1:30 p.m. and that some of the alleged PPP loan funds at issue have been frozen in a CapitalOne account, with counsel and Assistant United States Attorney Storage working with CapitalOne to get an accounting. It states that the parties request an additional thirty (30) days and that the government does not have an objection. The certificate of service is dated the 2nd day August, 2023.

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“Defendant Tamir Pratt's Motion to Continue Sentencing and All Related Deadlines — United States v. Tamir Pratt (Dkt. 24).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-wvsd-236441-24-0-e79c90e2d6/, SHA-256 c479e2e9e13212f430bd7443d20e98f27d46905e83c7feb65d25dfe9f5696fb6.

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 dates. In support thereof, counsel states as follows:

       1.      The sentencing hearing in this matter is scheduled for August 24, 2023 at 1:30 p.m.,

before the Honorable Joseph R. Goodwin.

       2.      The Final Presentence Report Deadline is August 10, 2023, and Sentencing

Memorandum are due by August 17, 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.      Some of the alleged PPP loan funds at issue in this matter have been frozen in a

CapitalOne account. The Defendant’s counsel as well as Assistant United States Attorney Storage

are working with CapitalOne to get an accounting of the funds that are frozen in this account. The

parties request an additional thirty (30) days in order to ensure there has been a full accounting of
these funds prior to Defendant’s sentencing in this matter.

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

continuance and the defendant supports this motion to continue.

       6.      Defense counsel has consulted with the Assistant United States Attorney in this

matter and the government does not have an objection to this continuance.

       7.       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 thirty (30) days from the present scheduled dates.




                                               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 2nd day August, 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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