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Motion to Continue Sentencing Hearing — No. 4:21-cr-00532 (Dkt. 144, E.D. Mo.)

Summary

A motion to continue the sentencing hearing, filed December 2, 2022 as Doc. #144 in United States v. George Reed, Case No. 4:21-cr-532-2 SEP, in the U.S. District Court for the Eastern District of Missouri. Defense counsel asks the court to continue the sentencing hearing scheduled for December 7, 2022 by ninety (90) days. The motion states that Reed entered a guilty plea on September 6, 2022, that counsel plans to address potential issues with the presentence report with the probation office, and that the government's attorney has no objection.

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“Motion to Continue Sentencing Hearing — No. 4:21-cr-00532 (Dkt. 144, E.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-to-continue-sentencing-hearing-no-4-21-cr-00532-dkt-144-e-d-mo-19d215ef78/, SHA-256 fb564bec2f44d2c9fea65843e07378444d380c43886db7a2538d98326cfe481e.

Full text

Case: 4:21-cr-00532-SEP Doc. #: 144 Filed: 12/02/22 Page: 1 of 2 PageID #: 1572




                             UNITED STATES DISTRICT COURT
                             EASTERN DISTRICT OF MISSOURI
                                  EASTERN DIVISION

UNITED STATES OF AMERICA,                      )
                                               )
       Plaintiff,                              )
                                               )
vs.                                            ) Case No.: 4:21-cr-532-2 SEP
                                               )
GEORGE REED,                                   )
                                               )
       Defendant.                              )

                    MOTION TO CONTINUE SENTENCING HEARING

       COMES NOW Defendant, George Reed, by and through counsel, and hereby moves this

Court to continue the sentencing hearing scheduled for December 7, 2022, by a period of ninety

(90) days. In support of this motion, Defendant states as follows:

       1.      Defendant entered a guilty plea on September 6, 2022.

       2.      Defendant is presently scheduled to be sentenced on December 7, 2022.

       3.      Counsel has received and reviewed the Presentence Investigation Report with

               Defendant. There are some potential issues with the PSR that counsel plans to

               address with the probation office prior to the sentencing hearing.

       5.      Due to competing work obligations along with complexities specific to this case,

               counsel anticipates this process will require an additional ninety (90) days beyond

               the current scheduled sentencing hearing.

       6.      Defendant, through counsel, has spoken with Assistant United States Attorney

               Gwen Carroll. Ms. Carroll has no objection to Defendant’s request.




                                                 1
Case: 4:21-cr-00532-SEP Doc. #: 144 Filed: 12/02/22 Page: 2 of 2 PageID #: 1573




               WHEREFORE, Defendant respectfully requests this Honorable Court continue

the sentencing hearing presently scheduled for December 7, 2022, by a period of ninety (90)

days.




                                             Respectfully submitted,

                                             ROSENBLUM, SCHWARTZ & FRY, PC

                                     By:     /S/ Marc Johnson
                                             MARC JOHNSON, #58065 MO
                                             Attorney for Defendant
                                             120 S. Central Avenue, Suite 130
                                             Clayton, Missouri 63105
                                             (314) 862-4332/Facsimile 862-8050

                                CERTIFICATE OF SERVICE

       I hereby certify that on December 2, 2022, the foregoing was electronically filed with the
Clerk of the Court to be served by operation of the Court’s electronic filing system upon Ms.
Gwen Carroll, assistant United States attorney.




                                                2

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