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Motion to Continue Sentencing — No. 2:21-cr-00520 (Dkt. 202, D. Utah)

Summary

A motion to continue sentencing, filed February 29, 2024 as Document 202 in United States v. Allison Marie Baver, Case No. 2:21-cr-00520, in the U.S. District Court for the District of Utah, before Judge Jill Parrish. The Federal Public Defender asks the court to continue the sentencing hearing set for April 10, 2024 at 11:00 a.m., either for 150 days from mid-February or for 90 days past the set date. The motion explains that records for a neuropsychological assessment are still being collected and that the expert, a social worker and counsel need further time to complete reports and a sentencing memorandum. It states that the government does not oppose.

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Cite this document

“Motion to Continue Sentencing — No. 2:21-cr-00520 (Dkt. 202, D. Utah).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-to-continue-sentencing-no-2-21-cr-00520-dkt-202-d-utah-a462d5cda7/, SHA-256 ad81094fb43567d76aa195ddd99de38ca63c04e35158edfd0392a1ec3eaafd71.

Full text

 Case 2:21-cr-00520-JNP Document 202 Filed 02/29/24 PageID.3210 Page 1 of 2




SCOTT KEITH WILSON, Federal Public Defender (#7347)
KRISTEN R. ANGELOS, Assistant Federal Defender (#8314)
ROBERT K. HUNT, Assistant Federal Defender (#5722)
OFFICE OF THE FEDERAL PUBLIC DEFENDER
DISTRICT OF UTAH
Attorneys for Defendant
46 West Broadway, Suite 110
Salt Lake City, Utah 84101
Telephone: (801) 524-4010
Email: kris_angelos@fd.org and robert_hunt@fd.org



                        IN THE UNITED STATES DISTRICT COURT

                                     DISTRICT OF UTAH


  UNITED STATES OF AMERICA,                                 MOTION TO CONTINUE
                                                               SENTENCING
                 Plaintiff,

  v.

  ALLISON MARIE BAVER,                                         Case No. 2:21-cr-00520

                 Defendant.                                  Honorable Judge Jill Parrish



       Defendant Allison Marie Baver (“Ms. Baver”), by and through counsel, Kristen R.

Angelos and Robert K. Hunt, moves this Court for an order continuing the sentencing hearing set

for April 10, 2024, at 11:00 a.m., for a period of 150 days from mid-February or a continuance of

the hearing for 90 days past the currently set date. In support, Ms. Baver states the following:

   1. Although Ms. Baver has already started a neuropsychological assessment, records

continue to be requested and collected in order for the assessment to be complete. It’s

anticipated that our records requests will take an additional 30 days from today’s date.

                                                1
 Case 2:21-cr-00520-JNP Document 202 Filed 02/29/24 PageID.3211 Page 2 of 2




   2. Once the records have arrived, our expert will need an additional 60 days to complete the

assessment and provide findings.

   3. Our social worker, who has been working with Ms. Baver to complete a life history, will

need an additional 30 days after the draft is completed to summarize and synthesize everything.

   4. Upon receipt of the expert’s and social worker’s reports, undersigned counsel will need

an additional 30 days to prepare a sentencing memorandum summarizing the same. Counsel

believes a sentencing memorandum and the associated reports will aid and assist the Court in

determining sentencing in this matter.

       For the foregoing reasons, Ms. Baver respectfully requests a continuance of the currently

scheduled sentencing hearing set for April 10, 2024. The Government does not oppose the

continuance. Any reports will be provided to the Government as they are completed. A

proposed Order is submitted with this Motion.

       DATED this 29th day of February, 2024.



                                            /s/ Kristen R. Angelos
                                            KRISTEN R. ANGELOS
                                            Assistant Federal Defender


                                            /s/ Robert K. Hunt
                                            ROBERT K. HUNT
                                            Assistant Federal Defender




                                                2

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