Motion to Extend Deadline to File Sentencing Memoranda — No. 1:21-cr-00284 (Dkt. 13, D.D.C.)

Summary

Motion to extend deadline to file sentencing memoranda in the U.S. District Court for the District of Columbia, United States v. James Bell, case 1:21-cr-00284, Document 13, filed November 23, 2021. Through counsel Brandi Harden, Bell asks to extend his deadline by twenty-four hours, from November 23, 2021 to November 24, 2021. Counsel states that the final pre-sentence report arrived on the due date and that Bell wants to respond to the Small Business Administration's statement of restitution and to the government's arguments. Sentencing is listed for Dec. 3, 2021.

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              Case 1:21-cr-00284-JDB Document 13 Filed 11/23/21 Page 1 of 3




                                 UNITED STATES DISTRICT COURT
                                 FOR THE DISTRICT OF COLUMBIA


UNITED STATES OF AMERICA                  :
                                          :
                                          :
      v.                                  :                     No. 21-CR-284 (JDB)
                                          :
                                          :                     Sentencing Dec. 3, 2021
JAMES BELL                                :
      Defendant.                          :
__________________________________________:


         MOTION TO EXTEND DEADLINE TO FILE SENTENCING MEMORANDA

           James Bell through counsel, respectfully moves this Court to extend the deadline for

filing his Sentencing Memoranda by twenty-four hours, from November 23, 2021, to November

24, 2021.

           In support of the motion counsel states the following:

      1. Counsel received the final 1 pre-sentence report on November 23, 2021, the same date that

           Mr. Bell’s sentencing memorandum is due.

      2. The government has not yet filed its’ sentencing memoranda, and Mr. Bell would request

           an opportunity to respond to the Small Business Administration’s statement of restitution,

           see PSR ¶65, and arguments made by the government, in his initial sentencing

           submission.

      3. There is no prejudice to the government by enlarging the time for Mr. Bell to submit his

           sentencing submission by 24 hours.

           WHEREFORE, Mr. Bell respectfully requests that this Court grant his Motion to Extend

Deadline to File Sentencing Memoranda.


1
    Counsel received the draft PSR on September 1, 2021.
Case 1:21-cr-00284-JDB Document 13 Filed 11/23/21 Page 2 of 3




                                 Respectfully submitted,

                                 /s/ Brandi Harden
                                 ____________________
                                 Brandi Harden
                                 Bar No. 470706
                                 Counsel for James Kyle Bell
                                 Harden|Pinckney, PLLC
                                 400 7th Street Suite 604
                                 Washington, DC 20004
                                 bharden@hardenpinckney.com
         Case 1:21-cr-00284-JDB Document 13 Filed 11/23/21 Page 3 of 3




                               CERTIFICATE OF SERVICE

       I hereby certify that on November 23, 2021, I caused a copy of the foregoing motion to

be served on counsel of record via ECF.


                                                   /s/ Brandi Harden
                                                   _______________________________
                                                   Brandi Harden, Esq.


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