United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 355: Hockridge's conditional motion for a staggered sentence (2025-11-20)

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Defendant Stephanie Hockridge's Opposed Conditional Motion for a Staggered Sentence in United States v. Reis and Hockridge, Case No. 4:24-cr-00287-O, Document 355, filed November 20, 2025, in the U.S. District Court for the Northern District of Texas, Fort Worth Division. The motion asks that, if the Court imposes a custodial sentence, Hockridge serve it staggered with that of her husband and codefendant Nathan Reis, for the sake of an infant son. It cites Fifth Circuit authority on deferring a federal sentence and decisions of other courts granting staggered sentences. The motion states that counsel for Reis does not oppose the relief and that the Government opposes it. Alternatively, it asks the Court to defer its decision until after Reis is sentenced.

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“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 355: Hockridge's conditional motion for a staggered sentence (2025-11-20).” Original at storage.courtlistener.com. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/united-states-v-reis-and-hockridge-n-d-tex-no-4-24-cr-00287-o-doc-355-9b5df0bd38/, SHA-256 4dc464aad5cef39709485fc8c94ebfaf4bfdda36691dadb8f9a1308e95e85307.

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Case 4:24-cr-00287-O Document 355 Filed 11/20/25 Page 1 of 5 PageID 8784

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

UNITED STATES OF AMERICA, §
§
Plaintiff, §
§
v. § Case No. 4:24 CR-00287-O
§
STEPHANIE HOCKRIDGE, a/k/a § (02)
STEPHANIE REIS, §
§
Defendants. §

DEFENDANT STEPHANIE HOCKRIDGE’S OPPOSED
CONDITIONAL MOTION FOR A STAGGERED SENTENCE
Defendant Stephanie Hockridge, by and through undersigned counsel, hereby

conditionally moves that, in the event the Court imposes a custodial sentence upon her, she be

granted a sentence that is staggered with that of her husband and codefendant Nathan Reis, for the

sake of their infant son W.R. In support of this Motion, Ms. Hockridge respectfully states:

1. In her Sentencing Memorandum (Doc. #304), Ms. Hockridge has sought a non-

custodial sentence in light of her objections to the Presentence Investigation Report and other

factors she contends warrant a downward variance or departure from the Sentencing Guidelines

range.

2. In the event, however, that the Court is unpersuaded by Ms. Hockridge’s arguments

and elects to impose a custodial sentence, Ms. Hockridge respectfully requests that the Court allow

Ms. Hockridge to serve any sentence staggered with that of her codefendant and husband Nathan

Reis, in order to avoid imposing any unnecessary hardship on their infant son.

3. Mere weeks before her indictment—and at a time when the Government had not

notified her that she was a target of its investigation—Ms. Hockridge gave birth to her and Mr.

Reis’s only child, W.R., who is now one year old. The letters submitted in support of Ms.

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Case 4:24-cr-00287-O Document 355 Filed 11/20/25 Page 2 of 5 PageID 8785

Hockridge for sentencing recount Ms. Hockridge’s devotion to W.R. and her close bond with him.

But if the Court imposes custodial sentences in her case and Mr. Reis’s case, her son will grow up

without either of his parents. The law does not require the Court to create such a harsh result.

4. This Court has “broad sentencing discretion” in assessing an appropriate custodial

sentence. See United States v. Nikonova, 480 F.3d 371, 376 (5th Cir. 2007). Pertinent here, the

Fifth Circuit has upheld the discretion of a district court “to defer serving [a] federal sentence”

when the circumstances make such deferral appropriate. Scott v. United States, 434 F.2d 11, 20

(5th Cir. 1970).1

5. Other courts across the country have repeatedly sought to “maintain parental

continuity” for minor children by “granting codefendant parents’ requests for staggered sentences”

in similar circumstances. United States v. Gary, 613 F.3d 706, 709 (7th Cir. 2010); see also, e.g.,

United States v. Marsh, No. 10-CR-0480, 2011 WL 5325410, at *24 (E.D.N.Y. Oct. 26, 2011)

(“Generally, in cases where both parents of a young child receive incarceratory sentences, the court

considers staggered service, where one parent completes the incarceratory portion of his or her

sentence before the other so that one parent is always available to care for the child.”); United

States v. Tartareanu, No. 2:12-CR-175-PPS, 2020 WL 5576730, at *5 (N.D. Ind. Sep. 17, 2020)

(“As part of my discretion in sentencing, and on account of the Tartareanus’ minor children, I

ordered their sentences to be staggered, so that both parents would not be simultaneously

incarcerated.”); United States v. Gasich, No. 2:14-cr-63, 2019 WL 4261614, at *1 (N.D. Ind. Sep.

9, 2019) (“When I sentenced Barbara Gasich and her husband . . . I staggered their sentence so that

1
Although the deferred sentence in Scott reflected the district court’s decision to effectively
extend the defendant’s imprisonment (by making his federal sentence commence after he finished
serving a sentence in state prison), Scott nonetheless stands for the proposition that a district court
need not order immediate remand to custody but may instead defer the commencement of the
period of confinement.

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Case 4:24-cr-00287-O Document 355 Filed 11/20/25 Page 3 of 5 PageID 8786

one parent could always be around for their young child who will live at home.”); Hussain v.

United States, No. 16-CR-6124, 2017 WL 4014503, at *3 (W.D.N.Y. Sept. 12, 2017) (“The

Petitioner asked the Court to stagger her and her husband’s sentences ‘to allow for child care for

the co-defendants’ four children.’ . . . The Court granted that request.”); United States v. English,

333 F. Supp. 3d 1311, 1315 (M.D. Ala. July 24, 2018) (“[T]he court granted his unopposed motion

for staggered sentences, in the event that his wife is sentenced in this case, so that one of the parents

may be released on supervision while the other is serving their sentence.”).

6. Where courts have denied codefendant parents’ requests for staggered sentences,

they have done so where the children were grown and where they were born prior to the conduct

for which the defendant was convicted. See, e.g., United States v. Roskovski, No. 2:19-cr-106-1,

2021 WL 3493404 (W.D. Pa. Aug. 9, 2021) (denying request for staggered sentence where

defendant sought to assist her “23-year-old son’s medical condition,” as he was “a fully

functioning adult with employment” and was not “unable to physically care for himself”); United

States v. Cruz, No. 2:10-CR-115-FTM-29, 2011 WL 4048965, at *1 (M.D. Fla. Sept. 13, 2011)

(“Defendants engaged in joint criminal activity while they had the children, and are not now

entitled as a matter of right to have the Court ameliorate the foreseeable consequences of their

criminal conduct.” (emphasis added)). Here, by contrast, W.R. was conceived after the conspiracy

alleged in the Superseding Indictment had concluded and was born before Ms. Hockridge was

indicted or notified she was a target.

7. The undersigned has conferred with counsel for Mr. Reis, who does not oppose the

relief sought herein, and with Ms. Hockridge’s pretrial services officer, who has indicated that she

has no concerns regarding Ms. Hockridge’s remaining on release during the pendency of her

appeal. The undersigned has also conferred with counsel for the Government, who has indicated

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Case 4:24-cr-00287-O Document 355 Filed 11/20/25 Page 4 of 5 PageID 8787

that the Government opposes the relief sought herein and intends to request that Ms. Hockridge be

remanded immediately after sentencing.

8. Despite the Government’s opposition, imposing staggered sentences would be an

unalloyed good. Ms. Hockridge is not a flight risk, particularly as she would not risk jeopardizing

her relationship with her son. Ms. Hockridge poses no threat to the community and was not

convicted of an offense involving violence or controlled substances. The alleged conspiracy for

which she was convicted ended years ago, and she has no other criminal record. She is no threat

to anyone. Ms. Hockridge would, of course, continue to observe any release conditions the Court

deems appropriate.

9. Staggering Ms. Hockridge’s sentence would not lessen the weight any potential

custodial sentence would carry for purposes of retribution, or for general or specific deterrence.

All it would do is avert a tragic collateral consequence: that a young boy whose parents love him

dearly would effectively be rendered an orphan. Ms. Hockridge humbly requests that the Court

spare her son from that.

10. If the Court is not inclined at present to grant a staggered sentence, Ms. Hockridge

alternatively requests that the Court defer its decision until after Mr. Reis is sentenced. 2

WHEREFORE Defendant Stephanie Hockridge humbly prays that the Court, if it is

inclined to impose custodial sentences upon both her and Mr. Reis, stagger the sentences such that

2
In the event that Ms. Hockridge is given a custodial sentence, she also intends to file an
alternative motion for release pending appeal under 18 U.S.C. § 3143. The Government has
indicated it intends to suppose Ms. Hockridge’s request for bail pending appeal. Deferring decision
on the instant motion until after Mr. Reis’s sentencing would therefore also provide the Court with
additional time to consider Ms. Hockridge’s forthcoming motion for bail pending appeal and the
Government’s response.

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Case 4:24-cr-00287-O Document 355 Filed 11/20/25 Page 5 of 5 PageID 8788

Ms. Hockridge would not be required to report for incarceration until the completion of Mr. Reis’s

sentence, and that the Court grant such other and further relief as it deems just and proper.

Dated: November 20, 2025 Respectfully submitted,

BRYAN CAVE LEIGHTON PAISNER LLP

/s/ Richard E. Finneran
RICHARD E. FINNERAN
MARK A. SRERE
KEVIN H. JENCO
211 North Broadway, Suite 3600
St. Louis, Missouri 63102
Tel: (314) 259-2000
Fax: (314) 259-2020
richard.finneran@bryancave.com
mark.srere@bryancave.com
kevin.jenco@bryancave.com

Attorneys for Defendant Stephanie Hockridge

CERTIFICATE OF SERVICE

I hereby certify that on this 20th day of November, 2025, a true and correct copy of the
foregoing document was served on all counsel of record by operation of the Court’s CM/ECF
system.
/s/ Richard E. Finneran
RICHARD E. FINNERAN

CERTIFICATE OF CONFERENCE

I hereby certify that on the 20th day of November, 2025, the undersigned conferred via
email with Assistant United States Attorney Matthew Weybrecht, who has indicated that the
Government opposes the relief sought herein.
/s/ Richard E. Finneran
RICHARD E. FINNERAN

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