Opinion
Case No. 3:09-CR-00240-28
12-10-2012
UNITED STATES OF AMERICA, Plaintiff, v. THOMAS L. CAREY, JR., Defendant.
MOTION FOR IMMEDIATE SENTENCING
Comes your defendant Thomas L. Carey, Jr., by and through court-appointed counsel, and moves the Court for sentencing to occur on the same day as the entry of plea offer in this cause currently scheduled for December 11, 2012, at 11:00 a.m. The plea agreement in this cause is pursuant to Rule 11(c)(1)(C) Federal Rules of Criminal Procedure and the agreed upon sentence is 180 months as well as other recommendations subject to Court approval. Court-appointed counsel for the defendant suggests it is in the best interest of judicial economy for sentencing to occur after the conclusion of entry of the guilty plea since he is traveling over two hours to appear in court and a subsequent sentencing hearing would require more billable time for court-appointed counsel.
That court-appointed counsel has consulted with Assistant United States Attorney Sunny Koshy who is in agreement with this motion.
Respectfully submitted, this the 10th day of December, 2012.
_____________
Matthew M. Maddox, 14,400
19695 East Main Street
P.O. Box 827
Huntingdon, TN 38344
(731) 986-4896
maddoxfedfile@bellsouth.net
Court-appointed counsel for
Thomas L. Carey, Jr.
CERTIFICATE OF SERVICE
I, Matthew M. Maddox, one of the attorneys for the defendant, do hereby certify that I have served a copy of the foregoing Motion for Immediate Sentencing upon Sunny Koshy, Assistant U.S. Attorney, 110 9th Avenue South, Suite A-961, Nashville, Tennessee 37203, by electronic means through the Court's ECF System, this the 10th day of December, 2012.
_____________
Matthew M. Maddox, 14,400
19695 East Main Street
P.O. Box 827
Huntingdon, TN 38344
(731) 986-4896
maddoxfedfile@bellsouth.net
Court-appointed counsel for
Thomas L. Carey, Jr.