Opinion
2:21-cr-00306-GMN-NJK
11-28-2022
JASON M. FRIERSON United States Attorney Jim W. Fang Counsel for USA WALDO LAW, LLC. Jennifer M. Waldo Counsel for Emerald Wilson-Bey
JASON M. FRIERSON United States Attorney Jim W. Fang Counsel for USA
WALDO LAW, LLC. Jennifer M. Waldo Counsel for Emerald Wilson-Bey
STIPULATION AND ORDER TO CONTINUE CHANGE OF PLEA HEARING
IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson United States Attorney, through Jim. W. Fang, Assistant United States Attorney, counsel for the United States of America, and Jennifer M. Waldo counsel for Emerald Ruth Wilson-Bey that the Change of Plea hearing, currently scheduled for Tuesday, November 29, 2022 be vacated and continued to a date and time convenient to this court, but no sooner than forty-five (45) days from the current setting.
The Stipulation is entered into for the following reasons:
1. That the parties resolved this matter through pretrial plea negotiations and have submitted a fully-executed plea agreement to the Court for its consideration;
2. On November 2, 2022, an expedited change of plea hearing was set for December 6, 2022 at 11:00 a.m.;
3. That after the above date was set, counsel for Ms. Wilson-Bey was scheduled for surgery on December 6, 2022;
4. That based upon the stipulation of parties (ECF No.: 117), the change of plea Hearing was moved up to November 29, 2022;
5. That counsel now needs additional time to speak with Ms. Wilson-Bey regarding questions and/or concerns she has related to the plea agreement to ensure Ms. Wilson-Bey fully understands the plea agreement and the consequences of same;
6. That counsel for Ms. Wilson-Bey has spoken to government counsel and the government has no objection to continuing the change of plea hearing; and
7. This is the first request to continue the change of plea hearing.
STIPULATION AND ORDER TO CONTINUE CHANGE OF PLEA HEARING
FINDINGS OF FACT
1. That the parties resolved this matter through pretrial plea negotiations and have submitted a fully-executed plea agreement to the Court for its consideration;
2. On November 2, 2022, an expedited change of plea hearing was set for December 6, 2022 at 11:00 a.m.;
3. That after the above date was set, counsel for Ms. Wilson-Bey was scheduled for surgery on December 6, 2022;
4. That based upon the stipulation of parties (ECF No.: 117), the change of plea Hearing was moved up to November 29, 2022;
5. That counsel now needs additional time to speak with Ms. Wilson-Bey regarding questions and/or concerns she has related to the plea agreement to ensure Ms. Wilson-Bey fully understands the plea agreement and the consequences of same;
6. That counsel for Ms. Wilson-Bey has spoken to government counsel and the government has no objection to continuing the change of plea hearing; and
7. This is the first request to continue the change of plea hearing.
CONCLUSIONS OF LAW
The ends of justice served by granting said continuance outweigh the best interests of the public and the defense in a proceeding with the change of plea hearing as currently scheduled.
ORDER
IT IS THEREFORE ORDERED that the change of plea hearing currently scheduled for November 29, 2022 at 9:00 a.m., be vacated and continued to the 17th day of January, 2023, at the hour of 11:00 a.m.