`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`Brian T. Rafferty, Esq.
`Ga. Bar #311903
`Admitted Pro Hac Vice
`Rafferty Law, LLC
`1575 Johnson Road NE
`Atlanta, GA 30306
`912.658.0912
`brian@raffertylawfirm.com
`Attorney for Defendant Jeffrey King
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF ARIZONA
`
`
`Case No.: 2:24-CR-01040-ROS-2
`
`JOINT MOTION TO CONTINUE
`SENTENCING AND TO FILE
`OBJECTIONS OR
`CLARIFICATIONS TO THE PSR
`
`UNITED STATES OF AMERICA,
` Plaintiff,
`
`
`vs.
`
`
`JEFFREY KING, ET AL.,
` Defendants.
`
`
`Defendant Jeffrey King and the UNITED STATES OF AMERICA,
`pursuant to Fed. R. Crim. P. 32, respectfully move this Court to continue
`the sentencing hearing in this case from April 15, 2025, to a date after
`August 12, 2025, which is the current sentencing date for codefendant
`Alexandra Gehrke. The parties further move to extend the time to file any
`objections or clarifications to the Presentence Report (“PSR”) through July
`15, 2025.
`I. Relevant Procedural History
`On January 31, 2025, Defendant Jeffrey King entered a guilty plea to
`Count 1 of the Superseding Indictment. At the conclusion of the Rule 11
`
` - 1 -
`
`
`
`Case 2:24-cr-01040-ROS Document 142 Filed 03/29/25 Page 2 of 3
`
`
`
`hearing, the Court scheduled the sentencing hearing for Mr. King for April
`15, 2025. (ECF No. 138).
`II. Factual Assertions
`The case presents complex issues, and upon conferring with each other,
`the parties respectfully submit that they need additional time to respond to
`the presentence report and prepare for sentencing fully. The parties agree
`that they will be able to accomplish that preparation after August 12, 2025,
`the current sentencing date for Alexandra Gehrke, a codefendant in this
`case. The parties further request additional time to file any objections to
`the PSR through July 15, 2025. The parties will be available for sentencing
`that month.
`This is the first request to continue sentencing in this case.
`III. Memorandum of Law
`A “court must impose sentence without unnecessary delay.” Fed. R.
`Crim. P. 32(b)(1). However, a “court may, for good cause, change any time
`limits prescribed in [Fed. R. Crim. P. 32].” Fed. R. Crim. P. 32(b)(2).
`IV. Certificate of Conference
`The government joins in this motion.
`V. Conclusion
`Mr. King and the Government, based on the foregoing assertions and
`argument, pray that the Court continue the sentencing hearing in this case
`from April 15, 2025, to a date after August 12, 2025, which is the current
`sentencing date of Defendant Alexandra Gehrke. The parties further
`request additional time to file any objections or clarifications to the
`Presentence Report through July 15, 2025.
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
` - 2 -
`
`
`
`Case 2:24-cr-01040-ROS Document 142 Filed 03/29/25 Page 3 of 3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`Dated this 29th of March, 2025.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s Brian T. Rafferty, Esq.
`Brian T. Rafferty, Esq.
`
` - 3 -
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
