USA v. Applebury et al

District of Alaska, akd-3:2017-cr-00121-58433

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BRYAN SCHRODER United States Attorney RETTA-RAE RANDALL Assistant U.S. Attorney Federal Building & U.S. Courthouse 222 West Seventh Avenue, #9, Room 253 Anchorage, Alaska 99513-7567 Phone: (907) 271-5071 Fax: (907) 271-1500 Email: Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA UNITED STATES OF AMERICA,) No. 3:17-cr-00121-TMB) Plaintiff,) MOTION FOR LEAVE TO FILE) OVER LENGTH BRIEF vs.)) (Filed on Shortened Time) JILL DIANE APPLEBURY,)) Defendant.)) COMES NOW United States of America, by and through undersigned counsel, and requests permission to file a sentencing memorandum in excess of twenty-five pages. In addition to discussing the offense conduct, the legal issues pertaining to loss, and restitution, USSG factors as well as acceptance of responsibility need to be analyzed. Sentencing factors pursuant to 18 U.S.C. § 3553 also need to be discussed. Counsel for Defendant has stated that he does not oppose this request. This motion is filed on shortened time because the sentencing memoranda for Defendant is due Tuesday, March 19, 2019, for imposition of sentence currently scheduled for April 1, 2019. RESPECTFULLY SUBMITTED this 15th day of March, 2019, at Anchorage, Alaska. BRYAN SCHRODER United States Attorney s/ Retta-Rae Randall RETTA-RAE RANDALL Assistant U.S. Attorney CERTIFICATE OF SERVICE I hereby certify that on March 15, 2019, a true and correct copy of the foregoing was served electronically on the following: James A. Wendt, Esq. s/ Retta-Rae Randall Office of the U.S. Attorney U.S. v. Jill Diane Applebury 2 3:17-cr-00121-TMB-DMS