This is the text of the document filed Wednesday by Jasiel Correia II's Defense Team:

 

Defendant Jasiel F. Correia, II, respectfully requests that the Court continue his surrender
date for 30 days, to January 3, 2022.

 

The government opposes this request.

As grounds for this motion, Mr. Correia states this his motion for continued release
during his appeal [D.E. 328] remains pending before this Court.

 

If the Court grants that motion,

the issue of a surrender date will be moot. If the Court denies that motion, however, an extension
of 30 days would permit orderly briefing of a motion for continued release in the First Circuit.1
In addition, the requested surrender extension would permit Mr. Correia to continue
providing critical assistance to his family’s small business through the busy holiday season.

This motion is Mr. Correia’s first request to continue his surrender date, and he
understands that, if this Court were to allow it, no further continuance could be expected.

1
 Mr. Correia cannot request release from the Court of Appeals until this Court has ruled on the
pending motion. See Fed. R. App. P. 9.
Case 1:18-cr-10364-DPW Document 347 Filed 11/17/21 Page 1 of 2