MOTION TO CONTINUE SURRENDER DATE
Defendant Jasiel F. Correia, II, respectfully renews his request that this Court stay his
surrender date pending this its resolution—and if necessary, the First Circuit’s resolution—of his
Motion for Continued Release Pending Appeal [D.E. 328].

The government opposes this request.

Mr. Correia incorporates herein by reference his previously filed motions to continue his
surrender date. D.E. 347, 383, 388, 397.

On March 3, 2022, this Court continued Mr. Correia’s surrender date to April 5, 2022.
D.E. 400.

On March 7, 2022, this Court sentenced Mr. Correia’s co-defendant, Genoveva Andrade,
to time served, 12 month’s supervised release, and a $50,000 fine, consistent with the joint
recommendation of the prosecution and her defense counsel. D.E. 407.

On March 30, 2022, Mr. Correia filed his appeal brief in the First Circuit. See United
States v. Correia, No. 21-1823 (1st Cir.). A copy of Mr. Correia’s brief is attached as Exhibit A.
It raises a number of “substantial question[s],” and if the Appeals Court decides one or more of
them “favorably to [Mr. Correia], that decision is likely to result in reversal or an order for a new
trial on all counts on which imprisonment has been imposed.” United States v. Bayko, 774 F.2d
516, 522 (1st Cir. 1985).

Case 1:18-cr-10364-DPW Document 421 Filed 04/01/22 Page 1 of 2
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Because Mr. Correia poses neither a flight risk nor any danger to the community, as this
Court has acknowledged by permitting him to remain out on bail before trial and to self-report
after sentencing, see United States v. Zimny, 857 F.3d 97, 99 (1st Cir. 2017), continued release
during his appeal would be appropriate pursuant to 18 U.S.C. § 3143.

Accordingly, at this time, Mr. Correia respectfully renews his suggestion that it would be
most efficient to stay his surrender pending final resolution of whether he will be permitted to
remain on release during his appeal.