Joint MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (Re: 38 Scheduling Order,,… — USA v. Thomas (Dkt. 40)

Record facts

U.S. District Court for the Northern District of Oklahoma · No. 4:21-cr-00239-GKF · Doc. 40 · 2021-08-31 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF OKLAHOMA 
 
UNITED STATES OF AMERICA, 
 
 
) 
 
 
 
 
 
 
 
) 
 
 
 
Plaintiff, 
 
 
) 
 
 
 
 
 
 
 
) 
-vs- 
 
 
 
 
 
 
) 
Case No.: 21-cr-00239-GKF 
 
 
 
 
 
 
 
) 
ALETA NECOLE THOMAS, 
 
 
 
) 
PEPPER JONES, 
 
 
 
 
) 
KATRINA WEST,  
 
 
 
 
) 
 
 
 
 
 
 
 
) 
 
 
 
Defendants. 
 
 
) 
 
JOINT MOTION TO CONTINUE DEADLINES AND NEW SCHEDULING ORDER 
 
 
COME NOW all parties to this action, by and through counsel of record, and respectfully move 
this Court to continue all remaining court dates and deadlines currently set, upon the following grounds, 
to-wit:  
 
1. 
 Counsel for the Government, Kristin F. Harrington, joins this request for a continuance 
and entry of a new scheduling order.   
 
2. 
Defense counsel who join in this request and are requesting a continuance of all dates 
for a period of ninety (90) days are as follows:  
 
 
Keith A. Ward for Defendant Aleta Thomas (1) 
 
 
Stephen G. Layman for Defendant Pepper Jones (2) 
 
 
G. Steven Stidham for Defendant Katrina West (3)  
3.  
The original Indictment in this matter was filed on May 20, 2021, charging only Ms. 
Thomas in the Indictment (Dkt. #2).  
4. 
On July 20, 2021, the Government presented a  Superseding Indictment as to Defendants 
Case 4:21-cr-00239-GKF     Document 40 Filed in USDC ND/OK on 08/31/21     Page 1 of 3

Thomas (1), Jones (2), and West (3). 
5. 
On July 28, 2021, the court entered and amended Scheduling Order requiring Motions 
to be due by August 11, 2021, Responses by August 25, 2021, Pretrial Conference set for September 8, 
2021, Jury Instructions, Voir Dire, and Trial Briefs due September 13, 2021; and the Jury Trial to be set 
September 20, 2021 (Dkt. #38).   
 
6. 
Counsel listed above are respectfully requesting the Court enter a new Scheduling Order.  
 
7. 
The Government’s discovery is voluminous. The discovery contains approximately 10 
gigabits of information. In total, the Government’s production contains thousands of individual items 
that must be reviewed.  
 
8. 
The moving parties submit that continuing the trial of this case to the Court’s December 
2021 trial docket would allow them reasonable time necessary for effective trial preparation with regard 
to the discovery materials that have been produced to date. Such also allows reasonable time for 
continued plea negotiations. Therefore, the ends of justice would be served by moving the trial date and 
all related dates of this case to the Court’s December 2021 docket.  
 
9.  
Defendants joining in this Motion for Continuance intend to file waivers of speedy trial 
forthwith.  
 
WHEREFORE, premises considered, the moving Defendants herein ask the Court to find that 
continuing the trial of this matter from September 20, 2021 to December 2021 serves the best interests 
of justice by affording them reasonable time for effective preparation, that the period of time occasioned 
by such continuance outweighs the interest of the public in a speedy trial, and that the dates between 
September 20, 2021, and December 13, 2021, are therefore excluded from computation under the Speedy 
Trial Act, 18 U.S.C. §3161.  
Case 4:21-cr-00239-GKF     Document 40 Filed in USDC ND/OK on 08/31/21     Page 2 of 3

Respectfully submitted, 
 
/s/ Stephen G. Layman  
 
 
Stephen G. Layman, OBA No. 22423 
LAYMAN & MORRIS, PLLC 
401 South Boston Avenue | Suite 500 
Tulsa, Oklahoma 74103 
(918) 933-4353 Telephone 
(918) 699-0353 Facsimile 
steve@laymanmorris.com 
COUNSEL OF RECORD FOR DEFENDANT 
PEPPER JONES 
 
 
 
CERTIFICATE OF SERVICE 
 
 
I certify that on the 31st  day of August, 2021, a true-and-correct copy of the foregoing was served 
upon: 
 
 
All Counsel of Record  
 
By electronic transmission to the Clerk of Court using the ECF System for filing and transmittal of a 
Notice of Electronic Filing to all ECF registrant(s) above. 
 
 
s/ Stephen G. Layman  
 
 
 
 
 
Case 4:21-cr-00239-GKF     Document 40 Filed in USDC ND/OK on 08/31/21     Page 3 of 3

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