MOTION for Extension of Time to Respond to Motion (Re: 150 MOTION for an Order Recognizing… — USA v. Thomas (Dkt. 152)

Record facts

U.S. District Court for the Northern District of Oklahoma · No. 4:21-cr-00239-GKF · Doc. 152 · 2022-09-20 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OKLAHOMA
TULSA DIVISION
UNITED STATES OF AMERICA	
	
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4:21-CR-00239-GKF-1
	
	
	
	
	
	
	
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ALETA NECOLE THOMAS	
	
	
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MOTION FOR EXTENSION OF TIME
 Ms. ALETA NECOLE THOMAS, by and through her attorney, Mr. 
MURDOCH WALKER, II, ESQ., respectfully moves this Court to grant an 
extension of no less than seven (7) days to file a response to the Government’s 
Motion for an Order Recognizing that Defendant has waived her Attorney-Client 
Privilege. Motion ECF No. 150. 
I. Relevant Procedural History 
On September 13, 2022 the Government filed a Motion for an Order 
Recognizing that Defendant has waived her Attorney-Client Privilege. Motion 
ECF No. 150
On September 13, 2022 this Court entered an order for undersigned 
counsel to file a response to the Motion for an Order Recognizing that Defendant 
has waived her Attorney-Client Privilege by September 20, 2022. Order, ECF 
No.151
Case 4:21-cr-00239-GKF     Document 152 Filed in USDC ND/OK on 09/20/22     Page 1 of 4

II. Factual Assertions 
Undersigned counsel has attempted to contact Ms. Thomas to discuss the 
Court’s order and to discuss a response to the Government’s motion, since the 
Government requested Ms. Thomas’ position by email, on August 31, 2022.   	

Ms. Thomas is currently being housed at the Federal Medical Center, 
Carswell located in Fort Worth, Texas.  
Furthermore, and since Thursday, September 15, 2022, specifically, and 
each day thereafter, the undersigned counsel has repeatedly contacted the 
Federal Medical Center, Carswell, to schedule a legal phone call to speak with 
Ms. Thomas.  Counsel has left repeated messages with staff members at the 
Federal Medical Center, Carswell stressing the urgency to speak with Ms. 
Thomas.  No calls or responses have been received from the Federal Medical 
Center, Carswell facility to date. 
III. Memorandum of Law 
Ms. Thomas respectfully submits that good cause exists for this Court to 
extend its deadline for a response to Government’s motion.  For reasons, as 
demonstrated herein above, Ms. Thomas respectfully requests that the Court 
ordered response to the Government’s Motion for an Order Recognizing that 
Defendant has waived her Attorney-Client Privilege be extended seven (7) days.

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Case 4:21-cr-00239-GKF     Document 152 Filed in USDC ND/OK on 09/20/22     Page 2 of 4

IV. Opposing Party’s Position 
The Government does not oppose this motion. 

V.	Conclusion 
 Ms. Thomas, based on the foregoing assertions and argument, prays 
that this Court continue the response deadline for no less than seven (7) days.  
	
Date: 	September 20, 2022
Respectfully submitted,	
	

s/ Murdoch Walker, II, Esq. 
Murdoch Walker, II, Esq.
Ga. Bar # 163417
mwalker@lowtherwalker.com 
Lowther | Walker LLC 
101 Marietta St., NW, Ste. 3325 
Atlanta, GA 30303
O 404.496.4052
www.lowtherwalker.com
Attorney for Aleta Necole Thomas 

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Case 4:21-cr-00239-GKF     Document 152 Filed in USDC ND/OK on 09/20/22     Page 3 of 4

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OKLAHOMA
TULSA DIVISION
UNITED STATES OF AMERICA	
	
)
	
	
	
	
	
	
	
)	

	
v.	
	
	
	
	
	
)	
4:21-CR-00239-GKF-1
	
	
	
	
	
	
	
)
ALETA NECOLE THOMAS	
	
	
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CERTIFICATE OF SERVICE
	
I certify that on September 20, 2022, I electronically filed the foregoing 
MOTION FOR EXTENSION OF TIME with the Clerk of the United States 
District Court for the Northern District of Oklahoma by way of the CM/ECF 
system, which automatically will serve this document on the attorneys of record 
for the parties in this case by electronic mail. 
	
Date: 	September 20, 2022	

Respectfully submitted,	
	

s/ Murdoch Walker, II, Esq. 
Murdoch Walker, II, Esq.
Ga. Bar # 163417
mwalker@lowtherwalker.com
Lowther | Walker LLC 
101 Marietta St., NW, Ste. 3325 
Atlanta, GA 30303
O 404.496.4052
www.lowtherwalker.com
Attorney for Aleta Necole Thomas 

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Case 4:21-cr-00239-GKF     Document 152 Filed in USDC ND/OK on 09/20/22     Page 4 of 4

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