First Motion to Continue Sentencing Hearing Scheduled for June 30, 2022 — USA v. Thomas et al. (Dkt. 489, N.D. Ga.)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 489 · 2022-06-09 · Docket on CourtListener

Full text

1 | P a g e  
BANKS WEAVER LLC | 100 Peachtree Street, NW, Suite 260 
Atlanta, Georgia 30303 
IN THE UNITED STATES DISTRICT COURT 
FOR THE NOTHERN DISTRICT OF GEORGIA  
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA      ) 
 
 
 
 
 
 
) 
INDICTMENT NO.   
v. 
 
 
 
 
 
) 
1:20-cr-00296-JPB-CMS-9 
 
 
 
 
 
 
) 
  
AMANDA CHRISTIAN,  
  
) 
  
 
 
 
 
 
 
) 
 
 
Defendant.  
 
 
) 
 
 
UNOPPOSED MOTION TO CONTINUE  
SENTENCING HEARING SCHEDULED FOR JUNE 30, 2022 
 
COMES NOW Defendant Amanda Christian in the above-styled criminal 
matter, by and through her counsel, Gabe Banks, and hereby files this 
“Unopposed Motion to Continue the Sentencing Hearing Scheduled for June 30, 
2022.”  In support of her motion, Ms. Christian would show this Honorable Court 
the following:  
1. 
On July 13, 2021, a Northern District of Georgia Grand Jury returned a 
first superseding, multi-count indictment charging Ms. Christian (and others) 
with, among other things, bank and wire fraud.  See Docket Entry No. 135.  
2. 
Ms. Christian a Northern District of Georgia Grand Jury returned a second 
superseding, multi-count indictment charging Ms. Christian (and others) with, 
among other things, bank and wire fraud.  See Docket Entry No. 290.  On August 
Case 1:20-cr-00296-JPB-CMS     Document 489     Filed 06/09/22     Page 1 of 5

2 | P a g e  
BANKS WEAVER LLC | 100 Peachtree Street, NW, Suite 260 
Atlanta, Georgia 30303 
11, 2021, a summons was issued for her to appear on August 25, 2021 for 
arraignment (see Docket Entry No. 334), but on August 23, 2021, undersigned 
counsel filed a waiver of personal appearance on her behalf and entered a plea of 
not guilty to the second superseding indictment.  See Docket Entry No. 355.       
3. 
 
On March 23, 2022, appeared before this Honorable Court and entered a 
plea of guilty to Count 34 of the Indictment.  See Docket Entry No. 447.  This 
court scheduled her sentencing hearing for June 30, 2022 at 2:00 pm.  Id. 
4. 
On May 25, 2022, the parties received a copy of the Presentence Report 
(“PSR”).  The parties are required to lodge objections to the PSR on June 9, 2022.  
From his initial review of the PSR in this case, undersigned counsel anticipates 
that he will have a number of objections to said PSR; undersigned counsel has 
requested additional time to file said objections to the same.  Importantly, 
undersigned counsel has been in a bench trial this week in Fulton County, 
Georgia.  As such, undersigned counsel will not be able to timely respond to the 
PSR.   
5. 
Additionally, there are several other matters undersigned counsel is 
required to handle in June 2022, including depositions and hearings in both state 
and federal courts.  As such, undersigned counsel will not be in a position to 
Case 1:20-cr-00296-JPB-CMS     Document 489     Filed 06/09/22     Page 2 of 5

3 | P a g e  
BANKS WEAVER LLC | 100 Peachtree Street, NW, Suite 260 
Atlanta, Georgia 30303 
prepare a sentencing memorandum which may include a departure and/or 
deviation from the guidelines ten (10) days before the sentencing hearing as 
required by this Court’s standard practice.   
6. 
 
Accordingly, undersigned counsel respectfully requests that this 
Honorable Court continue the Sentencing Hearing in this matter.  Undersigned 
counsel is requesting a 45-day reset.   
7. 
 
Undersigned counsel has discussed the filing of this motion with counsel 
for the government and is authorized to state that the government is not opposed 
to the granting of this motion.   
 
 
[signature page to follow] 
 
 
 
 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 489     Filed 06/09/22     Page 3 of 5

4 | P a g e  
BANKS WEAVER LLC | 100 Peachtree Street, NW, Suite 260 
Atlanta, Georgia 30303 
WHEREFORE, for the above stated reasons, Ms. Christian respectfully 
requests that this Honorable Court continue the Sentencing Hearing.  
Respectfully submitted this 9th day of June, 2022. 
BANKS WEAVER LLC 
/s/ Gabe Banks  
 
 
 
 
 
 
_________________________________ 
 
 
 
 
 
 
Gabe Banks 
 
 
 
 
 
 
Georgia Bar No. 721945 
 
 
 
 
 
 
Attorney for Defendant Amanda Christian 
100 Peachtree Street, NW, Suite 260 
Atlanta, Georgia 30303 
 
 
 
404-891-9280 (Phone) 
404-891-9283 (Fax) 
gabe@banksweaver.com  
Case 1:20-cr-00296-JPB-CMS     Document 489     Filed 06/09/22     Page 4 of 5

5 | P a g e  
BANKS WEAVER LLC | 100 Peachtree Street, NW, Suite 260 
Atlanta, Georgia 30303 
IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA      ) 
 
 
 
 
 
 
) 
INDICTMENT NO.   
v. 
 
 
 
 
 
) 
1:20-cr-00296-JPB-CMS-9 
 
 
 
 
 
 
) 
 
 
 
 
 
 
 
) 
AMANDA CHRISTIAN, 
 
) 
 
 
 
 
 
 
) 
 
 
 
Defendant.  
) 
 
 
CERTIFICATE OF SERVICE 
 
 
This is to certify that a copy of the foregoing document was formatted in 
Times New Roman 14 pt., in accordance with Local Rule 5.1B, and was 
electronically filed this day with the Clerk of Court using the CM/ECF system 
which will automatically send email notification of such filing to all parties of 
record.  
Dated: June 9, 2022. 
BANKS WEAVER LLC 
/s/ Gabe Banks  
 
 
 
 
 
 
_________________________________ 
 
 
 
 
 
 
Gabe Banks 
 
 
 
 
 
 
Georgia Bar No. 721945 
 
 
 
 
 
 
Attorney for Defendant Amanda Christian 
100 Peachtree Street, NW, Suite 260 
Atlanta, Georgia 30303 
 
 
 
404-891-9280 (Phone) 
404-891-9283 (Fax) 
gabe@banksweaver.com 
Case 1:20-cr-00296-JPB-CMS     Document 489     Filed 06/09/22     Page 5 of 5

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