Court filing
Motion to Continue August 24 Sentencing Hearing by Amanda Christian — USA v. Thomas et al. (Dkt. 526, N.D. Ga.)
Filed August 15, 2022 in USA v. Thomas et al.; one of 41 filings from this case.
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2022-08-15 |
U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 526 · 2022-08-15 · 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 NORTHERN 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 AUGUST 24, 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 August 24, 2022,” requesting that the Court continue the sentencing hearing in this case for two (2) weeks. 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. Case 1:20-cr-00296-JPB-CMS Document 526 Filed 08/15/22 Page 1 of 5 2 | P a g e BANKS WEAVER LLC | 100 Peachtree Street, NW, Suite 260 Atlanta, Georgia 30303 2. 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 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”), to which objections were filed. On August 11, 2022, the parties received a copy of the Final PSR in this case which reflect that there are several outstanding issues that will need to be resolved by the Court at Ms. Christian’s sentencing hearing. Case 1:20-cr-00296-JPB-CMS Document 526 Filed 08/15/22 Page 2 of 5 3 | P a g e BANKS WEAVER LLC | 100 Peachtree Street, NW, Suite 260 Atlanta, Georgia 30303 5. Recently, undersigned counsel finished extensive trial preparations for a complex criminal trial that was scheduled for today; that case will ultimately resolve in a guilty plea which that court will eventually schedule. See United States v. Wilkins, Indictment No. 1:21-cr-00103. In light of the extensive trial preparation in that case, undersigned counsel has been unable to adequately prepare a Sentencing Memorandum in Ms. Christian’s case. Importantly, pursuant to this Court’s Order, any Sentencing Memorandum that contemplates a variance must be filed ten (10) days before said sentencing hearing. 6. Accordingly, undersigned counsel respectfully requests that this Honorable Court continue the Sentencing Hearing in this matter. Undersigned counsel is requesting a 2-week continuance. This additional two (2) weeks will afford undersigned counsel the additional time needed to timely prepare and file the Sentencing Memorandum in Ms. Christian’s case. 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. Case 1:20-cr-00296-JPB-CMS Document 526 Filed 08/15/22 Page 3 of 5 4 | P a g e BANKS WEAVER LLC | 100 Peachtree Street, NW, Suite 260 Atlanta, Georgia 30303 8. This motion is not being offered for the purposes of delay or to frustrate the administration of justice and/or this Honorable Court’s calendar. Rather, this motion is being offered to afford undersigned counsel adequate time to timely prepare and file the appropriate Sentencing Memorandum in Ms. Christian’s case for the Court’s consideration. WHEREFORE, for the above stated reasons, Ms. Christian respectfully requests that this Honorable Court continue the Sentencing Hearing. Respectfully submitted on August 15, 2022. BANKS WEAVER, LLC /s/ Gabe Banks _____________________________ Gabe Banks Georgia Bar No.: 721945 Tennessee Bar No. 021377 Counsel For Amanda Christian 100 Peachtree Street, NW Suite 260 Atlanta, GA 30303 404.891.9280 (ofc.) 404.891.9283 (fax) gabe@banksweaver.com Case 1:20-cr-00296-JPB-CMS Document 526 Filed 08/15/22 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. Respectfully submitted on August 15, 2022. BANKS WEAVER, LLC /s/ Gabe Banks _____________________________ Gabe Banks Georgia Bar No.: 721945 Tennessee Bar No. 021377 100 Peachtree Street, NW, Suite 260 Counsel For Amanda Christian Atlanta, GA 30303 404.891.9280 (ofc) 404.891.9283 (fax) gabe@banksweaver.com Case 1:20-cr-00296-JPB-CMS Document 526 Filed 08/15/22 Page 5 of 5
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- gov.uscourts.gand.292218.526.0.pdf
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