Court filing
First Motion for Extension of Time To Self-Surrender — USA v. Thomas et al. (Dkt. 615, N.D. Ga.)
Filed January 3, 2023 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 | 2023-01-03 |
U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 615 · 2023-01-03 · 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 EXTEND TIME TO REPORT TO DESIGNATED BUREAU OF PRISONS FACILITY DUE TO HER SISTER’S SERIOUS MEDICAL CONDITION COMES NOW Defendant Amanda Christian, by and through her counsel, Gabe Banks, and hereby files this “Unopposed Motion to Extend Time to Report to Designated Bureau of Prisons Facility Due to Her Sister’s Serious Medical Condition.” In support of her motion, Ms. Christian would show this Honorable Court as follows: 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. Ms. Christian was granted a bond and remained on pretrial release prior to sentencing. Case 1:20-cr-00296-JPB-CMS Document 615 Filed 01/03/23 Page 1 of 5 2 | P a g e BANKS WEAVER LLC ׀ 100 Peachtree Street, NW, Suite 260 Atlanta, Georgia 30303 2. On March 23, 2022, Ms. Christian appeared before this Court and entered a plea of guilty to Count 34 of the Second Superseding Indictment. See Docket Entry No. 447. 3. On September 13, 2022, Ms. Christian appeared before this Court for her sentencing hearing, at the conclusion of which Ms. Christian was sentenced to 41- month custodial sentence to be served at a facility designated by the Bureau of Prisons. See Docket Entry No. 569. 4. Pursuant to her request at her sentencing hearing, this Court did not take her into custody. Instead, because she had been compliant with the terms and conditions of her pretrial release, this Court allowed Ms. Christian to remain on release, but instructed her to self-surrender to a designated facility by the Bureau of Prisons when notified. See Docket Entry No. 568-569. 5. To date, the Bureau of Prisons has not designated a facility to which Ms. Christian is required to self-surrender. As such, Ms. Christian has remained on release and continues to await any such designation and notification. Case 1:20-cr-00296-JPB-CMS Document 615 Filed 01/03/23 Page 2 of 5 3 | P a g e BANKS WEAVER LLC ׀ 100 Peachtree Street, NW, Suite 260 Atlanta, Georgia 30303 6. Unfortunately, in October 2022, Ms. Christian’s sister was diagnosed1 with a serious (and potentially terminal) medical condition and is now required to undergo various medical procedures for said condition. At this time, Ms. Christian is the only person who can transport her sister to these medical procedurals which are scheduled to last through February 2023. 7. After her medical procedures are completed in February 2023, Ms. Christian’s sister has to undergo more testing to determine whether any additional treatment is required. 8. Importantly, on March 13, 2023, Ms. Christian’s nephews will return from their out-of-state seasonal jobs, at which time they will be able to transport their mother to any future medical procedures after they return home. 9. Accordingly, Ms. Christian is requesting that this Court extend the time for Ms. Christian to self-surrender to a designated facility by the Bureau of Prisons until 1 To protect her sister’s privacy, her sister’s medical records are not attached to this motion but were provided to counsel for the government. The medical records confirm the diagnosis of a serious medical condition and also reflect the schedule for her sister’s ongoing treatment. Of course, in the event that this Court needs to review the supporting documentation, undersigned counsel would be happy to amend this motion upon any such request. Case 1:20-cr-00296-JPB-CMS Document 615 Filed 01/03/23 Page 3 of 5 4 | P a g e BANKS WEAVER LLC ׀ 100 Peachtree Street, NW, Suite 260 Atlanta, Georgia 30303 after March 13, 2023. This will ensure that Ms. Christian will be able to take her sister to any medical appointments until her sister’s sons return home from their out- of-state seasonal employment. 10. 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. WHEREFORE, Ms. Christian respectfully requests that this Court enter an Order extending her time to self-surrender to a designated facility until after March 13, 2023. Dated: January 3, 2023. BANKS WEAVER, LLC /s/ Gabe Banks ___________________________________ Gabe Banks Georgia Bar No.: 721945 Tennessee Bar No. 021377 Attorney for Defendant Amanda Christian 100 Peachtree Street, NW Suite 260 Atlanta, GA 30303 gabe@banksweaver.com 404.891.9280 (ofc) 404.891.9283 (fax) Case 1:20-cr-00296-JPB-CMS Document 615 Filed 01/03/23 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: January 3, 2023. BANKS WEAVER, LLC /s/ Gabe Banks _____________________________ Gabe Banks Georgia Bar No.: 721945 Tennessee Bar No. 021377 Attorney for Amanda Christian 100 Peachtree Street, NW, Suite 260 Atlanta, GA 30303 gabe@banksweaver.com 404.891.9280 (ofc) | 404.891.9283 (fax) Case 1:20-cr-00296-JPB-CMS Document 615 Filed 01/03/23 Page 5 of 5
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