Motion to Continue Pretrial Conference by Andre Lee Gaines — USA v. Thomas et al. (Dkt. 119, N.D. Ga.)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 119 · 2021-05-07 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
 
FOR THE NORTHERN DISTRICT OF GEORGIA 
 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
 
) 
) 
v. 
 
 
 
 
)       CRIMINAL ACTION 
) 
NO. 1:20-CR-296-JPB-AJB 
ANDRE LEE GAINES 
 
) 
_______________________________________) 
 
MOTION TO CONTINUE PRETRIAL CONFERENCE 
 
 
COMES NOW, Defendant, ANDRE LEE GAINES, by and through 
undersigned counsel and files this motion to continue the pretrial conference 
currently scheduled for May 10, 2021.  For cause, Defendant shows the following: 
 
1) 
Defendant has been charged in an indictment with conspiracy, bank 
fraud, wire fraud, and money laundering.  He entered a not guilty plea.  A pretrial 
conference is scheduled for May 10, 2021.  
 
2) 
Undersigned counsel has another hearing scheduled for the same 
time as the pretrial conference.  In addition, the parties are discussing a possible 
resolution of the case.  If the case can be resolved, the pretrial conference will be 
unnecessary.  As a result, Defendant requests a two week continuance of the 
pretrial conference. 
 
3) 
The period from the filing of this motion through the pretrial 
conference is properly excluded from the speedy trial clock because the ends of 
Case 1:20-cr-00296-JPB-CMS     Document 119     Filed 05/07/21     Page 1 of 3

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justice served by the granting this extension of time outweigh the best interest of 
the public and the defendant in a speedy trial. 18 U.S.C. §3161(h)(7)(A). 
 
WHEREFORE, the defendant respectfully requests that the Court continue 
the pretrial conference for two weeks.  
 
Dated:  This 8th day of May, 2021. 
Respectfully submitted,  
 
 
 
 
 
 
S/BRIAN MENDELSOHN, Esq. 
 
 
 
 
 
STATE BAR NO. 502031 
 
 
 
 
 
ATTORNEY FOR ANDRE LEE GAINES 
 
FEDERAL DEFENDER PROGRAM, INC. 
Suite 1500, Centennial Tower 
101 Marietta Street, N.W. 
Atlanta, Georgia 30303 
(404) 688-7530 
Brian_Mendelsohn@fd.org 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 119     Filed 05/07/21     Page 2 of 3

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CERTIFICATE OF SERVICE 
 
I hereby certify that on May 8, 2021, I electronically filed this pleading with 
the Clerk of Court using the CM/ECF system which will automatically send email 
notification of such filing to the following attorneys of record: 
 
 
 
Tal Chaiken, Esq. 
 
 
 
Nathan Kitchens, Esq. 
 
 
 
Assistant United States Attorney 
 
 
 
 
600 Richard B. Russell Building 
 
 
 
 
75 Spring Street, S. W. 
 
 
 
 
 
Atlanta, Georgia  30335 
 
 
 
 
 
 
 
 
 
 
 
Dated:  This 8th day of May, 2021. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
s/BRIAN MENDELSOHN, Esq. 
 
  
 
 
 
 
 
ATTORNEY FOR ANDRE LEE GAINES 
 
 
 
 
 
STATE BAR NO. 502031 
Case 1:20-cr-00296-JPB-CMS     Document 119     Filed 05/07/21     Page 3 of 3

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