Motion to Continue — United States v. Brown (Dkt. 45, W.D.N.C.)

Summary

A motion to continue filed for defendant Tijema Brown by counsel Kimberly Y. Best in United States of America v. Tijema Brown, No. 3:25CR00106-KDB-SCR, in the U.S. District Court for the Western District of North Carolina, filed August 1, 2025. The motion asks to continue the trial set for September 2, 2025. It states that Brown was indicted on May 22, 2025 on charges under 18 USC §§1343 and 1349 and appeared on May 23, 2025, that no other counsel has been appointed or hired, and that counsel has received discovery but not yet reviewed it with Ms. Brown. It states that AUSA Warren does not object to the continuance.

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Full text

IN THE UNITED STATES DISTRICT COURT
                FOR THE WESTERN DISTRICT OF NORTH CAROLINA
                             CHARLOTTE DIVISION


UNITED STATES OF AMERICA                     )
                                             )
              v.                             )             MOTION TO CONTINUE
                                             )              3:25CR00106-KDB-SCR
TIJEMA BROWN                                 )
 Defendant.                                  )
                                             )
       NOW COMES the Defendant, by and through counsel Kimberly Y. Best, and hereby
moves this court for a Continuance in the above referenced matter scheduled for trial on
September 2, 2025, and in support of said Motion avers:

   1.) Defendant was indicted on May 22, 2025, and charged with violations of 18 USC §§1343
       and 1349 and appeared for her initial appearance on Friday, May 23, 2025.


   2.) Defense Counsel was present for Ms. Brown’s initial appearance, and it was anticipated
       that another counsel would be hired and/or appointed to represent Ms. Brown prior to this
       date. Likewise, Counsel has been advised there is additional discovery for which a hard
       drive is required. Counsel is scheduled to drop one off next week.

   3.) To date, other counsel has not been appointed to represent the Defendant nor hired, and
       the undersigned continues to serve as counsel.

   4.) Counsel has received discovery in this matter but has yet to review said discovery with
       Ms. Brown and discuss viable solutions.

   5.) Counsel has exchanged emails with AUSA Warren regarding this continuance he does
       not object to this Motion.

   6.) Counsel wishes to continue the matter to provide for an opportunity to review the
       discovery in the matter and discuss it with Ms. Tijema Brown.

   7.) This Motion is not for dilatory purposes and for good cause.

    WHEREFORE, Defendant Tijema Brown requests this Court grant the Motion to Continue
the trial matter currently scheduled for the trial calendar on Monday, September 2, 2025.

Submitted on this 31st day of July 2025.

                                                           s/Kimberly Y. Best_______
                                                           Kimberly Y. Best
                                                           The Best Law Firm, PLLC
                                                           212 N. McDowell St., Suite 208
                                                           Charlotte, NC 28204
                                                           thebestlawfirmpllc@gmail.com
                                                           980-553-0139
    Case 3:25-cr-00106-KDB-SCR             Document 45      Filed 08/01/25     Page 1 of 2

                               CERTIFICATE OF SERVICE

     I, Kimberly Y. Best, hereby certify that I have served a copy of the foregoing MOTION
TO CONTINUE upon the following parties via ECF.

Matthew Warren, Esq.
Assistant United States Attorney
227 W. Trade St., Suite 1650
Charlotte, NC 28202


Submitted this 31ST day of July,2025.




                                                 /s/Kimberly Y. Best
                                                 Kimberly Y. Best, Esq. 24932
                                                 212 N. McDowell St., Suite 208
                                                 Charlotte, NC 28204
                                                 thebestlawfirmpllc@gmail.com
                                                 980-553-0139




    Case 3:25-cr-00106-KDB-SCR          Document 45      Filed 08/01/25    Page 2 of 2

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