Unopposed Motion for Extension of Time — USA v. Thomas et al. (Dkt. 58, N.D. Ga.)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 58 · 2020-08-24 · Docket on CourtListener

Full text

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA, 
) 
) 
Plaintiff, 
) 
) 
vs. 
) 
CASE NO.: 1:20-CR-00296-JPB-AJB 
) 
BERN BENOIT, 
) 
) 
Defendant. 
) 
  
) 
 
UNOPPOSED MOTION FOR EXTENSION OF TIME WITHIN WHICH TO 
FILE PRETRIAL MOTIONS BRIEF IN SUPPORT THEREOF 
 
Defendant, (BERN BENOIT), by and through his undersigned counsel 
(ANTHONY O. EGBASE), hereby moves this Court for an order to continue the pretrial 
scheduling conference dated August 24, 2020. In support of this Motion, counsel avers as 
follows: 
1. 
 
Defendant was arraigned in this court on August 14, 2016 and plead not guilty to 
counts 7, 8, 9 and 13 through 16.  
2. 
 
Shortly before the arraignment, Defendant and counsel received voluminous 
discovery from the Government in this matter and Defendant and counsel are still in the 
process of reviewing such discovery. Defendant and his counsel need additional time to 
comply with the pretrial order. 
Case 1:20-cr-00296-JPB-CMS     Document 58     Filed 08/24/20     Page 1 of 5

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3. 
 
Undersigned counsel states herein that Defendant has expressly authorized the 
filing of this motion for an extension of time within which to file pretrial motions and to 
continue the pretrial conference and waives any speedy trial time restraints. 
 4 
 
On August 24, 2020, Defendant’s counsel conferred with Assistant United State 
Attorney (AUSA), Tal Cohen Chaiken regarding this motion and Ms. Chaiken indicated 
that the government will not oppose a 60-day continuance. 
  
WHEREFORE defendant (BERN BENOIT) and his counsel hereby request that 
this court continue the scheduling conference in this matter for at least 60 days, or to a 
date the court deems proper.  
Dated this 24TH day of August, 2020. 
 
Respectfully submitted, 
 
s/ Anthony O. Egbase 
 
ANTHONY O. EGBASE 
California Bar No. 181721 
Attorney for Defendant Bern Benoit 
 
A.O.E LAW & ASSOCIATES, INC 
350 S. Figueroa Street 
Suite 189 
Los Angeles, California 90071 
(213) 620-7070 (Telephone) 
(213) 620-1200 (Facsimile) 
info@aoelaw.om 
C:\AOE\Client\B\Benoit\MotionForAdditionalTime 
Case 1:20-cr-00296-JPB-CMS     Document 58     Filed 08/24/20     Page 2 of 5

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CERTIFICATE OF COMPLIANCE 
 
This is to certify that to the best of my knowledge this document has been prepared 
with one of the font and point selections approved by the Court in LR 5.1B, pursuant to 
LR 7. Specifically, the above-mentioned document has been prepared using Times New 
Roman font, 14 point. 
 
Dated this 24TH day of August, 2020. 
 
s/ Anthony O. Egbase 
 
ANTHONY O. EGBASE 
California Bar No. 181721 
Attorney for Defendant Bern Benoit 
 
A.O.E LAW & ASSOCIATES, INC 
350 S. Figueroa Street 
Suite 189 
Los Angeles, California 90071 
(213) 620-7070 (Telephone) 
(213) 620-1200 (Facsimile) 
info@aoelaw.om 
C:\AOE\Client\B\Benoit\MotionForAdditionalTime 
 
Case 1:20-cr-00296-JPB-CMS     Document 58     Filed 08/24/20     Page 3 of 5

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA, 
) 
) 
Plaintiff, 
) 
) 
vs. 
) 
CASE NO.: 1:20-CR-00296-JPB-AJB 
) 
BERN BENOIT, 
) 
) 
Defendant. 
) 
  
) 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on the above date, I electronically filed this document 
using the CM/ECF system which will automatically send email notification of such filing 
to all attorneys of record. 
Respectfully submitted, 
 
s/ Anthony O. Egbase 
 
ANTHONY O. EGBASE 
California Bar No. 181721 
Attorney for Defendant Bern Benoit 
 
A.O.E LAW & ASSOCIATES, INC 
350 S. Figueroa Street 
Suite 189 
Los Angeles, California 90071 
(213) 620-7070 (Telephone) 
(213) 620-1200 (Facsimile) 
info@aoelaw.om 
C:\AOE\Client\B\Benoit\MotionForAdditionalTime 
 
 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 58     Filed 08/24/20     Page 4 of 5

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA, 
) 
) 
Plaintiff, 
) 
) 
vs. 
) 
CASE NO.: 1:20-CR-00296-JPB-AJB 
) 
BERN BENOIT, 
) 
) 
Defendant. 
) 
  
) 
 
ORDER 
For good cause shown, the Defendant’s Motion for Extension of Time to File 
Motions and to Continue the Pretrial Conference is hereby GRANTED, Defendant shall 
have until                              to file motions. The pretrial conference shall be held on 
October          , 2020 at           .   
The period from the date of this order to the date of the pretrial conference shall be 
excluded from the speedy trial clock because the ends of justice served by the granting this 
extension of the time outweigh the best interest of the public and the defe3ndnats in speedy 
trial. 18 U.S.C. Section 3161(h)(7)(A). 
IT IS SO ORDERED 
This        day of August, 2020.  
 
HON. ALAN J. BAVERMAN 
UNITED STATE MAGISTRATE JUDGE 
Proposed Order submitted by: 
Anthony O. Egbase 
Attorney for Bern Benoit 
Case 1:20-cr-00296-JPB-CMS     Document 58     Filed 08/24/20     Page 5 of 5

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