Motion for Extension of Time to File Motions Unopposed by John J. — USA v. Okojie (Dkt. 25, S.D. Ga.)

Record facts

U.S. District Court for the Southern District of Georgia · No. 4:22-cr-00084-LGW-BWC · Doc. 25 · 2022-08-15 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION 
UNITED STATES OF AMERICA
)
)
v.                                        
)   CASE NUMBER: CR422-0084
)
BERNARD OKOJIE, 
 
)
Defendant
)
DEFENDANT BERNARD OKOJIE’S 
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTIONS
COMES NOW, BERNARD OKOJIE, Defendant, by and through his counsel of record,
and moves this Honorable Court for a thirty (30) day extension of time in which to file motions
and pretrial pleadings.
In support thereof, Mr. Okojie states as follows:
1.
Undersigned counsel was appointed to represent Mr. Okojie on June 22, 2022. 
(Document 13) 
2.
Count One of the Indictment alleges conspiracy to commit wire and bank fraud in
violation of 18 U.S.C. §1349, claiming that: 
A.
Mr. Okojie submitted “no less than ten different EIDL applications to the SBA on
behalf of various businesses purportedly owned and operated by OKOJIE.”  
B.  
Mr. Okojie submitted “at least eight EIDL applications to the SBA on behalf of
various business purportedly owned and operated by individuals” other than Mr.
Okojie; and  
Case 4:22-cr-00084-LGW-BWC     Document 25     Filed 08/15/22     Page 1 of 4

C.
Mr. Okojie submitted “one or more PPP applications”.
3.
Count Two of the Indictment alleges wire fraud in violation of 18 U.S.C. §1343 and 2. 
4.
Count Three of the Indictment alleges a money laundering conspiracy in violation of       
18 U.S.C. §1956(h) concerning the wire and bank fraud schemes and conspiracy charged in
Counts One and Two of the Indictment. 
5.
The Indictment also contains a forfeiture allegation.
6.  
While no co-conspirators are named in the Indictment, the Indictment alleges that at least
eight other individuals had some involvement in these financial transactions alleged in Count
One.
7.
Defense counsel was initially furnished significant discovery materials on July 19, 2022
at the Initial Appearance and has received additional productions with the most recent furnished
on August 12, 2022.  
8.
Upon defense counsel’s request at the Initial Appearance, the Court extended the filing
time for pretrial motions and in its Order that stated “All pretrial motions shall be filed on or
before August 18, 2022.”  (Document 21)
Case 4:22-cr-00084-LGW-BWC     Document 25     Filed 08/15/22     Page 2 of 4

9.
As discovery materials have been reviewed, it now appears that the factual matters
described in these materials and the potential legal issues in this case are more involved than
initially expected, and as a consequence more time is necessary to determine and prepare pretrial
motions.  Mr. Okojie’s counsel requests that he be granted a thirty (30) day extension of time in
which to file motions.
10.
Counsel has conferred with Assistant United States Attorney Jonathan Porter, who is
prosecuting the case, and Mr. Porter has given his permission for counsel to represent to the
Court that he does not oppose the extension of time.    
11.
Mr. Okojie is not requesting this extension of time to delay or unduly prejudice these
proceedings.
WHEREFORE, Mr. Okojie respectfully requests that the Court grant his Motion and
extend the time to file motions for thirty (30) days from August 18, 2022 until September 17,
2022. 
Respectfully submitted, this 15th day of August, 2022.    
/s/John  J. Ossick, Jr.
Georgia Bar No. 555150
JOHN J. OSSICK, JR., P.C.
Post Office Box 1087
Kingsland, Georgia  31548
Telephone:  912-729-5864
E-mail:  ossick@tds.net 
Case 4:22-cr-00084-LGW-BWC     Document 25     Filed 08/15/22     Page 3 of 4

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION 
UNITED STATES OF AMERICA
)
)
v.                                        
)   CASE NUMBER: CR422-0084
)
BERNARD OKOJIE, 
 
)
Defendant
)
CERTIFICATE OF SERVICE 
This is to certify that I have this day served all parties in this case in accordance with the
directives from the Court Notice of Electronic Filing (“NEF”), which was generated as a result
of electronic filing.
This 15th day of August, 2022. 
/s/John  J. Ossick, Jr.
Georgia Bar No. 555150
JOHN J. OSSICK, JR., P.C.
Post Office Box 1087
Kingsland, Georgia  31548
Telephone:  912-729-5864
E-mail:  ossick@tds.net 
Case 4:22-cr-00084-LGW-BWC     Document 25     Filed 08/15/22     Page 4 of 4

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