Motion to Interview Government Informants Prior to Trial — USA v. Okojie (Dkt. 39, S.D. Ga.)

Record facts

U.S. District Court for the Southern District of Georgia · No. 4:22-cr-00084-LGW-BWC · Doc. 39 · 2022-09-15 · Docket on CourtListener

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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 
MOTION TO INTERVIEW GOVERNMENT
INFORMANTS PRIOR TO TRIAL
COMES NOW, BERNARD OKOJIE, Defendant in the above-styled action, by
and through his undersigned counsel of record, and moves this Court for an order
requiring the government to provide him, through counsel, with the identity and present
location of all unindicted co-conspirators who the government expects to call as
witnesses against him at trial, who are alleged to have participated in the acts forming the
basis of the above indictment so that counsel can attempt to interview them in preparation
for hearings on Mr. Okojie’s motions and for trial; or, in the alternative, to make them
available at a time and location convenient to counsel as soon as reasonably possible.  
Mr. Okojie further requests that the Court order the government to refrain from
obstructing any efforts by his counsel to interview these persons or from discouraging
them from consenting to an interview by his counsel.
In the instant indictment, Mr. Okojie is the only named defendant; however, the
indictment refers to “co-conspirators, known and unknown”, but does not identify anyone
as an unindicted co-conspirator.  While the indictment references Individual 1",
“Individual 2", “Individual 3", “Individual 4", “Individual 5", “Individual 6",  “Individual 
Case 4:22-cr-00084-LGW-BWC     Document 39     Filed 09/15/22     Page 1 of 3

7", and “Individual 8", they are not alleged to be parties to any conspiratorial agreement.  
WHEREFORE, Mr. Okojie respectfully prays that this Court issue an order
requiring the government to inform his counsel of the identity and current address of any
and all unindicted co-conspirators, or, in the alternative, to make them available at a time
and location convenient to counsel for purposes of counsel requesting an interview, and
for such other and further relief as this Court may deem just and proper.
Respectfully submitted, this 15th day of September, 2022.      
  
/s/John J. Ossick, Jr. 
Georgia Bar Number 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 39     Filed 09/15/22     Page 2 of 3

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 September, 2022.        
/s/John J. Ossick, Jr. 
Georgia Bar Number 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 39     Filed 09/15/22     Page 3 of 3

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