Response by Bernard Okojie re 67 Notice (Other) — USA v. Okojie (Dkt. 86, S.D. Ga.)

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Filed March 9, 2023 as Document 86 in Case No. 4:22-CR-84 (S.D. Ga., Savannah Division), this is Defendant Bernard Okojie's Response to Government's Notice of Supplemental Evidence, filed by counsel John J. Ossick, Jr. It responds to the Government's Notice of Supplemental Evidence Pertinent to Defendant's Pending Motion in Limine Regarding Undeclared Cash Seized at Airport (Document 67). Reserving all objections to admissibility at trial, the response says that for the 404(b) motion hearing he has no objection to admission of the four exhibits the government referenced. It adds that the exhibits, which identify a portion of the seized funds, are evidence of disclosure contrary to the government's theory of concealment. These are the defense's contentions.

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IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA           
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v.
      
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 CASE NUMBER: 4:22-CR-84
       
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BERNARD OKOJIE, 
       
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Defendant 
       
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DEFENDANT BERNARD OKOJIE’S      
RESPONSE TO GOVERNMENT’S NOTICE OF SUPPLEMENTAL EVIDENCE 
COMES NOW, BERNARD OKOJIE, Defendant in the above-styled action, by and
through his undersigned counsel of record, and files this his response to the Government’s
Notice of Supplemental Evidence Pertinent to Defendant’s Pending Motion in Limine Regarding
Undeclared Cash Seized at Airport (Document 67) as follows:
Reserving all objections to admissibility at trial, for purposes of the Court’s consideration
concerning the 404(b) motion hearing, Mr. Okojie has no objection to admission of the four
exhibits referenced by the government.  
Mr. Okojie would suggest that these exhibits identifying a portion of the seized funds
constitute evidence of disclosure that is contrary to the government’s theory of concealment. 
Respectfully submitted, this 9th day of March, 2023.         
/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 86     Filed 03/09/23     Page 1 of 2

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA           
)
       
)
v.
      
)
 CASE NUMBER: 4:22-CR-84
       
)
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 9th day of March, 2023.           
/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 86     Filed 03/09/23     Page 2 of 2

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