Response by Bernard Okojie re 79 Motion in Limine by Government — USA v. Okojie (Dkt. 91, S.D. Ga.)

Record facts

U.S. District Court for the Southern District of Georgia · No. 4:22-cr-00084-LGW-BWC · Doc. 91 · 2023-03-10 · 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: 4:22-CR-84
       
)
BERNARD OKOJIE, 
       
)
Defendant 
       
)
       
)
DEFENDANT BERNARD OKOJIE’S      
RESPONSE TO GOVERNMENT’S MOTION IN LIMINE  
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
Motion in Limine (Document 79) as follows:
1. Certain Records in this Case are Self-Authenticating: 
Mr. Okojie has no authenticity objections as to any document for which notices and
certificates of authenticity have been furnished.
2. Motion to Admit Certain Evidence at Trial:  
Mr. Okojie’s motion in limine (Document 75) references matters concerning his
involvement with Brandon Richardson, and contends that these crimes were not included in the
government’s 404(b) notice; therefore, they should not be admissible in the present case.  There
has not been any repudiation by Mr. Okojie, either directly or through pleadings filed by counsel,
of any matter in his proffer.  Identifying in Defendant’s motion in limine that the crimes involve
Brandon Richardson as a party are different crimes than those contained in the indictment is not
any material change from what Mr. Okojie has previously stated.    
The government did not name or include in the present indictment any criminal acts 
Case 4:22-cr-00084-LGW-BWC     Document 91     Filed 03/10/23     Page 1 of 3

involving Mr. Okojie and Brandon Richardson.  Brandon Richardson is not named directly or
otherwise identified as any of the unnamed individuals in the indictment (Count One - Paragraph 
27 of the indictment references Individuals 1 through 8 respectively and Paragraph 28 references
Individuals 3, 5, 4, 6, 7, 1, 8, and 2.  Count Two - Paragraph 31 references Individual 4.) The 
discovery materials and matters involving Mr. Okojie and Brandon Richardson, as can best be
determined, are not included in the transactions identified by descriptions in the indictment.
 No recording or transcript of Mr. Okojie’s proffer has ever been provided and the only
report included in the discovery materials was a summary of the interview.  
3. Motion to Exclude Certain Argument and Evidence at Trial:  
Mr. Okojie is not offering “negligence of a victim” as a defense.
Respectfully submitted, this 10th 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 91     Filed 03/10/23     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: 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 10th 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 91     Filed 03/10/23     Page 3 of 3

File and source

File

gov.uscourts.gasd.87222.91.0.pdf

Size

100,798 bytes

SHA-256

5d10486cd7b0f1a841e2a5f001112ea4007806c636913a27dcedab6277455c7e

Our copy

gov.uscourts.gasd.87222.91.0.pdf

Original

PACER (login required)