Unopposed MOTION for Extension of Time To File Pretrial Motions by Carla Jackson — USA v. Thomas et al (Dkt. 46)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 46 · 2020-08-18 · Docket on CourtListener

Summary

An unopposed motion for extension of time to file pretrial motions, filed August 18, 2020 by defendant Carla Jackson as Doc. 46 in USA v. Thomas et al, No. 1:20-cr-00296-JPB-CMS, in the U.S. District Court for the Northern District of Georgia. The motion asks for a 60-day extension through October 20, 2020, noting that pretrial motions are due by August 21, 2020 and the pretrial conference is set for August 24, 2020. It states that the government has just mailed discovery that counsel has not yet reviewed, and cites counsel's other appellate briefing obligations. It reports that the government has no objection and asks that the time be excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7). The three-page filing is signed by defense attorney David D. Marshall and includes a certificate of service.

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Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES                               ) 
 
 
                                                             )   
 
             v.                                             )         
                                                              )     
INDICTMENT NO. 
 
CARLA JACKSON, 
 
 
)     
1:20-CR-00296-JPB-AJB-05 
 
 
 
Defendant  
) 
 
______________________________ ) 
 
 
UNOPPOSED MOTION FOR EXTENSION OF  
TIME TO FILE PRETRIAL MOTIONS 
 
 
Defendant CARLA JACKSON, through his counsel, respectfully 
requests a 60-day time extension through October 20, 2020 in which to 
file pretrial motions in this case. In support, Defendant states the following:  
1. 
 
Ms. Jackson is named in the above referenced indictment charging her 
with money laundering violations under 21 U.S.C. § 1956. Ms. Jackson’s 
pretrial conference is scheduled for August 24, 2020 with pretrial motions 
presently due by August 21, 2020. (Doc. No. 41). 
2. 
The Government has just mailed discovery out to undersigned 
counsel, which counsel – as yet – has not had a chance to review. Counsel 
still needs additional time to review discovery, to discuss such discovery 
with the Defendant, and to determine if any pretrial motions should be filed. 
Case 1:20-cr-00296-JPB-CMS     Document 46     Filed 08/18/20     Page 1 of 3

 
2
Counsel’s current caseload obligations also factor into his request for a time 
extension. These other obligations include counsel’s preparation of two 
appellate briefs to the Eleventh Circuit Court of Appeals and to the Georgia 
Court of Appeals, briefs for which are both due during the next few weeks. 
3. 
 
Because of the above, Defendant requests an extension through 
October 20, 2020 in which to file any pretrial motions, a 60-day 
extension from the current deadline.  
4. 
Undersigned counsel has discussed Defendant’s time extension 
request with AUSA Tal Chaiken and Ms. Chaiken has indicated that the 
Government has no objection. 
5. 
 
Defendant further requests that the time extension in which to file 
pretrial motions be excluded under the Speedy Trial Act, pursuant to 18 
U.S.C. § 3161(h)(7). 
 
Respectfully submitted this 18th day of August, 2020. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/  David D. Marshall 
      
 
 
 
 
 
 
 
David D. Marshall 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
Georgia Bar No. 471517 
 
Case 1:20-cr-00296-JPB-CMS     Document 46     Filed 08/18/20     Page 2 of 3

 
3
2550 Sandy Plains Road 
Suite 225 PMB 349 
Marietta, Georgia 30066 
(404) 213-1358 (phone) 
(678) 868-2241 (fax) 
ddmarshall98@gmail.com 
 
CERTIFICATE OF SERVICE 
 
 
This is to certify that the foregoing was formatted in 14-point Times 
Roman, in accordance with Local Rule 5.1C, and was electronically filed 
this day with the Clerk of Court using the CM/ECF system, which will 
automatically send email notification of such filing to the following: 
All defense counsel; All AUSA’s of record 
 
This 18th day of August, 2020. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/  David D. Marshall 
      
 
 
 
 
 
 
 
David D. Marshall 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
Georgia Bar No. 471517 
2550 Sandy Plains Road 
Suite 225 PMB 349 
Marietta, Georgia 30066 
(404) 213-1358 (phone) 
(678) 868-2241 (fax) 
ddmarshall98@gmail.com 
 
Case 1:20-cr-00296-JPB-CMS     Document 46     Filed 08/18/20     Page 3 of 3

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