Unopposed MOTION for Extension of Time To File Pretrial Motions by Carla Jackson — USA v. Thomas et al (Dkt. 66)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 66 · 2020-10-19 · Docket on CourtListener

Summary

An unopposed motion for extension of time to file pretrial motions, filed October 19, 2020 by defendant Carla Jackson 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. It is Document 66. The motion states that the indictment charges the defendant with money laundering violations under 21 U.S.C. § 1956, with pretrial motions due October 21, 2020 and a pretrial conference set for October 23, 2020. It cites counsel's ongoing review of initial discovery, expected additional discovery and caseload obligations, and states that the government has no objection. The motion asks for a 60-day extension through December 21, 2020, with the time excluded under 18 U.S.C. § 3161(h)(7). The three-page filing is signed by defense counsel David D. Marshall.

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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 December 21, 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 October 23, 2020 with pretrial motions 
presently due by October 21, 2020. 
2. 
The Government has mailed its initial discovery out to undersigned 
counsel, which counsel is still reviewing and discussing with Defendant. 
Counsel understands that the Government will be producing additional 
discovery to defendants. Counsel would appreciate additional time from the 
Case 1:20-cr-00296-JPB-CMS     Document 66     Filed 10/19/20     Page 1 of 3

 
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Court to review this new discovery, and the original produced discovery, and 
to discuss these materials with Defendant. Counsel will also need to 
determine if any pretrial motions should be filed. Counsel’s current caseload 
obligations also factor into his request for the instant time extension. 
3. 
 
Because of the above, Defendant requests an extension through 
December 21, 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 Nathan Kitchens and Mr. Kitchens 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 19th day of October, 2020. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/  David D. Marshall 
      
 
 
 
 
 
 
 
David D. Marshall 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
Georgia Bar No. 471517 
 
Case 1:20-cr-00296-JPB-CMS     Document 66     Filed 10/19/20     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 19th day of October, 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 66     Filed 10/19/20     Page 3 of 3

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