Unopposed MOTION for Extension of Time To File Pretrial Motions by Carla Jackson — USA v. Thomas et al (Dkt. 76)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 76 · 2020-12-11 · Docket on CourtListener

Summary

An unopposed motion by defendant Carla Jackson for an extension of time to file pretrial motions 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, filed December 11, 2020 as Document 76. The motion asks for a 30-day extension through January 13, 2021. It states that the indictment charges Ms. Jackson with money laundering violations under 21 U.S.C. § 1956, and that defense counsel is still reviewing the initial discovery and has sought supplemental discovery from the government. The motion states 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). It is signed by defense counsel 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 30-day time extension through January 13, 2021 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. The 
Government recently announced that is has additional discovery to available 
to defendants. Undersigned counsel has just mailed out a flash drive to to the 
Case 1:20-cr-00296-JPB-CMS     Document 76     Filed 12/11/20     Page 1 of 3

 
2
Government to obtain the supplemental discovery. Counsel would appreciate 
additional time from the 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. 
3. 
 
Because of the above, Defendant requests an extension through 
January 13, 2021 in which to file any pretrial motions, a 30-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 11th day of December, 2020. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/  David D. Marshall 
      
 
 
 
 
 
 
 
David D. Marshall 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
Georgia Bar No. 471517 
 
Case 1:20-cr-00296-JPB-CMS     Document 76     Filed 12/11/20     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 11th day of December, 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 76     Filed 12/11/20     Page 3 of 3

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