Unopposed MOTION for Extension of Time To File Pretrial Motions by Carla Jackson — USA v. Thomas et al (Dkt. 88)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 88 · 2021-02-17 · Docket on CourtListener

Summary

An unopposed motion for extension of time to file pretrial motions, filed February 17, 2021 by defendant Carla Jackson in United States v. Thomas et al, No. 1:20-cr-00296-JPB-CMS, in the U.S. District Court for the Northern District of Georgia, as Doc. 88. The motion asks for a 30-day extension through March 24, 2021, stating that pretrial motions are due February 22, 2021 and the pretrial conference is set for February 24, 2021. It states that the indictment charges money laundering violations, cited as 21 U.S.C. § 1956, and that counsel needs more time to review initial and supplemental discovery mailed by the Government. It reports that AUSA Tal Chaiken indicated no objection and asks that the time be excluded under 18 U.S.C. § 3161(h)(7). The three-page motion 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 March 24, 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 February 24, 2021 with pretrial motions 
presently due by February 22, 2021. 
2. 
The Government has mailed its initial discovery out to undersigned 
counsel, which counsel is still reviewing and discussing with Defendant. The 
Government also has mailed out supplemental discovery, which is somewhat 
voluminous and which counsel if still reviewing. Counsel would appreciate 
Case 1:20-cr-00296-JPB-CMS     Document 88     Filed 02/17/21     Page 1 of 3

 
2
additional time from the Court to review the original and supplemental 
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 
March 24, 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 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 17th day of February, 2021. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/  David D. Marshall 
      
 
 
 
 
 
 
 
David D. Marshall 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
Georgia Bar No. 471517 
 
2550 Sandy Plains Road 
Suite 225 PMB 349 
Case 1:20-cr-00296-JPB-CMS     Document 88     Filed 02/17/21     Page 2 of 3

 
3
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 17th day of February, 2021. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/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 88     Filed 02/17/21     Page 3 of 3

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