Joint Proposed Special Verdict Form as to Carla Jackson filed by USA — USA v. Thomas et al. (Dkt. 845, N.D. Ga.)

Summary

The parties' joint proposed verdict form for defendant Carla Jackson in United States v. Carla Jackson, Criminal Action No. 1:20-CR-296-JPB-5, U.S. District Court for the Northern District of Georgia, dated January 23, 2024 and filed 01/23/24 as Document 845. The form asks the jury to find her guilty or not guilty on Count 46 and Count 47 of the indictment, each charging money laundering. The filing notes that Jackson objects to the government's proposed wording naming the charge for each count and the word unanimously, and sets out the government's position that the wording will prevent confusion in a multi-defendant, multi-count case.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
v. 
 
CARLA JACKSON 
 
Criminal Action No. 
1:20-CR-296-JPB-5 
 
PARTIES’ PROPOSED VERDICT FORM 
The United States of America, by Ryan K. Buchanan, United States Attorney 
for the Northern District of Georgia, and Tal C. Chaiken and Samir Kaushal, 
Assistant United States Attorneys, and by Glenn S. Leon, Chief of the Fraud 
Section, and Siji Moore, Trial Attorney, and Defendant Carla Jackson, by her 
attorney David D. Marshall, jointly file this Proposed Verdict Form. 
 The language highlighted in yellow below is language that the United States 
has proposed and to which Defendant Jackson objects.  The United States’ 
position is set forth below.  In addition, while the United States has no objection 
related to the order of “Guilty” and “Not Guilty” on the verdict form, it requests 
that the same order be used in each defendant’s verdict form. 
United States’ Position:  With respect to the language “As to Count [#] of 
the Indictment charging money laundering,” the United States requests this 
language to aid the jury in its review and deliberation as to this multi-defendant, 
multi-count indictment.  Placing the relevant charge for each count on the verdict 
form will ensure that there is no confusion as to the jury’s verdict.  
As to the language “unanimously,” the United States believes that language 
is appropriate given the requirement that any verdict reached be unanimous. 
 
Case 1:20-cr-00296-JPB-CMS     Document 845     Filed 01/23/24     Page 1 of 3

Dated: January 23, 2024  
 
   Respectfully submitted, 
 
/s/ David Marshall (with permission)_ 
DAVID D. MARSHALL 
   Counsel for Carla Jackson 
Georgia Bar No. 471517 
ddmarshall98@gmail.com   
  
RYAN K. BUCHANAN 
United States Attorney 
 
 
/s/ Tal Chaiken________________ 
TAL C. CHAIKEN 
   Assistant United States Attorney 
Georgia Bar No. 273949 
Tal.Chaiken@usdoj.gov 
 
SAMIR KAUSHAL 
   Assistant United States Attorney 
Georgia Bar No. 935285 
Samir.Kaushal@usdoj.gov 
 
 
GLENN S. LEON 
   Chief, Fraud Section 
   U.S. Department of Justice 
 
SIJI MOORE 
   Trial Attorney, Fraud Section 
   U.S. Department of Justice 
Babasijibomi.Moore2@usdoj.gov 
 
 
 
  
 
 
 
 
 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 845     Filed 01/23/24     Page 2 of 3

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
v. 
 
CARLA JACKSON 
 
Criminal Action No. 
1:20-CR-296-JPB-5 
 
VERDICT 
 
Count 46: 
 
As to Count Forty-Six of the Indictment charging money laundering, we, 
the Jury, unanimously find Defendant Carla Jackson: 
_______ Not Guilty 
 
 
_______ Guilty 
 
Count 47: 
 
As to Count Forty-Seven of the Indictment charging money laundering, 
we, the Jury, unanimously find Defendant Carla Jackson: 
_______ Not Guilty 
 
 
_______ Guilty 
 
 
SO SAY WE ALL. 
 
Signed and dated at the United States Courthouse, Atlanta, Georgia, 
this ______ day of February, 2024.  
 
 
_________________________ 
_________________________ 
Foreperson’s Signature 
Foreperson’s Printed Name 
 
Case 1:20-cr-00296-JPB-CMS     Document 845     Filed 01/23/24     Page 3 of 3

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