Motion for Leave to Proceed in forma pauperis by Carla Jackson — USA v. Thomas et al. (Dkt. 1009, N.D. Ga.)

Summary

A Motion to Proceed on Appeal in Forma Pauperis, Document 1009, filed 05/28/24 by defendant Carla Jackson through her CJA counsel David D. Marshall, Indictment No. 1:20-CR-00296-JPB-CMS-5, Northern District of Georgia. It says counsel was appointed under the Criminal Justice Act on August 10, 2020 and that Jackson filed a Notice of Appeal the same day from the conviction, judgment and sentence imposed on May 16, 2024 and entered on May 20, 2024. Because she was already found indigent in the district court action, she asks that counsel be appointed for the appeal and that she be allowed to proceed in forma pauperis. The motion is dated May 28, 2024 and includes a certificate of service.

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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-CMS-5 
 
 
 
Defendant  
) 
 
______________________________ ) 
 
 
MOTION TO PROCEED ON APPEAL IN FORMA PAUPERIS 
 
 
COMES NOW Defendant CARLA JACKSON, by and through her 
undersigned CJA counsel of record, and hereby files this her “Motion to 
Proceed on Appeal in Forma Pauperis” and in support thereof states the 
following: 
1. 
Undersigned counsel was appointed under the Criminal Justice Act on 
August 10, 2020 (nunc pro tunc to August 7, 2020) to represent Defendant 
before this Court in her district court criminal case. 
2. 
Defendant has filed a Notice of Appeal this same day to the 
conviction, judgment and sentence entered against her in this case (judgment 
and sentence imposed on May 16, 2024 and entered on May 20, 2024). 
 
Case 1:20-cr-00296-JPB-CMS     Document 1009     Filed 05/28/24     Page 1 of 3

 
2
3. 
According to Rule 24 of the Federal Rules of Appellate Procedure for 
the Eleventh Circuit (“FRAP 24”), [a] party who was permitted to proceed in 
forma pauperis in the district court action, or who was determined to be 
financially unable to obtain an adequate defense in a criminal case, may 
proceed on appeal in forma pauperis without further authorization” (except 
in certain specified conditions not applicable in Defendant’s current appeal). 
4. 
As Defendant was already qualified as indigent by this Court during 
her district court action, Defendant respectfully requests that the Court 
appoint undersigned counsel to handle her appeal case, and that Defendant 
be allowed to proceed in her appeal in forma pauperis. 
This 28th day of May, 2024. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/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) 
david.marshall@esquireguy.com 
 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 1009     Filed 05/28/24     Page 2 of 3

 
3
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-CMS-5 
 
 
 
Defendant  
) 
 
______________________________ ) 
 
CERTIFICATE OF SERVICE 
 
 
This is to certify that the foregoing MOTION TO PROCEED ON 
APPEAL IN FORMA PAUPERIS 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 all parties of record. 
 
This 28th day of May, 2024. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/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) 
david.marshall@esquireguy.com 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 1009     Filed 05/28/24     Page 3 of 3

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