First Motion to Continue All Deadlines by Chad Brandon Thomas — USA v. Thomas (Dkt. 62, E.D. Tenn.)

Record facts

U.S. District Court for the Eastern District of Tennessee · No. 2:22-cr-00076-JRG-CRW · Doc. 62 · 2023-05-05 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF TENNESSEE AT GREENEVILLE 
 
 
UNITED STATES OF AMERICA 
 
 
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Plaintiff, 
 
 
 
 
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vs. 
 
 
 
 
 
 
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Docket No. 2:22-CR-76 
 
 
 
 
 
 
 
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JUDGE GREER 
CHAD BRANDON THOMAS  
 
 
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Defendant. 
 
 
 
 
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MOTION TO CONTINUE ALL DEADLINES 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Comes now your Defendant, by and through counsel, and brings forth this Motion to 
Continue All Deadlines and a request would show as follows:  
1. 
On or about April 11, 2023 the Defendant was appointed the undersigned as 
new counsel.   
2. 
That soon thereafter the undersigned was made aware of such appointment 
and immediately began to gather information by speaking with the AUSA and 
prior counsel. 
3. 
Given the fragile nature of what is pending before the Court, having nothing to 
do with the undersigned, it is paramount that a continuance of all deadlines be 
granted in order to allow counsel to familiarize herself with the case and have 
the opportunity to build a rapport with the Defendant. 
4. 
Currently, a decision is set to be made by May 10, 2023 on the Defendant’s 
Motion to Withdraw his plea agreement.   
Case 2:22-cr-00076-JRG-CRW     Document 62     Filed 05/05/23     Page 1 of 3     PageID
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5. 
The undersigned states that though she has been able to meet with the 
Defendant one time, she is still gathering discovery documents that are 
pertinent to the Defendant’s decision to move forward. 
6. 
The undersigned states that there is no possible way with the time constraints 
given and where the Defendant is housed, that she would be able to make 
those travels and discussions while she is still not in full possession of the 
documents to give guidance to the Defendant as required before May 10, 2023. 
7. 
Counsel for the Defendant has discussed this issue with the AUSA and he is 
unopposed to this motion.   
WHEREFORE, the Defendant prays that all deadlines be continued a minimum of 
sixty (60) days to afford counsel the opportunity to fully investigate the case and to advise 
the Defendant accordingly.  This request is not made to delay proceedings unnecessarily, but 
to afford zealous representation to meet the interest of justice. 
Respectfully submitted, this the 5th day of May, 2023. 
 
Defendant Chad Brandon Thomas 
 
s/ Donna M. Bolton  
 
 
 
 
Donna M. Bolton, BPR # 026349 
200 West Unaka Avenue 
Johnson City, TN 37604 
Phone: 423-631-0077 
Fax: 423-631-0944 
boltonlaw@gmail.com 
 
 
 
 
 
 
 
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CERTIFICATE OF SERVICE 
 
 
I hereby certify that on the 5th day of May, 2023, the foregoing document was filed 
electronically.  Notice of this filing is sent by operation of the Court’s electronic filing system 
to all parties indicated on the electronic filing receipt.  All other parties will be served by 
regular U.S. Mail.  Parties may access this filing through the Court’s electronic filing system. 
 
s/ Donna M. Bolton  
 
 
Donna M. Bolton 
Case 2:22-cr-00076-JRG-CRW     Document 62     Filed 05/05/23     Page 3 of 3     PageID
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