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Home Court filings USA v. Davis — U.S. District Court, Eastern District of Virginia Consent MOTION to Continue Motions Deadline by Craig David Davis — USA v. Davis (Dkt. 23)

Court filing

Consent MOTION to Continue Motions Deadline by Craig David Davis — USA v. Davis (Dkt. 23)

Record facts

CourtU.S. District Court for the Eastern District of Virginia
Filed2024-04-24

U.S. District Court for the Eastern District of Virginia · No. 1:24-cr-00040-PTG · Doc. 23 · 2024-04-24 · Docket on CourtListener

Summary

An agreed motion to continue the motions deadline, filed April 24, 2024 by defendant Craig David Davis in United States v. Davis, No. 1:24-cr-00040-PTG, in the U.S. District Court for the Eastern District of Virginia, Doc. 23. The motion recounts that a February 15, 2024 indictment charges four counts of wire fraud under 18 U.S.C. § 1343, that arraignment was on March 7, 2024, and that the Court set a May 6, 2024 motions deadline and an October 22, 2024 trial date. It states the parties are discussing a potential resolution, that government counsel awaits supervisory approval, and that the government may seek a superseding indictment. It asks the Court to continue the deadline by 30 days to June 5, 2024, with the government's agreement, and attaches a proposed order. It is signed by Assistant Federal Public Defender Cadence A. Mertz.

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Full text

UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF VIRGINIA 
Alexandria Division 
 
UNITED STATES OF AMERICA 
) 
 
 
 
 
 
 
) 
            v. 
 
 
 
 
) 
Case No. 1:24-cr-40 
 
 
 
 
 
 
)  
CRAIG DAVID DAVIS,  
 
) 
Hon. Patricia Tolliver Giles  
 
 
 
 
 
 
) 
 
 
 
Defendant.  
 
) 
Motions Deadline: May 6, 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AGREED MOTION TO CONTINUE MOTIONS DEADLINE 
 
 
COMES NOW the defendant, Craig David Davis, through counsel, who states: 
1. The government obtained an indictment in this case on February 15, 2024, 
charging Mr. Davis with four counts of wire fraud in violation of 18 U.S.C. § 
1343.  Mr. Davis made his initial appearance in the Eastern District of 
California on February 21, 2024, and traveled to this jurisdiction for his 
arraignment on March 7, 2024.  
2. At the arraignment, this Court set a motions deadline of 60 days, resulting in 
a due date of May 6, 2024.  Trial was set for October 22, 2024. 
3. Since the arraignment, the parties have been in regular contact regarding a 
potential resolution.  Those discussions are in good faith, detailed and 
progressing.  Government counsel is awaiting supervisory approval to seek a 
resolution along the lines of what the parties have been discussing.  As a result, 
the parties do not anticipate reaching a resolution before the May 6 motions 
deadline.   
Case 1:24-cr-00040-PTG     Document 23     Filed 04/24/24     Page 1 of 2 PageID# 121

2 
 
4. Additionally, the government has advised that it may seek a superseding 
indictment in the coming weeks.  A superseding indictment could affect the 
parties’ motions calculus, as well as the calendar set for those motions and 
responses to be due. 
5. For these reasons, the parties believe that continuing the motions deadline for 
30 days would serve the interests of judicial economy.  A continuance would 
conserve party and judicial resources and may avoid unnecessary, premature 
or duplicative litigation.  
6. Undersigned counsel has conferred with government counsel, who has 
reviewed and agreed to the filing of this motion.  
Accordingly, the defense respectfully moves this Court to continue the motions 
deadline by 30 days to June 5, 2024.  A proposed order is attached. 
 
 
 
 
 
 
Respectfully submitted,  
 
 
 
 
 
 
CRAIG DAVID DAVIS 
 
 
 
 
 
 
 
By Counsel, 
 
 
 
 
 
 
Geremy C. Kamens 
 
 
 
 
 
 
Federal Public Defender 
 
 
 
 
 
 
By:  
/s/ Cadence A. Mertz            
        
Cadence A. Mertz 
 
 
 
 
 
 
Va. Bar No. 89750 
Assistant Federal Public Defender 
 
 
 
 
 
 
1650 King Street, Suite 500 
Alexandria, Virginia   22314 
(703) 600-0840 (tel) 
(703) 600-0880 (fax) 
 
 
 
 
 
 
Cadence_Mertz@fd.org  
 
 
 
 
 
 
 
Counsel to Mr. Davis 
Case 1:24-cr-00040-PTG     Document 23     Filed 04/24/24     Page 2 of 2 PageID# 122

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