Court filing
Unopposed Motion to Continue Pretrial Motions Deadline — USA v. Thomas et al. (Dkt. 270, N.D. Ga.)
Filed August 9, 2021 in USA v. Thomas et al.; one of 21 filings from this case.
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2021-08-09 |
U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 270 · 2021-08-09 · Docket on CourtListener
Full text
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRIC OF GEORGIA UNITED STATES OF AMERICA Plaintiff, v. DEREK PARKER, et al. Defendant Case No. 1:20-CR-296-JPB-AJB UNOPPOSED MOTION TO CONTINUE PRETRIAL MOTION DEADLINE AND PRETRAIL CONFERENCE Defendant Derek Parker, by and through counsel, respectfully files this Unopposed Motion to Continue the Pretrial Motion Deadline and the Pretrial Conference currently scheduled for August 12 and August 23, 2021, respectively, showing the Court as follows: 1. A grand jury sitting in the Northern District of Georgia returned the above-referenced indictment against Mr. Parker and 14 co-defendants on July 13, 2021 (Doc. 135) [First Superseding Indictment]. Mr. Parker is not in custody. 2. The Indictment alleges multiple fraud and money laundering schemes involving over a dozen allegedly fraudulent CARES Act Paycheck Protection Program loan applications submitted to various lenders by different businesses (Id.). Case 1:20-cr-00296-JPB-CMS Document 270 Filed 08/09/21 Page 1 of 4 #3266129v1 2 3. On July 21, 2021, the Court appointed the undersigned counsel to represent Mr. Parker in this case pursuant to the Criminal Justice Act of 1964, 18 U.S.C. § 3006A (Doc. 221). 4. Undersigned counsel has not yet had an opportunity to review the discovery in this matter, but understands that it involves a large volume of materials requiring a 64GB hard drive. 5. The court-ordered deadline for the filing of pretrial motions is August 12, 2021, and the pretrial conference is scheduled for August 13, 2021 (Doc. 258). 6. Mr. Parker respectfully requests that the Court continue the pretrial conference and pretrial motion deadline for sixty days to afford counsel additional time to review and analyze the discovery, assess any necessary pretrial motions, evaluate potential pretrial resolutions and confer with the prosecutors, and to confer with and advise Mr. Parker. 7. Mr. Parker further requests that any delay caused by the requested extension be excluded from Speedy Trial Act computations because there is good cause for the extension, a continuance is needed to allow reasonable time necessary for effective representations to prevent a Case 1:20-cr-00296-JPB-CMS Document 270 Filed 08/09/21 Page 2 of 4 #3266129v1 3 miscarriage of justice, and the defendant’s interests in a speedy trial. See 18 U.S.C. §§ 3161(h)(7)(A), 3161(h)(7)(B)(i) & (iv). 8. No previous continuances have been requested or obtained. 9. The undersigned counsel has conferred with counsel for the government about a continuance, and the government has stated that it does not oppose a continuance. WHEREFORE, Defendant Parker requests that the pretrial motion deadline in this case be extended for sixty days, until October 11, 2021, and that the pretrial conference be rescheduled accordingly on a date agreeable to the Court and the parties. Respectfully submitted, this 9th day of August, 2021. /s/ Kamal Ghali Kamal Ghali Georgia Bar No. 805055 Bondurant Mixson & Elmore, LLP One Atlantic Center, Suite 3900 1201 W. Peachtree Street NW, Atlanta, Georgia 30309 (404) 881-4100 (404) 881-4111 ghali@bmelaw.com Counsel for Derek Parker Case 1:20-cr-00296-JPB-CMS Document 270 Filed 08/09/21 Page 3 of 4 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was electronically filed this day with the Clerk of the Court using the CM/ECF system which will automatically send email notification of such filing to all counsel of record. This 9th day of August, 2021. /s/ Kamal Ghali Kamal Ghali Georgia Bar No. 805055 Case 1:20-cr-00296-JPB-CMS Document 270 Filed 08/09/21 Page 4 of 4
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