Court filing

Unopposed Motion to Continue Pretrial Motions Deadline — USA v. Thomas et al. (Dkt. 270, N.D. Ga.)

Summary

Document 270, filed 08/09/21 in No. 1:20-CR-296-JPB-AJB in the U.S. District Court for the Northern District of Georgia, is a four-page unopposed motion by Derek Parker to continue the pretrial motion deadline of August 12, 2021 and the pretrial conference. It says the First Superseding Indictment returned July 13, 2021 names him and 14 co-defendants over multiple fraud and money laundering schemes tied to PPP loan applications, and that he is not in custody. CJA-appointed counsel Kamal Ghali has not yet reviewed discovery that requires a 64GB hard drive. The motion asks for sixty days, until October 11, 2021, with the time excluded under the Speedy Trial Act, and says the government does not oppose.

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Filed August 9, 2021 in USA v. Thomas et al.; one of 541 filings from this case.

Record facts

Court	U.S. District Court for the Northern District of Georgia
Filed	2021-08-09

Cite this document

“Unopposed Motion to Continue Pretrial Motions Deadline — USA v. Thomas et al. (Dkt. 270, N.D. Ga.).” U.S. District Court for the Northern District of Georgia, No. 1:20-cr-00296-JPB-CMS, Doc. 270, filed 2021-08-09. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-derek-parker-gand-292223/2021-08-09-gov-uscourts-gand-292223-270-0-doc-270/, SHA-256 0b846c0c42ed5f72835b3a26e78b9a101302e305e0a5c01926fa2d1c9a2702dd.

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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.).  
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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 
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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 
 
 
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