Motion to Continue Sentencing with Brief In Support by Derek Parker — USA v. Thomas et al. (Dkt. 512, N.D. Ga.)

Summary

Defendant Derek Parker's Motion to Continue Sentencing in United States of America v. Derek Parker, File No. 1:20-CR-00296-14-JPB, in the U.S. District Court for the Northern District of Georgia, filed July 14, 2022 as Document 512 in No. 1:20-cr-00296-JPB-CMS. It asks the court to continue the sentencing hearing set for July 28, 2022 and states that the government joins the motion. The motion states that Mr. Parker pled guilty on April 14, 2022 under a plea agreement that contains a cooperation agreement, and that a brief continuance would give him time to meet with the government and the government time to assess whether to file a motion for reduction of sentence under U.S.S.G. § 5K1.1. The parties request a continuance of 21 days, and it is signed /s/ by Kamal Ghali of Bondurant Mixson & Elmore, LLP.

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#3400558v1 
IN THE UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA,
 
Plaintiff, 
 
v. 
 
 
DEREK PARKER, 
 
Defendant. 
 
 
 
 
 
CIVIL ACTION FILE NO. 
 
1:20-CR-00296-14-JPB 
            
 
DEFENDANT DEREK PARKER’S MOTION TO CONTINUE SENTENCING 
 
 
Defendant Derek Parker respectfully requests that the Court continue the 
sentencing hearing currently scheduled for July 28, 2022. The Government has 
represented that it joins in this motion.  
 
Mr. Parker pled guilty on April 14, 2022. Mr. Parker’s plea agreement 
contains a cooperation agreement. A brief continuance will provide additional 
time for Mr. Parker to meet with the Government, and for the Government to 
assess whether it would be appropriate to file a motion for reduction of sentence 
pursuant to U.S.S.G. § 5K1.1. To that end, a brief continuance would ensure that 
the any sentencing memoranda filed with the Court contains up-to-date 
information about Mr. Parker and any appropriate sentence. Therefore, the 
parties respectfully request a continuance of 21 days.   
Case 1:20-cr-00296-JPB-CMS     Document 512     Filed 07/14/22     Page 1 of 4

2 
 
 
Respectfully submitted this 14th day of July, 2022. 
 
/s/ Kamal Ghali 
 
Kamal Ghali 
Georgia Bar No. 805055 
BONDURANT MIXSON & ELMORE, LLP 
3900 One Atlantic Center 
1201 W. Peachtree Street, NW 
Atlanta, Georgia 30309 
Telephone: 
404-881-4100 
Facsimile: 
404-881-4111 
ghali@bmelaw.com 
 
 
Attorney for Defendant 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 512     Filed 07/14/22     Page 2 of 4

3 
 
CERTIFICATE OF COMPLIANCE 
Pursuant to Local Rule 7.1D of the Local Rules for the District Court for the 
Northern District of Georgia, I hereby certify that the foregoing pleading has 
been prepared in Book Antiqua, 13 point font, as permitted by Local Rule 5.1B. 
 
/s/ Kamal Ghali 
 
Kamal Ghali 
Georgia Bar No. 805055   
 
Case 1:20-cr-00296-JPB-CMS     Document 512     Filed 07/14/22     Page 3 of 4

#3400558v1 
 
CERTIFICATE OF SERVICE 
 
 
I do hereby certify that I have this day caused to be electronically filed the 
foregoing DEFENDANT’S MOTION TO CONTINUE with the Clerk of Court 
using the Court’s electronic filing system which will deliver a copy to all counsel 
of record by electronic mail.   
 
This 14th day of July, 2022. 
 
 
/s/ Kamal Ghali 
 
Kamal Ghali 
Georgia Bar No. 805055 
 
Case 1:20-cr-00296-JPB-CMS     Document 512     Filed 07/14/22     Page 4 of 4

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