Motion to Continue Sentencing Hearing by Derek Parker — USA v. Thomas et al. (Dkt. 528, N.D. Ga.)

Summary

Defendant Derek Parker's motion to continue sentencing in United States of America v. Derek Parker, No. 1:20-cr-00296-JPB-CMS, in the U.S. District Court for the Northern District of Georgia, Atlanta Division, filed August 17, 2022 as Document 528. The motion asks to continue the sentencing hearing scheduled for August 31, 2022 and states that the Government consents. Defense counsel states that he is lead counsel in a federal trial set for August 29, 2022 in the Middle District of Georgia, United States v. Ceddrick Mercery, expected to last through at least August 31, 2022, and asks for sentencing during the week of September 19 or later. It is signed by Kamal Ghali of Bondurant Mixson & Elmore, LLP.

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#3411122v1 
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 August 31, 2022. The Government 
has represented that it consents to this motion.  
 
Undersigned counsel is lead counsel (appointed) in a federal trial set for 
August 29, 2022 in the U.S. District Court for the Middle District of Georgia. See 
United States v. Ceddrick Mercery, 3-21-CR—009 (CAR). The trial is expected to last 
through at least August 31, 2022. Undersigned counsel respectfully requests that 
the Court continue the sentencing for anytime during the week of September 19 
or later.  
 
 
Case 1:20-cr-00296-JPB-CMS     Document 528     Filed 08/17/22     Page 1 of 4

 
2 
 
#3411122v1 
 
  
Respectfully submitted this 17th day of August, 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 528     Filed 08/17/22     Page 2 of 4

 
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#3411122v1 
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 528     Filed 08/17/22     Page 3 of 4

 
#3411122v1 
 
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 17th day of August, 2022. 
 
 
/s/ Kamal Ghali 
 
Kamal Ghali 
Georgia Bar No. 805055 
 
Case 1:20-cr-00296-JPB-CMS     Document 528     Filed 08/17/22     Page 4 of 4

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