Motion for Continuance of Pretrial Conference — United States v. Maurice Fayne (Dkt. 52, N.D. Ga.)

Summary

Motion for continuance of pretrial conference filed August 6, 2020 as Document 52 in United States v. Maurice Fayne (Case 1:20-cr-00228-MHC-JKL, N.D. Ga.), written and signed by the defendant as “maurice johnson fayne el,” who calls himself a Moor American National, but not Citizen of the United States. He asks the court to continue the pretrial hearing set for August 14, 2020, citing the spread of COVID-19 and the United States Attorney Office’s failure to answer his 7/28/2020 email asking for a pretrial discovery conference. He says he sent a reminder email on the 29th of July and left a voicemail, and that without discovery he cannot prepare a defense. The motion is declared under penalty of perjury and says it is made in good faith, not for delay. Its certificate of service calls the filing a “Motion to Suppress Criminal Affidavit.”

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IN THE UNITED STATES DISTRICT COURT
FILED IN CLERK’S OFFICE
NORTHERN DISTRICT OF GEORGIA
U.s.O.C.MIanta
Plaintiff,
ATLANTA DIVISION
AUG 06 zozo
I
CRIMINAL
I
CASE NO. 1:20-CR-228 M ~+C
I
CASE NOs. 1:20-MJ-370, 364,
MAURICE FAYNE,
FICTITIOUS DEFENDANT
Defendant,
361, 360,355 and 1:20-MC-833,
1:20-CR-228-MHC-JKL,
1 :20-CR-228-MHC-JKL
MOTION FOR CONTINUANCE OF PRETRIAL CONFERENCE
COMES NOW, maurice johnson fayne el, (real party in interest) a
aniyunwan Moor American National, but not Citizen of the United States,
respectfully request and move this Court that the Court’s previously-ordered
hearing set for August 14, 2020.
maurice johnson fayne el seeks to continue the Pre-trial hearing due to the
wide spread of COVID- 19 effects and the fact that a Pre-Trial discovery
conference was requested from the United Stated Attorney Office via email on
7/28/2020. A reminder email was sent on the 29Ih of July. maurice johnson fayne el
UNITED STATES OF AMERICA
V.
.,-Glerk
also called and left a voicemail requesting a Pre-Trial Discovery conference. The
Case 1:20-cr-00228-MHC-JKL     Document 52     Filed 08/06/20     Page 1 of 4

Attorney(s) from the United States Attorney Office have not responded to date.
Without receiving discovery maurice johnson fayne el cannot prepare a proper
defense of all allegations. Pursuant the Federal Rules of Criminal Procedure 16.1
and the order filed on 7/27/2020, the real party in interest has reached out to the
United States Attorney Office for a pre-trial conference and is currently awaiting a
response from the United States Attorney Office with a day, time and place to meet
to discuss possible settlement and closure of this matter. Alleged defendant
requests additional time for the UNITED STATES ATTORNEY OFFICE to
comply with Pre-Trial Discovery Conference and the issues to be addressed at that
conference before making any representations to the Court. This motion is made in
good faith and not for the purposes of delay.
I declare (or certify, verify, or state) under penalty of perjury under the laws of the
United States of America that the foregoing is true and correct
Respectfully submitted this
day of August, 2020, by:
4fa~’tt
G~ii&~
ht~ S
~i(i~~~4 é~c,u,cc/
maurice johnson fayne el
Case 1:20-cr-00228-MHC-JKL     Document 52     Filed 08/06/20     Page 2 of 4

CERTIFICATE OF SERVICE
I hereby certify that the foregoing Motion to Suppress Criminal Affidavit and all
other Evidence has been formatted in Times New Roman 14 pt., in accordance
with Local Rule 5. 1B, and was electronically filed this day with the Clerk of Court
using CMJECF system which will automatically send email notification of such
filing to the following counsel of record:
James N. Hatten Clerk of Court
Attorney John Russell Phillips
UNITED STATES DISTRICT COURT
Richard B. Russell Federal Building
NORTHERN DISTRICT OF GEORGIA
United States Attorney’s Office
Richard B. Russell Federal Building
75 Ted Turner Drive, SW #600
2211 United States Courthouse
Atlanta, Georgia 30303-3309
75 Ted Turner Drive, SW
(404) 581-6000
Atlanta, Georgia 30303-3309
Email:russell.phillips@usdoj.gov
(404) 215- 1600
Attorney Bernita Malloy
Attorney Byung J. Pak
Richard B. Russell Federal Building
Richard B. Russell Federal Building
United States Attorney’s Office
United States Attorney’s Office
75 Ted Turner Drive, SW #600
75 Ted Turner Drive, SW #600
Case 1:20-cr-00228-MHC-JKL     Document 52     Filed 08/06/20     Page 3 of 4

Atlanta, Georgia 30303-3309
Atlanta, Georgia 30303-3309
(404) 581-6000
Email: Bernita.Malloy@usdoj.gov
Attorney Michael John Brown
Richard B. Russell Federal Building
United States Attorney’s Office
75 Ted Turner Drive, SW #600
Atlanta, Georgia 30303-3309
Email: Michael.j .brown2@usdoj.gov
maurice johnson fayne-el
do 6608 N Western Avenue # 1307
Oklahoma City, Oklahoma [73116] U.S.A
770-846-1034
Email: rnauricejohnsonfayne.eltrust@gmail.com
Case 1:20-cr-00228-MHC-JKL     Document 52     Filed 08/06/20     Page 4 of 4

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