Court filing
Information - United States v. Maurice Fayne related docket
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2020-08-21 |
U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00228-MHC-JKL · Doc. 67 · 2020-08-21 · Docket on CourtListener
Summary
Defendant Daniel Eric Jay's unopposed motion for continuance in United States of America v. Daniel Eric Jay, No. 1:20-cr-00228-MHC-JKL, in the U.S. District Court for the Northern District of Georgia, filed August 21, 2020 as Doc. 67. It asks the Court to continue the August 27, 2020 pretrial conference until at least October 29, 2020, and states that government counsel does not object. The motion states that the government produced 20,409 pages of discovery on August 11, 2020 but has not yet produced all Rule 16 materials, and that counsel must confirm whether search warrant applications for Mr. Jay's email accounts were produced. A footnote describes a 1 terabyte hard drive sent to the U.S. Attorney's Office, received August 17, 2020, for images of Fayne's phones and computer. The three-page motion is signed by appointed counsel Kamal Ghali.
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Full text
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERICA v. DANIEL ERIC JAY Criminal Action No. 1:20-CR-228-MHC-JKL DEFENDANT JAY’S UNOPPOSED MOTION FOR CONTINUANCE Defendant Daniel Eric Jay respectfully requests that this Court continue the August 27, 2020 pretrial conference for 60 days. Discovery is voluminous. And Mr. Jay’s appointed counsel needs more time to review the discovery before he can file pretrial motions. Government’s counsel does not object to a continuance. Although the Government produced 20,409 pages of discovery on August 11, 2020, it has not yet produced all Rule 16 materials.1 Given the volume of discovery and the fact that he has not yet received all Rule 16 materials, Mr. Jay’s counsel asked the Government to consent to a 60-day continuance of the pretrial conference. He needs that time to finish going through the thousands of pages of discovery, to review discovery that has not yet been produced, and to assess whether it is appropriate to file pretrial motions. 1 On August 11, 2020, the Government directed Mr. Jay to send a hard drive capable of storing 1 terabyte of data for the purpose of obtaining images of Fayne’s phones, Fayne’s computer, and other digital media. Mr. Jay’s appointed counsel ordered the hard drive and shipped it to the U.S. Attorney’s Office. According to FedEx tracking, the U.S. Attorney’s Office received it on August 17, 2020. Defense counsel anticipates receiving the drive soon. A preliminary review of the produced discovery appears to indicate that Mr. Jay has not yet received certain other materials necessary to determine whether a motion to suppress is appropriate, namely, the applications for search warrants relating to his email accounts. Additional time will permit defense counsel to confirm whether this information has been produced, and if not, to obtain it from the Government. Case 1:20-cr-00228-MHC-JKL Document 67 Filed 08/21/20 Page 1 of 3 2 Counsel for the Government represented that it does not object to this request. Therefore, Mr. Jay respectfully requests that the Court continue the pretrial conference until at least October 29, 2020. This 21st day of August, 2020. /s/ Kamal Ghali Kamal Ghali Georgia Bar No. 805055 ghali@bmelaw.com BONDURANT, MIXSON & ELMORE, LLP 1201 West Peachtree Street, N.W., Suite 3900 Atlanta, Georgia 30309 (404) 881-4100 – Telephone (404) 881-4111 – Facsimile Case 1:20-cr-00228-MHC-JKL Document 67 Filed 08/21/20 Page 2 of 3 3 CERTIFICATE OF SERVICE I hereby certify that this 21st day of August, 2020, a copy of the foregoing UNOPPSED MOTION FOR CONTINUANCE was electronically filed with the Clerk of the Court and copies sent to all counsel of record via the ECMF system. /s/ Kamal Ghali Kamal Ghali Georgia Bar No. 805055 ghali@bmelaw.com Case 1:20-cr-00228-MHC-JKL Document 67 Filed 08/21/20 Page 3 of 3
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