Unopposed Motion for Continuance of Pretrial Conference and Additional Time to File Motions, Dkt. 73

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A pro se unopposed motion filed August 25, 2020 in United States v. Maurice Fayne, No. 1:20-cr-00228, in the U.S. District Court for the Northern District of Georgia, Document 73, asking to continue the pretrial conference scheduled for August 27, 2020 and to extend the motions deadline of August 26, 2020. The motion states that Maurice Fayne has been indicted for wire fraud, bank fraud, money laundering and false statements to a federally insured bank, and received initial discovery only the week before. It recounts that at the August 14, 2020 status conference the government said more discovery would require a two terabyte hard drive. It asks for sixty days, with motions due on or about October 26, 2020, and states that the government does not oppose.

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FILED IN CLERK’S OFFICE
IN THE UNITED STATES DISTRICT COURT
IJ.S.D.C.
- Atlanta
NORTHERN DISTRICT OF GEORGIA
AUG 252020
ATLANTA DIVISION
JAME
IFIATTEN, CI
t-puty Clerk
UNITED STATES OF AMERICA
I
Plaintiff,
I CASE NO. 1:20-CR-00228-MHC-JKL
MAURICE FAYNE,
I
FICTITIOUS DEFENDANT
Defendant,
I
UNOPPOSED MOTION REQUESTING
CONTINUANCE OF PRETRIAL CONFERENCE AND ADDITIONAL
TIME TO FILE MOTIONS
COMES NOW, fayne, maurice johnson el, real party interest, a Moor
American National, but not a citizen of the United States, hereby respectfully
moves the Court for a continuance of the pretrial conference, currently scheduled
for August 27, 2020. Defendant also moves for extension of motions deadline
currently set for August 26, 2020. In support, real party in interest shows as
follows:
MAURICE FAYNE has been indicted on violation of wire fraud, bank
fraud, money laundering and False Statements to Federally-Insured Bank.
Defendant just received initial discovery on this case last week. At the status
Case 1:20-cr-00228-MHC-JKL     Document 73     Filed 08/25/20     Page 1 of 3

conference on August 14, 2020, the Government advised is would be producing
additional discovery, referencing the need for the alleged defendant to provide a
two (2) terabyte hard drive in order to receive the additional discovery. The real
party in interest, fayne, maurice johnson el will need time to receive discovery and
review it to assess which pre-trial motions should be filed. Additionally the
Government has noticed Defendant that it would like to keep all defendants on the
same track during the duration of the case.
In consideration of the above, the alleged Defendant respectfully requests an
extension of sixty (60) days beyond the current deadline to review this discovery
and file appropriate motions, such that motions will be due by on or about October
26, 2020, with the pretrial conference to be held later.
The Government has been consulted, and does not oppose the instant
motion.
WHERFORE, fayne, maurice johnson el, respectfully requests that the
Court extend the motions deadline for sixty (60) days and continue the pretrial
conference as requested. A proposed order is enclosed for the Court’s
consideration.
2
Case 1:20-cr-00228-MHC-JKL     Document 73     Filed 08/25/20     Page 2 of 3

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 1 OL~~ day of August, 2020, by:
fayne, mauricejohnson el, real party in interest
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.lB, and was electronically filed this day with the Clerk of Court
using CM/ECF system which will automatically send email notification of such
filing to the following counsel of record:
Russell Phillips
Office of the United States Attorney
Richard Russell Federal Building
75 Ted Turner Drive, SW #600
Atlanta, GA 30303-3309
This 25th of August 2020.
fayne, maruice johnson el
Case 1:20-cr-00228-MHC-JKL     Document 73     Filed 08/25/20     Page 3 of 3

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