Indictment — United States v. Maurice Fayne (Dkt. 150, N.D. Ga. No. 1:20-cr-00228)

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
 
) 
)  
 
v.  
 
 
 
 
 
 
) 
CASE NOS.: 
)  
MARK SARGENT and  
 
 
) 
1:20-cr-228-MHC-JKL-4 
MICHAEL SARGENT,  
 
 
) 
1:20-cr-228-MHC-JKL-3 
 
 
 
 
 
 
 
) 
Defendants.   
 
 
 
) 
____________________________________) 
 
UNOPPOSED MOTION TO CONTINUE PRETRIAL CONFERENCE 
 
 
MARK SARGENT and MICHAEL SARGENT, by and through 
undersigned counsel, hereby file this Unopposed Motion to Continue Pretrial 
Conference.  In support hereof, Defendants state as follows: 
1. 
On November 19, 2020, a grand jury sitting in the Northern 
District of Georgia returned a superseding indictment charging both 
Defendants with one count each of conspiracy to commit wire fraud in 
violation of 18 U.S.C. § 1349 and three counts each of wire fraud in violation 
of 18 U.S.C. § 1343. (Doc. 96). 
2. 
Defendants pleaded not guilty to the charges on January 27, 
2021. (Docs. 146 and 147). 
3. 
On January 29, 2021, the Court entered a pretrial scheduling 
order and set the pretrial conference for February 11, 2021. (Doc. 149). 

 
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4. 
Undersigned counsel recently received the discovery in the case.  
The discovery is comprised of over 300 GB of data.  Defendants request the 
Court continue the pretrial conference for at least sixty days to allow 
Defendants (who reside in Dallas, Texas) the opportunity to thoroughly 
review the discovery with Counsel and consider pretrial motions.  The ends 
of justice served by taking such action outweigh the best interest of the public 
and the defendant in a speedy trial and failure to grant a continuance would 
deny counsel for Defendants the reasonable time necessary for effective 
preparation, taking into account the exercise of due diligence.  Moreover, 
undersigned counsel requests that the Clerk be directed to exclude the 
additional time pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv). 
5. 
The Government does not object to this Court’s granting this 
motion. 
 
WHEREFORE MARK SARGENT and MICHAEL SARGENT 
request that this motion be granted and the pretrial conference be continued 
for at least sixty days. 
 
 

 
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Respectfully submitted this 2nd day of February, 2021. 
 
/s/ Mark A. Campbell                          
 
Mark A. Campbell 
3300 Hamilton Mill Road 
Suite 102-124 
(404) 345-2593 
mcampbell.atty@gmail.com 
 
 
 
 
 
Georgia Bar No. 384028 
 
 
 
 
 
 
 
 
 
/s/ Sandra L. Michaels                          
 
Sandra L. Michaels 
965 Virginia Avenue NE  
Atlanta, GA 30306  
404-312-5781  
SLMichaelsLaw@gmail.com 
 
 
 
 
 
 
Georgia Bar No. 504014  
 

 
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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
 
) 
)  
 
v.  
 
 
 
 
 
 
) 
CASE NOS.: 
)  
MARK SARGENT and  
 
 
) 
1:20-cr-228-MHC-JKL-4 
MICHAEL SARGENT,  
 
 
) 
1:20-cr-228-MHC-JKL-3 
 
 
 
 
 
 
 
) 
Defendants.   
 
 
 
) 
____________________________________) 
 
CERTIFICATE OF SERVICE 
 
 
I HEREBY CERTIFY that a copy of the foregoing was formatted in 
14-point Times New Roman font in compliance with Local Rule 5.1B and 
was electronically filed this day with the Clerk of Court using the CM/ECF 
system which will automatically send email notification of such filing to all 
parties of record. 
Respectfully submitted this 2nd day of February, 2021. 
 
 
 
 
 
 
 
 
/s/ Mark A. Campbell                          
 
 
 
 
 
 
Mark A. Campbell 
 
s/ Sandra L. Michaels                          
 
Sandra L. Michaels

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