Motion - United States v. Maurice Fayne related docket (Doc. 263, filed 2022-02-04)

Summary

Document 263, a three-page Motion to Continue Trial filed February 4, 2022 by Defendant Daniel Eric Jay in United States of America v. Daniel Eric Jay, No. 1:20-CR-228-2 (MHC) (JKL), Northern District of Georgia, Atlanta Division. The motion asks the Court to set or continue the trial to June 6, 2022, or a later date convenient to all the parties. It states that Mr. Jay and his counsel require additional time because of the geographic distance, the COVID-19 pandemic, the amount of discovery, the number of witnesses and the complexity of legal issues. It states that AUSA Russell Philips agrees to the continuance; the signature block names L. Burton Finlayson.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA
)
 
)
)
v.                               
)     1:20-CR-228-2 (MHC) (JKL)
)
)
DANIEL ERIC JAY
)  
____________________________
)
MOTION TO CONTINUE TRIAL
COMES NOW the Defendant, DANIEL ERIC JAY, and moves this
Honorable Court to set or continue his trial to June 6, 2022, or a later date which is
convenient to all the parties.  In support of this request, the Defendant shows as
follows:
1.
At this time, Mr. Jay and his counsel request and require additional time to
prepare for trial.  Mr. Jay lives in Pennsylvania, his counsel is in Atlanta, Georgia. 
Given the logistic and geographic distance, compounded by the COVID-19
pandemic, the amount of discovery, the number of witnesses and the complexity of
legal issues in this case, the Defendant and his counsel require and request
additional time to prepare. 
Case 1:20-cr-00228-MHC-JKL     Document 263     Filed 02/04/22     Page 1 of 3

2.
Counsel for the government, AUSA RUSSELL PHILIPS, agrees to this
continuance.
3.
The Defendant recognizes and agrees that the continuance requested
pursuant to this request serves the best ends of Justice, is in the interest of the
Defendants and the public and is excluded under the Speedy Trial Act, Title 18
U.S.C. § 3161(h).  
 
WHEREBY, DANIEL ERIC JAY requests that his trial be continued to 
June 6, 2022, or to a later date convenient to the Court and the parties.   
Dated:  This 4th day of February, 2022.
Respectfully submitted,
 
s/ L. Burton Finlayson 
L. BURTON FINLAYSON
Attorney For DANIEL JAY
Georgia Bar Number: 261460
LAW OFFICES OF
L. BURTON FINLAYSON, LLC 
931 Ponce de Leon Avenue, NE
Atlanta, Georgia 30306
(404) 872-0560
lbfcourts@aol.com
2
Case 1:20-cr-00228-MHC-JKL     Document 263     Filed 02/04/22     Page 2 of 3

CERTIFICATE OF SERVICE
This is to certify that I have this day electronically filed the foregoing
Motion to Continue with the Clerk of Court using the CM/ECF system which will
automatically send email notifications of such filing to all counsel of record
including the following:
     Mr. Russell Phillips . 
     Assistant United States Attorney
     600 U.S. Courthouse
     75 Ted Turner Drive, S. W.
     Atlanta, Georgia  30303
DATED:  This 4th day of February, 2022.
 s/ L. Burton Finlayson 
L. BURTON FINLAYSON
ATTORNEY FOR DANIEL JAY   
 State Bar Number: 261460   
  
3
Case 1:20-cr-00228-MHC-JKL     Document 263     Filed 02/04/22     Page 3 of 3

File and source

File

gov.uscourts.gand.278523.263.0.pdf

Size

69,501 bytes

SHA-256

6834d7f59a44dbd19e82a7a72560aa01c85ed83cb730c7c0c24993dea1c45877

Our copy

gov.uscourts.gand.278523.263.0.pdf

Original

PACER (login required)