Motion for Extension of Time to October 1, 2023 by Johnny Emmett Clyde Vines — USA v. Harun (Dkt. 24, S.D. Ga.)

Summary

Motion to Extend Time for Defense to Submit Written Objections to Presentence Investigation Report, Document 24, filed 09/20/23 by Gladys W. Harun in United States of America v. Gladys Wanjiku Harun, Case No. 3:23-CR-3 (S.D. Ga., Dublin Division). The motion says counsel was appointed on September 19, 2023 and obtained access to the PSR on September 20, 2023, and that prior counsel filed timely objections on July 27, 2023 but current counsel requests to file additional objections. It says the motion is not filed for the purpose of delay and cites counsel's obligations under the Criminal Justice Act. The text asks for time through and until November 1, 2023, in one place and through and until October 1, 2023 in the closing request. Johnny E.C. Vines signs with s/ for the defendant.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF GEORGIA 
DUBLIN DIVISION  
 
UNITED STATES OF AMERICA,  
 
] 
 
 
 
 
 
 
 
 
] 
 v. 
 
 
 
 
 
 
] 
 
 
 
 
 
 
 
]     
CASE NO. 3:23-CR-3 
GLADYS WANJIKU HARUN 
 
 
]  
 
 
 
 
 
 
 
] 
  
 
  
MOTION TO EXTEND TIME FOR DEFENSE TO SUBMIT  
WRITTEN OBJECTIONS TO PRESENTENCE INVESTIGATION REPORT 
 
 
Comes now GLADYS W. HARUN and hereby moves this Honorable Court to 
extend the time for her to submit written objections to the initial draft of the presentence 
investigation report (PSR).  For the reasons set forth below, Defendant requests that she 
has through and until November 1, 2023 to submit his objections to the PSR.   
1. 
Counsel was appointed on September 19, 2023 and obtained access to 
Defendant’s PSR on September 20, 2023. 
2. 
Prior counsel filed timely objections to the PSI on July 27, 2023, but current 
counsel requests to file additional objections.  
3. 
Moreover, this motion is not interposed for the purpose of delay, but 
instead it is filed to assist counsel in continuing to provide Defendant with 
a meaningful defense, consistent with counsel’s obligations to this Court 
under the Criminal Justice Act. 
 
Wherefore, Defendant having shown good cause to support the relief requested 
herein, she respectfully requests that she be granted through and until October 1, 2023, 
to submit all amended objections Defendant may have to the PSR. 
Case 3:23-cr-00003-DHB-BKE     Document 24     Filed 09/20/23     Page 1 of 3

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This 20th day of September, 2023. 
 
 
 
 
 
      
 
s/ Johnny E.C. Vines 
 
 
 
 
 
 
 
 
    
 
Johnny E.C. Vines 
 
 
 
 
 
      
 
GA Bar No. 940633 
 
 
 
 
 
      
 
Attorney for Defendant   
 
Law Office of Johnny Vines 
P.O. Box 1422 
Metter, Georgia 30439 
(o) 912.388.7071 
(f)  912.537.6600 
Email: jecvines@vineslaw.com  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 3:23-cr-00003-DHB-BKE     Document 24     Filed 09/20/23     Page 2 of 3

3 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF GEORGIA 
DUBLIN DIVISION  
 
UNITED STATES OF AMERICA,  
 
] 
 
 
 
 
 
 
 
 
] 
 v. 
 
 
 
 
 
 
] 
 
 
 
 
 
 
 
]     
CASE NO. 3:23-CR-3 
GLADYS WANJIKU HARUN 
 
 
]  
 
 
 
 
 
 
 
] 
  
CERTIFICATE OF SERVICE 
 
 
This is to certify that I have on this day served all parties in this case with the 
attached Motion to Extend Time for Defendant to Submit Written Objections to 
Presentence Investigation Report in accordance with the directives from the Court Notice 
of Electronic Filing (“NEF”) which was generated as a result of this electronic filing. 
 
This 20th day of September, 2023. 
 
 
 
 
 
      
 
s/ Johnny E.C. Vines 
 
 
 
 
 
 
 
 
    
 
Johnny E.C. Vines 
 
 
 
 
 
      
 
GA Bar No. 940633 
 
 
 
 
 
      
 
Attorney for Clarence Johnson  
 
Law Office of Johnny Vines 
P.O. Box 1422 
Metter, Georgia 30439 
(o) 912.388.7071 
(f)  912.537.6600 
Email: jecvines@vineslaw.com  
 
 
 
Case 3:23-cr-00003-DHB-BKE     Document 24     Filed 09/20/23     Page 3 of 3

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