Second Motion for Extension of Time to October 20, 2023 to File Objections — USA v. Harun (Dkt. 26, S.D. Ga.)

Record facts

U.S. District Court for the Southern District of Georgia · No. 3:23-cr-00003-DHB-BKE · Doc. 26 · 2023-10-02 · Docket on CourtListener

Full text

1 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF GEORGIA 
DUBLIN DIVISION  
 
UNITED STATES OF AMERICA,  
 
] 
 
 
 
 
 
 
 
 
] 
 v. 
 
 
 
 
 
 
] 
 
 
 
 
 
 
 
]     
CASE NO. 3:23-CR-3 
GLADYS WANJIKU HARUN 
 
 
]  
 
 
 
 
 
 
 
] 
  
 
  
SECOND 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 October 20, 2023 to submit his objections to the PSR.   
1. 
Counsel was appointed on September 19, 2023 and obtained the 
Defendant’s PSR on September 20, 2023. 
2. 
The Honorable Court granted Defendant’s first motion, setting the new 
date to October 6, 2023. 
4.  
The Defense recently received the discovery and is currently reviewing to 
better prepare for objections. 
5.  
Counsel for Defendant has municipal judges’ training from October 4, 2023 
until October 6, 2023. 
6. 
The Government does not oppose the motion.   
7. 
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 
Case 3:23-cr-00003-DHB-BKE     Document 26     Filed 10/02/23     Page 1 of 3

2 
 
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 he be granted through and until October 20, 2023 to 
submit all objections Defendant may have to the PSR. 
 
This 3rd day of October, 2023. 
 
 
 
 
 
      
 
s/ Johnny E.C. Vines 
 
 
 
 
 
 
 
 
    
 
Johnny E.C. Vines 
 
 
 
 
 
      
 
GA Bar No. 940633 
 
 
 
 
 
      
 
Attorney for Defendant  
 
Johnny Vines, P.C.  
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 26     Filed 10/02/23     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 Second 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 3rd day of October, 2023. 
 
 
 
 
 
      
 
s/ Johnny E.C. Vines 
 
 
 
 
 
 
 
 
    
 
Johnny E.C. Vines 
 
 
 
 
 
      
 
GA Bar No. 940633 
 
 
 
 
 
      
 
Attorney for Defendant  
 
Johnny Vines, P.C.  
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 26     Filed 10/02/23     Page 3 of 3

File and source

File

gov.uscourts.gasd.89545.26.0.pdf

Size

104,841 bytes

SHA-256

f581e56e79779f3849994285e8c9fd539f75545888990414739e28be39894719

Our copy

gov.uscourts.gasd.89545.26.0.pdf

Original

PACER (login required)