Motion for Extension of Time to File Motion to Vacate, Set Aside — USA v. Harun (Dkt. 49, S.D. Ga.)

Record facts

U.S. District Court for the Southern District of Georgia · No. 3:23-cr-00003-DHB-BKE · Doc. 49 · 2024-12-31 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
DUBLIN DIVISION
U.S DISTRICT OOURT
SOUTHERN DISTRICT OF QEORQIA
DEC 3 1 2024
GLADYS HARUN
PETITIONER
V.
UNITED STATES OF AMERICA
RESPONDENT
PILED
Case No: 3"•
PETITIONER'S MOTION FOR EXTENSION OF TIME TO FILE HER MOTION
TO VACATE, SET ASIDE, OR CORRECT SENTENCE, PURSUANT TO 28U.S.C
2255
Comes now petitioner Gladys Harun in pro se, in necessity,
and hereby moves this honorable court to issue an order granting
a ninety (90) day extension of time to file her motion to vacate,
set aside, or correct sentence pursuant to 28 U.S.C 2255.
Petitioner previously requested the court to appoint counsel for
her; a request that the court denied in June 2024. Petitioner had since
changed her mind and was not going to file a 2255 but this week^
she has become aware that her conviction and sentence was 
:
obtained under a constitutional violation that resulted in the
fundamental miscarriage of Justice and/or incarceration of an actually
innocent defendant. In support, the petitioner shows the court
the following:
1. ) 
Petitioner's A.E.D.P.A( Antiterrorism and Effective
Death Penalty Act of 1996) deadline has not yet been
reached but rapidly approaches.
Petitioner just discovered a constitutional violation in the
criminal process that produced her conviction/sentence and wishes
to file her request for relief, in GOOD FAITH, pursuant to
Case 3:23-cr-00003-DHB-BKE     Document 49     Filed 12/31/24     Page 1 of 3

28 U.S.C. 2255.
Petitioner currently has no othar choice but to represent herself
pro se, in necessity. Petitioner has no training in law and needs
additional time to research her recent discovery.
Petitioner has access to a limited law library as it
contains 6 computers to facilitate 650 inmates here at Alderson
prison camp. What's more, after waiting her turn, petitioner
is limited to ONLY two hours to research and then must wait her
turn again.
This motion is made in good.ifaith, in the Interest of Justice,
and not meant to delay the proceedings. The United States nor
any other adverse party will be prejudiced by a ninety(90)
days delay.
Wherefore now, above premises considered, petitioner
respectfully MOVES this honorable court to grant her a ninety
(90) day extension 
of time to file her 28 U.S.C 2255 motion.
Done ithis on 12/20/2024
Respectfully Submitted,
Gladys Harun
FED No: 09407510
DORM: B1
Address: One Glen Ray Rd
Box A,
Alderson WV 24910
Signed-
pro se petitioner
Case 3:23-cr-00003-DHB-BKE     Document 49     Filed 12/31/24     Page 2 of 3

Gj^ac^ Haru.A
pruu^ CA^-p
Q(\€, GiJLft. 
ftjJL i2p?c A
pacVert'*'^ 
su^c^vO.
PLACE ST1CK6B AT TOP OF ENVELOPE TO THE RISHT
OF THE RETURN ADDRESS. FOLD AT DOTTED LIN^ ^
"'certTfiedMil'
Retail
7D2E 333D UUUU b2S3 SU^^
30S01
RDC99
U.S. POSTAGE PAID
FCM LETTER
ALDERSON, WV 2491
DEC 26, 2024
R2305K140697-10
c.09407-510--^^
'Jnitecj St.ytes Court
'?00 Jatnes. B'own BLVD
;"3Uthe''n District
Auousia, OA 30901
..Jnited States
-00003-DHB-BKE     Document 49     Filed 12/31/24

File and source

File

gov.uscourts.gasd.89545.49.0.pdf

Size

266,300 bytes

SHA-256

b12b6879c79208771bb0815e782204f719d34f591b0b8f08dd778aed68019bf9

Our copy

gov.uscourts.gasd.89545.49.0.pdf

Original

PACER (login required)