Motion for Extension of Time to File Objections as to 77 Report and Recommendations — USA v. Harun (Dkt. 79, S.D. Ga.)

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Case 3:23-cr-00003-DHB-BKE Document 79 Filed 05/11/26 Page 1 of 5
FILED
U.S[illegible]STRICT COURT
[illegible] DIV.
2026 [illegible] 11 A 10:45
CLER[illegible] [handwritten: [illegible]]
[illegible] DIST. [illegible]F [illegible]A.
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA
DUBLIN DIVISION
GLADYS HARUN
Petitioner CASE NO. 3:23-cr-00003-DHB-BKE
UNITED STATES OF AMERICA
Respondent
MOTION FOR EXTENSION OF TIME TO FILE OBJECTIONS TO MAGISTRATE
JUDGE'S REPORT AND RECOMMENDATION
TO THE HONORABLE COURT:
Petitioner Gladys Harun, proceeding pro se, respectfully moves this Court for an extension of
time pursuant to Federal Rule of Civil Procedure 6(b) and the Court's inherent authority to
file objections to Magistrate Judge Brian K. Epps' Report and Recommendation issued on
April 30, 2026. Petitioner requests that the Court extend the current deadline of
May 18, 2026, by an additional sixty (60) days to July 17, 2026.
In support of this motion, Petitioner states as follows:
1. The Magistrate Judge issued a Report and Recommendation on April 30, 2026,
recommending dismissal of Petitioner's 28 U.S.C. § 2255 motion. The Report states
that objections must be filed by May 18, 2026.
2. Petitioner respectfully requests additional time to:
a. Seek and obtain appointment of counsel to assist in filing proper objections;
b. Prepare comprehensive objections addressing the legal and factual findings in
the Report and Recommendation; and
Case 3:23-cr-00003-DHB-BKE Document 79 Filed 05/11/26 Page 2 of 5
c. Ensure meaningful appellate review is preserved.
3. Under Federal Rule of Civil Procedure 6(b)(1)(A), a court may, for "good cause,"
extend the time to act when the request is made before the original deadline expires.
Good cause exists in this case because:
a. The Report and Recommendation addresses a 73-page motion to supplement
the record with extensive documentary evidence and a 52-page § 2255 petition
raising multiple cognizable claims;
b. Petitioner is currently Pro se and lacks the legal training necessary to
adequately address the complex legal issues raised in the Report and
Recommendation.
c. Petitioner need to locate counsel to assist with this matter, given the
complexity of the legal issues and the need to properly preserve issues for
appellate review;
d. The matters at issue involve significant liberty interests and substantial claims
concerning Petitioner's conviction and sentence, warranting careful and
thorough consideration; and
e. The interests of justice require that Petitioner have meaningful opportunity to
obtain counsel and prepare adequate objections.
4. The Eleventh Circuit has recognized that "judicial efficiency and the interests of
justice" are served when courts grant reasonable extensions to allow parties to obtain
counsel. See United States v. Lewis, 991 F.2d 524 (11th Cir. 1993).
5. Granting this extension will not prejudice the Government, as the additional time
requested is reasonable and necessary to ensure fair consideration of Petitioner's
claims.
Case 3:23-cr-00003-DHB-BKE Document 79 Filed 05/11/26 Page 3 of 5
6. Failure to grant this extension may result in the Report and Recommendation
becoming the opinion and order of the Court without adequate consideration of
Petitioner's objections, potentially affecting her substantial rights.
7. Petitioner respectfully requests that the Court grant this motion and extend the
deadline for filing objections to the Magistrate Judge's Report and Recommendation
from May 18, 2026, to July 17, 2026.
WHEREFORE, Petitioner respectfully requests that this Court:
1. Grant this Motion for Extension of Time;
2. Extend the deadline for filing objections to the Magistrate Judge's Report and
Recommendation to July 17, 2026; and
3. Grant such other and further relief as the Court deems just and proper.
Respectfully submitted this [handwritten: 4] day of [handwritten: May], 2026.
[signature]
Case 3:23-cr-00003-DHB-BKE Document 79 Filed 05/11/26 Page 4 of 5
Gladys Harun, Pro Se
192 Amelia Dr
Byron Ga, 31008
Tel 4785504123
05/05/2026
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the foregoing Motion for Extension of Time
upon the United States Attorney's Office for the Southern District of Georgia by mailing a
copy to:
United States Attorney's Office Southern District of Georgia
Assistant United States Attorney
United States Attorney's Office
P.O. Box 8970
Savannah, GA 31412
Gladys Harun
[signature]
Case 3:23-cr-00003-DHB-BKE Document 79 Filed 05/11/26 Page 5 of 5
UNITED STATES [illegible]CE®
PRIORITY® MAIL
UNITED STATES POSTAL SERVICE Retail
P
US POSTAGE PAID
$12.90
Origin: 31008
05/05/26
1212760008-07
PRIORITY MAIL®
0 Lb 2.10 Oz
RDC 03
EXPECTED DELIVERY DAY: 05/09/26
B005
SHIP
TO:
PO BOX 8286
SAVANNAH GA 31412-8286
USPS TRACKING® #
9505 5117 3067 6125 1329 64
FLAT [illegible]
ONE RATE [illegible]
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EP14F October 2023
OD: 12 1/2 x 9 1/2
PRIORITY
MAIL
UNITED STATES POSTAL SERVICE®
VISIT US AT USPS.COM
ORDER FREE SUPPLIES ONLINE
FROM:
[handwritten: Gladys Harun
192 Amelia Dr
Byron GA 31008]
TO:
[handwritten: Clerk US District Court
Post office Box 8286
Savannah GA 31412]
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Label 228, March 2016 FOR DOMESTIC AND INTERNATIONAL USE
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