Case 1:21-cr-00064-JPB-AJB Document 12 Filed 03/06/21 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA :
: CRIMINAL CASE
v. :
: No. 1:21-CR-64 (JPB)(AJB)
YUN JAE MOON :
_______________________________:
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE PRETRIAL MOTIONS
AND TO CONTINUE PRETRIAL CONFERENCE
Comes now, YUN JAE MOON, Defendant in the above-styled action, by
and through undersigned counsel, and moves this Court to grant an extension of
time to file pretrial motions and to continue the pretrial conference currently
scheduled for March 9, 2021. In support of this motion, Mr. Moon shows as
follows:
(1)
Mr. Moon is the lone defendant named in a single count indictment charging
him with conspiracy against the United States in violation of 18 U.S.C. § 371.
(2)
On February 19, 2021, Mr. Moon was arraigned on the indictment.
Case 1:21-cr-00064-JPB-AJB Document 12 Filed 03/06/21 Page 2 of 4
(3)
On February 24, 2021, this Court entered a pretrial scheduling order calling
for motions to be filed by March 8, 2021, and a pretrial conference on March 9,
2021.
(4)
The discovery in this case is voluminous.
(5)
The government has provided some of the discovery and has made the
remainder available to undersigned counsel.
(6)
Counsel cannot determine what motions must be submitted until he has
reviewed all of the discovery.
(7)
Counsel believes he can have the discovery reviewed and motions filed in
thirty days.
(8)
Mr. Moon requests this Court extend the time for filing pretrial motions until
April 8, 2021, and thereafter schedule a pretrial conference.
Case 1:21-cr-00064-JPB-AJB Document 12 Filed 03/06/21 Page 3 of 4
(9)
Counsel for the government, Thomas Krepp, has been contacted and does
not oppose this Motion.
WHEREFORE, this Court should grant an extension of time to file pretrial
motions and continue the pretrial conference currently scheduled for March 9,
2021.
Dated, this the 6th day of March, 2021.
Respectfully submitted,
/s/Jeffrey L. Ertel
JEFFREY L. ERTEL
State Bar No. 249966
Federal Defender Program, Inc.
101 Marietta Street, Suite 1500
Atlanta, GA 30303
(404) 688-7530
Jeff_ertel@fd.org
COUNSEL FOR MR. MOON
Case 1:21-cr-00064-JPB-AJB Document 12 Filed 03/06/21 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that the foregoing has, pursuant to Local Rule 5.1, has been
formatted in Times New Roman, 14 Point, electronically filed and served upon
counsel:
Thomas Krepp, Esq.
Assistant United States Attorney
600 Richard B. Russell Building
75 Ted Turner Drive, S. W.
Atlanta, Georgia 30303
Dated, this the 6th day of March, 2021.
s/Jeffrey L. Ertel