Pandemic Darlings The pandemic economy, in original documents
Home Source documents Court filing — No. 4:22-cr-00016 (Dkt. 278)

Court filing — No. 4:22-cr-00016 (Dkt. 278)

Full text

     Case 4:22-cr-00016-RSB-CLR      Document 278     Filed 10/23/23   Page 1 of 3




                     UNITED STATES DISTRICT COURT
                     SOUTHERN DISTRICT OF GEORGIA
                          SAVANNAH DIVISION

UNITED STATES OF AMERICA                  )
                                          )
v.                                        )   CASE NO: 4:22-CR-016
                                          )
SHAQUANDRA WOODS and                      )
KENNETH JACKSON                           )

UNITED STATES’ MOTION TO MODIFY TRIAL DATE TO NOVEMBER 27,
                           2023

       COMES NOW the United States, by and through United States Attorney Jill

E. Steinberg, and moves the Court to begin the trial of the above-captioned case on

November 27, 2023, versus November 28, 2023.


       On February 21, 2023, the government provided defense counsel, via letter,

notice of its intent to call Alfonso Olivas, SBA Supervisory Loan Specialist, as a

witness at trial. While the government believes Mr. Olivas’ testimony to be that of a

percipient fact witness, it nevertheless provided a detailed summary of his expected

testimony, a copy of his curriculum vitae, and other information required by

Fed.R.Crim.P. 16(a)(1)(G).


       Trial of this case is currently scheduled for Tuesday, November 28, 2023. Mr.

Olivas, however, is scheduled to testify that week in the specially set trial of United

States v. Eric Dean Sheppard, No. 1:22-cr-20290 (S.D. Fla.), doc. 112. After speaking

with the Assistant U.S. Attorney trying the case in the Southern District of Florida,

undersigned counsel does not believe the Sheppard matter will be resolved with a

negotiated plea agreement. Based upon the AUSAs’ orders of proof, it appears Mr.
   Case 4:22-cr-00016-RSB-CLR        Document 278      Filed 10/23/23    Page 2 of 3




Olivas can be available to testify in both trials if the Court begins the above-captioned

trial on Monday, November 27, 2023.


      Therefore, the government respectfully requests the Court to reschedule the

trial of this matter to begin at 9:00 a.m. on November 27, 2023. Defense counsel does

not join in this motion.


      Respectfully submitted, this 23rd day of October 2023.



                                         JILL E. STEINBERG
                                         UNITED STATES ATTORNEY

                                         /s/ Jennifer G. Solari
                                         Jennifer G. Solari
                                         Assistant United States Attorney
                                         Senior Litigation Counsel
                                         Washington, DC Bar No. 987167

                                         /s/ Ryan C. Grover
                                         Ryan C. Grover
                                         Assistant United States Attorney
                                         South Carolina Bar No. 101218

22 Barnard Street, Suite 300
Savannah, Georgia 31412
Telephone: (912) 652-4422
Facsimile: (912) 652-4991
Email: jennifer.solari@usdoj.gov
Email: ryan.grover@usdoj.gov
   Case 4:22-cr-00016-RSB-CLR         Document 278     Filed 10/23/23   Page 3 of 3




                            CERTIFICATE OF SERVICE

       This is to certify that I have on this day served all the parties in this case in

accordance with the notice of electronic filing (ANEF@) which was generated as a result

of electronic filing in this Court.

       This 23rd day of October 2023.

                                        Respectfully submitted,

                                        JILL E. STEINBERG
                                        UNITED STATES ATTORNEY

                                        /s/ Jennifer G. Solari
                                        Jennifer G. Solari
                                        Assistant United States Attorney


File and source

File
278.pdf
Size
116,544 bytes
SHA-256
7610812dd02d9b20521d59d33a77b6850fa147ea93a41080bde38634b248cb43
Our copy
278.pdf
Original
No public link identified.
Back to top