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Case 4:22-cr-00016-RSB-CLR Document 189 Filed 05/01/23 Page 1 of 6
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA )
)
v. ) CASE NO: 4:22-CR-016
)
SHAQUANDRA WOODS, )
COURTNEY GILCHRIST, and )
KENNETH JACKSON )
UNITED STATES’ OPPOSITION TO DEFENDANT WOODS’
OBJECTION TO ORDER AND MOTION TO RESCIND ORDER AND
ALLOW HEARING ON MOTIONS AS PREVIOUSLY REQUESTED
The United States opposes Defendant Shaquandra Woods’ Objection to Order
and Motion to Rescind Order and Allow Hearing on Motions as Previously Requested
(the “Motion”). See (Doc. 188.) The Motion misstates the record and should be denied.
On February 21, 2023, Defendant Woods filed a Motion for Extension of Time.
(Doc. 163.) On February 27, 2023, the Government filed its response, opposing a
continuance of more than 30 days. (Doc. 168.) On March 10, 2023, the Court issued
its Second Amended Scheduling and Discovery Order. (Doc. 170.) The Second
Amended Scheduling and Discovery Order extended the Pretrial Motions deadline to
March 23, 2023, and set April 20, 2023 as the deadline to submit a Status Report if
any pretrial motions were filed. (Id.) The Second Amended Scheduling and Discovery
Order explicitly stated that “to the extent Woods’ motion might be seeking any
additional relief, other than the already granted extension of time, that request is
DENIED, IN PART, with leave to refile.” (Id. at 2.) As a result, following the Second
Amended Scheduling and Discovery Order, Defendant Woods had no pending
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motions.
On March 10, 2023, Defendant Woods filed her Notice of Intent to Offer-Self-
Authenticating Records Pursuant to F.R.E. 902 (the “Notice”). (Doc. 171.) On March
23, 2023, the Government moved in limine to exclude certain of Woods’ self-
authenticating records (the “Motion in Limine”). (Doc. 177.) Responses to the
Government’s motion were due April 6, 2023. See (Docket Text, Doc. 177.)
On April 20, 2023, Defendant Woods emailed the parties regarding her
positions on the status of the case. See (Doc. 188-1, at 4.) Defendant Woods noted her
position that there was Brady material that was still outstanding. (Id.) Defendant
Woods also indicated in response to the Notice and Motion in Limine that she
“request[ed] a full hearing on both motions.” (Id.) Because the only motion pending
as of April 20, 2023 was the Motion in Limine, the Government reasonably construed
Defendant Woods’ request for hearing to refer to the Notice and Motion in Limine.
Accordingly, the Status Report filed April 20, 2023, noted Defendant Woods’ request
for hearing on the Motion in Limine. (Doc. 178.) The Status Report also noted that
Defendant Woods took the position that Brady material remained outstanding. (Doc.
178.)
On April 21, 2023, the Court emailed all parties, notifying them that one
motion was pending and requesting that the parties file a Joint Status Report. , The
same day, the Government emailed all defendants regarding their positions for the
Court’s Joint Status Report form. In so doing, the Government notified Defendant
Woods that “there was neither a Motion for Brady Material nor a motion to
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admit/authenticate any documents filed.” (Doc. 188-1, at 7.) The Government further
explained that “the Court’s earlier ruling stated that it would not construe the
language in the Motion to Continue as an additional motion for discovery” and
“invited defense to file a separate motion if desired.” (Id.) Because “[n]one was filed,”
the Government explained that “there is only one motion pending and it is the
government’s Motion in Limine at Doc. 177.” (Id.) Finally, the Government explained
that “[t]he Court has asked that we submit the joint status report on the form
provided instead of a narrative report, so we will not be able to include the language”
that Defendant Woods requested. (Id.)
Later that afternoon, the Government emailed Defendant Woods’ counsel with
a draft of the Joint Status Report. See (Ex. A.) The Government requested that
counsel review the filing and asked whether the Government could file and add
counsel’s e-signature. The Government received no response, and filed the Joint
Status Report without the e-signature of counsel for Defendant Woods. (Doc. 181.)
The Joint Status Report noted Defendant Woods’ position that additional time for
plea negotiation would be necessary after receiving additional Brady material. (Id.)
Defendant Woods’ Motion argues that the Court’s April 26, 2023 Order should
be “rescinded” because Defendant Woods requested a hearing on the Government’s
Motion in Limine, and such request was omitted from the Joint Status Report filed
April 21, 2023. (Doc. 188 at 1-2.) Defendant Woods contends that because she offered
the self-authenticating records as admissible, and the Government moved to exclude
them as inadmissible, that the Government’s Motion in Limine was opposed. (Doc.
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188 at 3.)
Defendant Woods’ Motion should be denied. As of the date of the April 21, 2023
Status Report, the only motion pending before the Court was the Government’s
Motion in Limine. Notably, the Government’s Motion in Limine sought to exclude
documents under Federal Rule of Evidence 403, not Rule 902(5). (Doc. 177.)
Defendant Woods filed no opposition to the Government’s Motion in Limine, which
the Court considered in its April 26, 2023 Order. However, the Court also explained
that the Government’s Motion in Limine was “well-supported and reasoned,” (Doc.
184 at 4), and Woods’ instant Motion still does not explain why the documents she
noticed should not be excluded under Rule 403.
Finally, to the extent that Woods implies that the Government intentionally
omitted her request for a hearing on a Brady motion, Woods does not point to a motion
that was pending as of either the April 20, 2023 Status Report or the April 21, 2023
Joint Status Report. The Government reasonably interpreted Defendant Woods’
request for hearing to refer to the Notice and the Motion in Limine, not the Motion
for Extension of Time that the Court denied in part in its Second Amended Scheduling
and Discovery Order. As a result, the Government noted Woods’ request for hearing
on the Motion in Limine in the April 20, 2023 Status Report. (Doc. 178.) However,
when the Court requested that the parties file the Joint Status Report, the
Government indicated that no hearing was requested on the April 21, 2023 Joint
Status Report because no opposition was filed to the Motion in Limine. (Doc. 181.)
Accordingly, the Government respectfully requests that Defendant Woods’
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Motion be denied.
Respectfully submitted, this 1st day of May 2023.
JILL E. STEINBERG
UNITED STATES ATTORNEY
/s/ Jennifer G. Solari
Jennifer G. Solari
Assistant United States Attorney
Senior Litigation Counsel
/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 189 Filed 05/01/23 Page 6 of 6
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 1st day of May 2023.
Respectfully submitted,
JILL E. STEINBERG
UNITED STATES ATTORNEY
/s/ Ryan C. Grover
Ryan C. Grover
Assistant United States Attorney