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Home Source documents Court filing — S.D. Ga. No. 4:22-cr-00016 (Dkt. 189-1)

Court filing — S.D. Ga. No. 4:22-cr-00016 (Dkt. 189-1)

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Case 4:22-cr-00016-RSB-CLR   Document 189-1   Filed 05/01/23   Page 1 of 4




                 EXHIBIT A
 Case 4:22-cr-00016-RSB-CLR                      Document 189-1          Filed 05/01/23   Page 2 of 4


From:            Solari, Jennifer (USAGAS)
To:              Jacque Hawk; Charlotte Raley
Cc:              Grover, Ryan (USAGAS)
Subject:         Draft Joint Status Report
Date:            Friday, April 21, 2023 2:26:57 PM
Attachments:     Joint status report form Woods et al (RCG edits).docx


Jacque and Charlotte,

Please review the attached and either file with Mr. Hawk’s e-signature or let us know whether we
can add it and file.

Thanks,
Jenna

Jennifer G. Solari
Senior Litigation Counsel
U.S. Attorney’s Office
Southern District of Georgia
912-652-4422
Case 4:22-cr-00016-RSB-CLR            Document 189-1         Filed 05/01/23     Page 3 of 4




                       IN THE UNITED STATES DISTRICT COURT
                      FOR THE SOUTHERN DISTRICT OF GEORGIA
                                SAVANNAH DIVISION


 UNITED STATES OF AMERICA

          v.                                                CASE NO.: 4:22-CR-016

 SHAQUANDRA WOODS,
 COURTNEY GILCHRIST, and
 KENNETH JACKSON




                                    JOINT STATUS REPORT

I.       Date of Status Report Conference: April 20, 2020
II.      Conference Attendees:

                          Name                                       Role
          Status information provided by
          defense counsel via email
          Ryan Grover                               AUSA
          Jennifer Solari                           AUSA
          Adrienne Browning                         Counsel for Defendant Gilchrist
          Charlotte Raley                           Paralegal for Mr. Hawk, Counsel for
                                                    Defendant Woods

III.     Pretrial Motions.

         All pretrial motions have been satisfied or otherwise resolved.

         The parties have not resolved the following pretrial motions(s) and will require a ruling
         from the Court to settle the actual controversy or dispute:

                                                                                     Evidentiary
                                                                Oral Argument
       Motion Title and Docket Number             Opposed                             Hearing
                                                                  Requested
                                                                                     Requested
 Government’s Motion in Limine to
 Exclude Defendant Woods’ Self-                      No                No                 No
 Authenticating Records (doc. 177)
Case 4:22-cr-00016-RSB-CLR          Document 189-1          Filed 05/01/23      Page 4 of 4




                Complete Remaining Portions Only In Judge Baker Cases

IV.   Are the parties prepared to proceed to trial? Defendant Woods states she is not ready to
      proceed to trial. Defendant Gilchrist is ready to proceed. Defendant Jackson has not
      provided a response.

      If so, list three potential dates for a telephonic status conference with the presiding
      District Judge.

                               Dates for Telephonic Conference
                                         May 4, 2023
                                         May 5, 2023
                                        May 12, 2023

V.    Do the parties believe the case will result in a negotiated plea agreement and, if so, do the
      parties request additional time (not to exceed 30 days) for further plea negotiations and
      how much time do the parties request?

                                 Additional Time Requested
             Defendant Woods states she is not ready to proceed to trial and
             requests an additional 30 days “for further plea negotiations after
             receiving the Brady material requested in the motion. (Doc. 171).”
             The government has notified Defendant Woods’ counsel that doc.
             171 was not construed as a motion for discovery, doc. 171 has been
             adjudicated, and no additional discovery motions are pending.

             Defendant Jackson did not provide any response for inclusion in this
             joint status report, so his status is unknown.

             Defendant Gilchrist is prepared to proceed to trial.



      This day April 21, 2023.



                                             /s/       Jennifer G. Solari
                                                       Assistant United States Attorney

                                             /s/       Ryan C. Grover
                                                       Assistant United States Attorney

                                             /s/       Adrienne Browning
                                                       Counsel for Defendant Gilchrist




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