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Superseding Indictment — United States v. Woods et al. (Southern District of Georgia, Document 190)

Summary

A Response to Government's Opposition to Defendant Woods' Objection to Order and Motion to Rescind the Order and Allow a Hearing on Motions Previously Requested, Document 190, filed May 3, 2023, in United States v. Shaquandra Woods, Courtney Gilchrist, and Kenneth Jackson, No. 4:22-CR-016, U.S. District Court, Southern District of Georgia, Savannah Division. Counsel for Woods states that the April 20 Status Report had been filed after counsel gave all input, and that the Government's emails of April 21 came after the Status Report deadline. Counsel states that those emails were not seen and that the Order granting the Government's Motion in Limine was filed on Wednesday. The response states that the rest of Woods' position is in the earlier Objection. It is signed by Jacque D. Hawk.

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Cite this document

“Superseding Indictment — United States v. Woods et al. (Southern District of Georgia, Document 190).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-ga-no-4-22-cr-00016-dkt-190-f49b1b8755/, SHA-256 681d1c399f05c77983e6052bbcef056eafc1f4b6d18eca00360a50d8099ae784.

Full text

   Case 4:22-cr-00016-RSB-CLR       Document 190       Filed 05/03/23   Page 1 of 4




                     UNITED STATES DISTRICT COURT
                     SOUTHERN DISTRICT OF GEORGIA
                          SAVANNAH DIVISION

UNITED STATES OF AMERICA                       SUPERSEDING INDICTMENT NO.
                                               4:22-CR-016


                                               18U.S.C. 1349
                                               Conspiracy to Commit Wire Fraud
             V.

                                               18U.S.C 287
                                               False, Fictitious, or Fraudulent
                                               Claims


SHAQUANDRA WOODS,                              18U.S.C. 1001(a)(3)
COURTNEY GILCHRIST,and                         False Document
KENNETH JACKSON
                                               18U.S.C. 1001(a)(2)
                                               False Statement

   RESPONSE TO GOVERNMENTS OPPOSITION TO DEFENDANT
  WOODS OBJECTION TO ORDER AND MOTION TO RESCIND THE
   ORDER AND ALLOW A HEARING ON MOTIONS PREVIOUSLY
                                  REQUESTED

                                          1.


      On April 20,2023 the Status Report was filed in Shaquandra Woods

case. Counsel for Shaquandra Woods had given all of his input for the Status

Report filed on April 20,2023. The deadline for having the Status Report filed was

April 20,2023. This deadline had passed and there was nothing further to be

done with the Status Report. A substantial portion ofthe Government's response is

based upon emails sent on April 21st, after the Status Report deadline of April 20^

and after the original Status Report had been filed.
   Case 4:22-cr-00016-RSB-CLR       Document 190      Filed 05/03/23   Page 2 of 4




      Counsel left for a weekend of relaxation and to prepare for a show and

performance he was hired to do on Saturday, April 22"^ leaving early Friday, the

21st of April. He had no reason whatsoever to be monitoring his email for any

activity regarding the Status Report in Shaquandra Woods' case as the Status

Report had been filed on the deadline date of April 20^^. Counsel's

paralegal, Charlotte Raley, had taken a personal day and was out ofthe office. He

did not see any ofthese emails fi-om the 2H^ or the final Status Report that was

filed on April 21^ after the original Status Report, and after the Status Report

deadline. This is supported by the lack ofany response on the 2P^

                                          3.


      On the following Monday counsel had two jury trials scheduled that were

resolved, along with appointments and meetings. Tuesday, counsel had a status

conference, along with appointments and meetings. Wednesday is when the Order

was filed granting the Government's Motion in Limine. On Wednesday,counsel

had Court appearances, appointments and a meeting.

                                          4.


      When he received notice that the Status Report had been filed, he had no

reason to believe it was any Status Report he had not reviewed and

approved. When he noticed the emails from the 2P^, upon returning to work, he
   Case 4:22-cr-00016-RSB-CLR      Document 190     Filed 05/03/23   Page 3 of 4




was in the process offormulating a response to what had occurred on the 21^^, ail

without his input. While in the middle offormulating the response to the emails, he

received the Order Granting the Government's Motion in Limine. Counsel then

shifted to formulating a response to that Order.

                                         5.


      The rest and remainder ofthe Defendant's position has been

adequately stated in the Objection To Order And Motion To Rescind Order And

Allow Hearing On Motions As Previously Requested.

             This 2"^ day of May,2023.

                                       Respectfully submitted,

                                      /s/ Jacque D. Hawk
                                      Jacque D. Hawk
                                      Georgia Bar No.: 338755
                                      Attorney for Defendant


The Hawk Firm
448 Telfair Street
Augusta, Georgia 30901
(706)724-8537
jdhawk@thehawkfirm.com
JDH/cgr
   Case 4:22-cr-00016-RSB-CLR        Document 190       Filed 05/03/23   Page 4 of 4




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


UNITED STATES OF AMERICA


VS.


SHAQUANDRA WOODS                                CASE NUMBER:4:22-CR-0016


             DEFENDANT


                          CERTIFICATE OF SERVICE


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

accordance with the directives from the Court Notice ofElectronic Filing("NEF")

which was generated as a result of electronic filing.

                   Submitted this 2"^ day of May,2023.

                                        By: s/ Jacque D. Hawk
                                               The Hawk Firm
                                               448 Telfair Street
                                              Augusta, Georgia 30901
                                              (706)724-8537


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