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/
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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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