Superseding Indictment — United States v. Woods et al. (Southern District of Georgia, Document 191)

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A Motion for a New Scheduling Order filed May 8, 2023, in United States v. Shaquandra Woods, Courtney Gilchrist, and Kenneth Jackson, Superseding Indictment No. 4:22-cr-016, U.S. District Court, Southern District of Georgia, Savannah Division (Document 191). The motion states that Shaquandra Woods was recently served with another 556 new pages of discovery that need to be read, analyzed and gone over with the defendant. It states that the new information may require more defense motions and that time is needed to gather possible rebuttal evidence. The motion requests that a new scheduling order be entered, and it is signed by Jacque D. Hawk as attorney for the Defendant.

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   Case 4:22-cr-00016-RSB-CLR      Document 191       Filed 05/08/23   Page 1 of 4




                        UNITED STATES DISTRICT COURT
                     SOUTEDERN DISTRICT OF GEORGIA
                            SAVANNAH DIVISION


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


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

                                             18U.S.C. §287
 SHAQUANDRA WOODS,                           False, Fictitious, or Fraudulent
 COURTNEY GILCHRIST,and                      Claims
 KENNETH JACKSON
                                             18U.S.C. § 1001(a)(3)
                                             False Document


                                             18U.S.C.§ 1001(a)(2)
                                             False Statement


               MOTION FOR A NEW SCHEDULING ORDER


                                        1.


      Recently the defendant, Shaquandra Woods was served with another five

hundred and fiffy-six(556)new pages of discovery.

                                        2.


      The discovery needs to be read and analyzed to determine what new issues it

presents for the presentation ofthe case. All ofthis discovery now needs to be

gone over with the defendant. The Defendant lives in Jacksonville, FL. The new

information needs to be investigated.
   Case 4:22-cr-00016-RSB-CLR       Document 191      Filed 05/08/23   Page 2 of 4




                                         3.


      The new information may require more defense motions based upon what it

contains. Research needs to be done to determine what if any motions would be

proper to file at this time. The defendant needs time to gather any possible rebuttal

evidence to this new discovery.

                                         4.


      If defense counsel had known that these five hundred and fifly-six(556)

pages of new discovery were going to be disclosed after the most recent status

conference report, then the status conference report from the defendant's

perspective would have been completely different. The defendant needs a new

scheduling order in order to properly evaluate, prepare for, and deal with this new

discovery disclosure of five hundred fifty-six(556)pages of discovery. Defense

counsel has been complaining about document dumping to the government during

this entire process. There is no quick way to go through this discovery and deal

with it without some additional time and without an additional scheduling order.

Counsel has seen so much recent document dumping in federal criminal litigation

that he has removed himself from federal criminal litigation. Finding meaningful

discovery in federal criminal litigation has become similar to searching for a

needle in a haystack.
   Case 4:22-cr-00016-RSB-CLR      Document 191     Filed 05/08/23   Page 3 of 4




                                        5.


      For all ofthe above and foregoing reasons, the defendant requests a new

scheduling order be entered. The original scheduling order was only entered after

the government had indicated that they had given us all ofthe discovery.

             This 8^ 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 191      Filed 05/08/23    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 in

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

which was generated as a result ofelectronic filing.

                   Submitted this 8^ 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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