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Home Source documents Court filing — S.D. Ga. No. 4:22-cr-00016 (Dkt. 205)

Court filing — S.D. Ga. No. 4:22-cr-00016 (Dkt. 205)

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      Case 4:22-cr-00016-RSB-CLR   Document 205   Filed 06/22/23   Page 1 of 3




                   UNITED STATES DISTRICT COURT
                   SOUTHERN DISTRICT OF GEORGIA
                        SAVANNAH DIVISION

UNITED STATES OF AMERICA                   )
                                           )
vs.                                        )      No. 4:22cr016
                                           )
SHAQUANDRA WOODS,                          )
                                           )
                    Defendant.             )

                 MOTION FOR EXTENSION OF TIME
                TO RESPOND TO MOTIONS IN LIMINE

        This case is currently set for jury selection and trial on July 18,

2023. (Doc 187) The Court’s Criminal Trial Management Order contains

deadlines geared to that trial date, like requiring the parties to file

motions in limine on or before June 20, 2023, and any responses on or

before June 27, 2023. (Doc 187-Pg 3) On June 20, 2023, the government

filed two motions in limine. (Doc 200, Doc 201)

        Undersigned counsel, who has not received or reviewed the

discovery in the case, has entered a limited notice of appearance to seek

an unopposed continuance of jury selection and trial to a date no earlier

than October 9, 2023. That motion asks the Court to set a new Criminal

Trial Management Order if it grants the requested continuance. A new

Criminal Trial Management Order, with deadlines corresponding with
   Case 4:22-cr-00016-RSB-CLR   Document 205   Filed 06/22/23   Page 2 of 3




a continued trial date, would permit undersigned counsel to review the

discovery, prepare for trial, and file her own and respond intelligently to

the government’s motions in limine.

     Again, though, any response to the government’s motions in

limine is currently due June 27, 2023. (Doc 187-Pg 3) If the Court

grants the motion for continuance, undersigned counsel requests an

extension of time to respond to the government’s pending motions in

limine until the response time set by the new Criminal Trial

Management Order.

     Respectfully submitted this 22nd day of June, 2023.

                                  /s/ Amy Lee Copeland
                                  Amy Lee Copeland
                                  Georgia Bar No. 186730
                                  Attorney for Defendant Woods
                                  (LIMITED APPEARANCE)

602 Montgomery Street
Savannah, Georgia 31401
912-807-5000
ALC@roco.pro
   Case 4:22-cr-00016-RSB-CLR   Document 205    Filed 06/22/23   Page 3 of 3




                     CERTIFICATE OF SERVICE


     I served today a copy of this motion on counsel for the government

by filing it on the Court’s CM/ECF portal, which generates an email to

all counsel of record with a link to the file-stamped copy of this filing.

     This 22nd day of June, 2023.


                                   ROUSE + COPELAND, LLC

                                    /s/ Amy Lee Copeland
                                   Amy Lee Copeland
                                   Georgia Bar No. 186730
                                   Attorney for Defendant
                                   (LIMITED APPEARANCE)

602 Montgomery Street
Savannah, Georgia 31401
912.807.5000 (phone)
912.335.3440 (fax)
ALC@roco.pro


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