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Case 4:22-cr-00016-RSB-CLR Document 219 Filed 07/03/23 Page 1 of 7
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA,
v. CASE NO.: 4:22-cr-16
SHAQUANDRA WOODS, and KENNETH
JACKSON,
Defendants.
AMENDED CRIMINAL TRIAL MANAGEMENT ORDER
This matter is before the Court on several Motions from Defendant Woods: an Unopposed
Motion for Continuance of Trial, (doc. 204); a Motion for Extension of Time to Respond to
Motions in Limine, (doc. 205); a Motion for Substitution of Counsel, (doc. 206); and a Motion for
Ruling, (doc. 217). After careful consideration and for good cause shown, the Court GRANTS
Defendant Woods’ Motions, (docs. 204-206, 217). Therefore, it is hereby ORDERED that Ms.
Copeland shall be substituted for Mr. Hawk as attorney of record for Defendant Woods thereby
relieving Mr. Hawk from further obligation as counsel for Defendant Woods. The Clerk is
DIRECTED to make the appropriate notations to the record of this case.
IT IS FURTHER ORDERED that the above captioned case is CONTINUED as follows. 1
This case is RESCHEDULED for a PRETRIAL CONFERENCE before R. Stan Baker, United
States District Judge, at 2:00 PM, on Tuesday, October 17, 2023, at the Federal Courthouse,
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While Defendant Woods’ Motion for Continuance of Trial does not incorporate by reference her
Co-Defendants, the Court herein CONTINUES Jury Selection and Trial as to Defendant Woods
and Defendant Jackson. By separate Order, the Court CONTINUES Jury Selection and Trial as
to Defendant Gilchrest in light of an agreement with the Government for Pre-Trial Diversion, (doc.
209).
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Courtroom 1, 8 Southern Oaks Court, Savannah, Georgia, and for JURY SELECTION AND
TRIAL before Judge Baker, at 8:30 AM, on Tuesday, October 24, 2023, at the Federal
Courthouse, Courtroom 1, 8 Southern Oaks Court, Savannah, Georgia. The Court ORDERS the
parties to carefully read and comply with the following directives. Moreover, the time periods set
forth herein are necessary for the Court and the parties to prepare for trial. The interest served by
providing the parties this additional time outweigh the public’s and Defendants’ interest in prompt
resolution of this case. Therefore, the time from the date of this Order up to the date of trial shall
be excluded from calculation of the time for trial provided by the Speedy Trial Act.
I. General Directions
In this Order, the Court sets forth the parties’ obligations to prepare this matter for trial. It
is not the Court’s intention to impose needlessly onerous obligations on counsel. Rather, these
measures are designed to ensure the just and efficient trial of this case. It is the Court’s experience
that the administration of justice is better served when the matters addressed herein are resolved
well in advance of trial rather than by last minute filings on the eve of or during trial.
Except where otherwise indicated in this Order, the parties shall electronically file the
documents described below using the Court’s CM/ECF system. Each filed document should be
separately and clearly captioned. When documents are required by this Order to be sent to the
Court by email attachment, they should be submitted to the Courtroom Deputy Clerk Pam
Hammock at pam_hammock@gas.uscourts.gov. Any questions may be directed to the Courtroom
Deputy Clerk either by email or by telephone at (912) 650-4081.
II. Motions to Continue or Extend
The Court will only continue or extend the deadlines in this Order upon a showing of good
cause. If any party seeks to continue or extend any of the deadlines in this Order including the
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date of the trial and/or pretrial conference, the party must make that request via a motion filed on
the Court’s docket. The filing of a notice of a plea agreement alone will not continue or extend
the deadlines in this Order. Absent a showing of good cause, a motion to continue or extend the
trial should be made at least two weeks before the trial date. Prior to filing any request to continue
or extend, the requesting party shall consult with opposing counsel to determine if the opposing
party agrees with or opposes the request. Within any motion to continue or extend, the moving
party shall state whether the Defendant agrees with or opposes the request and whether opposing
counsel agrees with or opposes the request. Additionally, within any motion to continue or extend,
the moving party should state whether the period of delay should be excluded in computing the
time within which the trial must commence under the Speedy Trial Act, 18 U.S.C. § 3161.
III. Expert Witnesses
On or before September 5, 2023, the Government shall disclose to Defendant, in writing,
the information required by Federal Rule of Criminal Procedure 16(a)(1)(G)(iii) for any testimony
that the government intends to use at trial during its case-in-chief under Federal Rule of
Evidence 702, 703, or 705. On or before September 12, 2023, the Defendant shall disclose to the
Government, in writing, the information required by Federal Rule of Criminal
Procedure 16(b)(1)(C)(iii) for any testimony that the defendant intends to use at trial under Federal
Rule of Evidence 702, 703, or 705. On or before September 19, 2023, the Government shall
disclose to Defendant, in writing, the information required by Federal Rule of Criminal
Procedure 16(a)(1)(G) (iii) for any testimony that the government intends to use at trial during its
rebuttal under Federal Rule of Evidence 702, 703, or 705 to counter testimony that the defendant
has disclosed under this Section.
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IV. Motions in Limine 2
The parties shall file any motions in limine on or before September 19, 2023. The parties
shall file any responses to any motions in limine on or before September 26, 2023. Complex trial
issues, including substantial evidentiary questions, are better resolved in advance of, rather than in
the midst of, trial. Thus, where possible, the Court expects the parties to raise complex trial issues,
including complex debates regarding the exclusion or admission of evidence, through motions in
limine. However, the Court discourages the filing of form motions in limine or motions about
issues the opposing party does not dispute.
V. Requested Voir Dire, Jury Instructions, and Verdict Form
Each party shall file the party’s requested voir dire, jury instructions, and verdict form on
or before October 3, 2023. 3 Each party shall file any objections to an opposing party’s requested
voir dire, jury instructions, and verdict form on or before October 10, 2023. In addition to the
CM/ECF-filed requests, each party shall email a copy of the party’s requested voir dire, jury
instructions, and verdict form as attachments in Word format to the Courtroom Deputy Clerk.
The parties are encouraged to use and refer to the Eleventh Circuit Pattern Jury Instructions
in making their requests. For each requested jury instruction, the party should include the full text
of the requested instruction and the pattern instruction number or other authority on which the
request is based. If a party’s requested instruction includes a modification of the pattern
instruction, the party should so indicate.
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There are several pending Motions in Limine already filed in this case in anticipation of trial. See Docs.
200-202. The Court expressly orders that the deadline to file any responses to any motions in limine is
September 26, 2023.
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These requests should be filed as three separate pleadings.
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VI. Witness List and Exhibit List
Each party shall e-mail the Courtroom Deputy Clerk a copy of their witness list and exhibit
list as attachments in PDF and Word format on or before on or before October 16, 2023. Parties
shall not file the witness list or exhibit list on the record of the case in CM/ECF. At the pretrial
conference, the Court will discuss with counsel whether each party’s exhibit list and/or witness
list should be disclosed to opposing counsel.
VII. Trial Exhibits
On or before October 16, 2023, each party shall deliver to the Courtroom Deputy Clerk, a
USB flash drive containing all trial exhibits in electronic format. 4 Parties shall not file trial exhibits
on the record of the case in CM/ECF.
Original exhibits shall be submitted at the time of trial in electronic format and in
accordance with the Eleventh Circuit rules regarding exhibits (11th Cir. R. 11-3,
http://www.ca11.uscourts.gov/rules-procedures). Ordinarily, all exhibits for introduction into
evidence at trial, to be shown to witnesses, and to be published to the jury must be presented
electronically during trial, including documentary exhibits. Some exhibits may not exist in
electronic format or may not easily convert to an electronic format. In those instances, the parties
shall notate their respective exhibit lists as to any exhibits not submitted in electronic format.
When submitting non-documentary physical exhibits, the parties shall include photographs or
other reproductions of such exhibits in electronic form.
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Acceptable electronic formats are limited to the following file types: .pdf, .jpg, .bmp, .tif, .gif, .avi, .wmv,
.mpg, .mp3, .mp4, .wma, .wav, .3gpp. Each trial exhibit should be clearly named in an easily identifiable
manner. Should the parties have any questions regarding the electronic format or naming conventions for
proposed exhibits, they should contact the Courtroom Deputy Clerk well in advance of their deadline for
submission of electronic exhibits.
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Additionally, all parties shall provide one paper courtesy copy of all trial exhibits for
inclusion in a Trial Exhibit Notebook to be given to the jury at the conclusion of the case. The
Trial Exhibit Notebook for the jury should contain said exhibits placed into labeled three-ring
binders with corresponding exhibit numbered side index tabs for each exhibit.
VIII. Trial Memoranda
Each party may file, but is not required to file, a trial memorandum. Any party desiring to
file a trial memorandum shall file the memorandum on or before October 16, 2023. A trial
memorandum should be filed where necessary to make the Court aware of significant or unique
procedural, factual, or legal issues that the party expects to arise at trial. The memorandum should
contain a short and plain statement of any such issues. For any legal issues, the party must cite to
relevant legal authority. A party should not file a trial memorandum to discuss routine or
insignificant issues. A party should also not file a trial memorandum to request court action prior
to trial as such a request should be made in a motion in limine. Additionally, a party should not
file a trial memorandum to reiterate issues that have already been raised by a motion in limine.
When filing a trial memorandum, the party should use the “Trial Brief” event in CM/ECF located
under Criminal – Other Filings – Trial Documents.
IX. Pretrial Conference
At the pretrial conference, the Court will conduct a meaningful and substantive discussion
regarding the trial of this case. Thus, the Defendants and all attorneys participating in the trial
of the case shall be present at the pretrial conference. Counsel shall be prepared to discuss and
offer argument on any motions in limine and responses thereto, as well as any trial document listed
above and objections thereto. Absent a significant issue, the Court will not address individual
exhibit objections at the pretrial conference as those objections are better addressed during trial.
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Additionally, at the pretrial conference, counsel should bring to the Court’s attention any
witnesses, parties, counsel, or others who will be present at trial and who may need accommodation
for any disability.
SO ORDERED, this 3rd day of July, 2023.
R. STAN BAKER
UNITED STATES DISTRICT JUDGE
SOUTHERN DISTRICT OF GEORGIA
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