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Defendant's Second Motion to Continue Trial — United States v. Carnisha Maurica Rogers (Dkt. 29)

Summary

A Defendant's Second Motion to Continue Trial filed February 9, 2025 as Document 29 in United States v. Carnisha Maurica Rogers, No. 3:24-cr-190-WWB-SJH, in the U.S. District Court for the Middle District of Florida, Jacksonville Division. The motion asks to continue the trial set for the March 3, 2025 trial term for ninety (90) days. As grounds it states that a thumb drive of 25 GB contained discovery received October 25, 2024, that counsel has reviewed eighty (80%) percent of the discovery with the defendant, and that counsel needs additional time to complete the review and to negotiate a plea. It states that the Government does not oppose the request.

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Cite this document

“Defendant's Second Motion to Continue Trial — United States v. Carnisha Maurica Rogers (Dkt. 29).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flmd-433477-29-0-b02e876f5e/, SHA-256 46bc00c272a49d494a9849c87d9a2426b784fd85ac055cabd8ddf8c15b081bf1.

Full text

Case 3:24-cr-00190-WWB-SJH            Document 29       Filed 02/09/25      Page 1 of 2 PageID 93




                                 United States District Court
                                  Middle District of Florida
                                   Jacksonville Division


 UNITED STATES OF AMERICA
       v.                                                  NO: 3:24-cr-190-WWB-SJH

 CARNISHA MAURICA ROGERS
 _____________________________________/



                DEFENDANT ‘S SECOND MOTION TO CONTINUE TRIAL


 DEFENDANT by and through the undersigned attorney, pursuant to the applicable Fed. R.
 Crim. P., respectfully files his Motion to Continue the trial of this matter which has been set for
 the March 3, 2025 trial term and as grounds states:


    1.This Defendant was arraigned on an eight (8) count indictment October 22, 2024.
 Undersigned was appointed on this date.


    2.Undersigned received discovery on October 25, 2024.which was contained on a 25 GB
 thumb drive. Discovery is quite extensive and voluminous.

    3. In addition, Pretrial Services recommended Defendant submit to a psychiatric evaluation
        and treatment. It was determined Defendant’s needed medication to stabilize her
        condition.
    4. Until the defendant’s condition stabilized, undersigned has only reviewed eighty (80%)
        percent of the received discovery with the defendant...
    5. Undersigned needs additional time to complete the review of the discovery with the
        defendant and will also allow time to negotiate a plea in an effort to resolve this matter
        short of trial.
    6. Undersigned has discussed this request in detail with the defendant. She is in agreement.

    7. The Government does not oppose this request.
Case 3:24-cr-00190-WWB-SJH            Document 29     Filed 02/09/25   Page 2 of 2 PageID 94


 _____________________________                                                       Page 2




    8. This request is made in good faith and not to gain an unfair advantage for dilatory
         purposes.
    9.   The Government will not be prejudiced by this request.


    \                                     MEMORANDUM
 Section 3161(h)(8) of the Speedy Trial Act states the Court may grant a continuance if the
 interest of justice may be served.


         WHEREFORE undersigned respectfully request this matter be continued for ninety (90)
         days for the foregoing reasons


 I HEREBY CERTIFY that a copy of the above and foregoing Motion has been furnished to the
 Office of the United Staes Attorney c/o Kevin Frein(USAFLM) kevin.frein@usdoj.gov and via
 CM/ECF portal this February 9, 2025

                                                    ___________________________________
                                                    Robert Calvin Rivers
                                                    Urban League Building
                                                    903 West Union Street, Suite 101-103
                                                    Jacksonville Florida 32204
                                                    Tel. 904.723.4043
                                                    Email: rriverslaw@yahoo.com


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