Motion for a New Scheduling Order — United States v. Woods, No. 4:22-cr-00016 (S.D. Ga., Dkt. 196)

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A Motion for a New Scheduling Order filed May 22, 2023 as Document 196 in United States v. Shaquandra Woods and others, No. 4:22-cr-00016-RSB-CLR, in the U.S. District Court for the Southern District of Georgia, Savannah Division. The caption lists a superseding indictment citing 18 U.S.C. § 1349, § 287 and § 1001. The motion states that the defendant Shaquandra Woods was served with eighty-eight pages of new discovery and that the new information may require more defense motions. It asks that a new scheduling order be entered and states that the original scheduling order was entered after the government had indicated it had given all of the discovery. The signature block names Jacque D. Hawk, attorney for the defendant.

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   Case 4:22-cr-00016-RSB-CLR      Document 196      Filed 05/22/23   Page 1 of 4




                        UNITED STATES DISTRICT COURT
                           SOUTHERN DISTRICT OF
                        GEORGIA SAVANNAH DIVISION


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


                                            18U.S.C. § 1349
                   V.
                                            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


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


                   MOTION FOR A NEW SCHEDULING
                              ORDER


      Recently the defendant, Shaquandra Woods was served with another eighty-

eight(88)new pages of discovery.



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

it presents for the presentation of the case. All of this 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 196     Filed 05/22/23   Page 2 of 4




      The new information may require more defense motions based upon what

it contains. Research needs to be done to determine what ifany motions would

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

rebuttal evidence to this new discovery.

                                        4.


      Ifdefense counsel had known that these eighty-eight(88)pages ofnew

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 ofeighty-eight(88)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 himselffrom 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 196    Filed 05/22/23   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 22"^ day ofMay,2023.

                                     Respectftilly 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
i dhawk@thehawkfirm.com
JDH/cgr
   Case 4:22-cr-00016-RSB-CLR       Document 196      Filed 05/22/23   Page 4 of 4




                IN THE UNITED STATES DISTRICT COURT
                     FOR THE SOUTHERN DISTRICT OF
                      GEORGIA SAVANNAH DIVISION


UNITED STATES OF
AMERICA

VS.

                                               CASE NUMBER: 4:22-CR-0016
SHAQUANDRA WOODS

           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 ofElectronic Filing

("NEF")which was generated as a result ofelectronic filing.

                   Submitted this 22"^ day of May, 2023.

                                             By:Is! Jacque D. Hawk
                                                  The Hawk Firm
                                                  448 Telfair Street
                                                   Augusta, GA 30901


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