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Motion for Continuance — United States v. Nariman Mahmoud Masoud, No. 4:22-cr-00140-SAL (Dkt. 218, D.S.C.)

Summary

In this motion filed April 24, 2023 in the District of South Carolina, defense attorney Wallace H. Jordan, Jr. asks the court to continue the sentencing of Nariman Mahmoud Masoud, scheduled for Tuesday, April 25, 2023 at 10:30 A.M. The motion says Masoud signed a plea agreement on December 2, 2022 and pleaded guilty to Count 1 of the Superseding Indictment on December 8, 2022. It says that on Thursday, April 20, 2023 the prosecutor emailed defense counsel that, because of an alleged incident at a grocery store several weeks earlier, the government would no longer file a 5K Motion as previously agreed, and sent a brief video of the incident the next day. The motion says the prosecutor did not object to a continuance and that the defense needs time to investigate the alleged grocery store event and prepare for sentencing.

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Full text

  4:22-cr-00140-JD       Date Filed 04/24/23      Entry Number 218        Page 1 of 2




                        UNITED STATES DISTRICT COURT
                         DISTRICT OF SOUTH CAROLINA
                              FLORENCE DIVISION


UNITED STATES OF AMERICA,           )               CASE NO.: 4:22-cr-00140-SAL
                                    )
                  Plaintiff,        )
                                    )
vs.                                 )
                                    )               MOTION FOR CONTINUANCE
Nariman Mahmoud Masoud,             )
                                    )
                  Defendant.        )
____________________________________)

       NOW COMES THE DEFENDANT, Nariman Mahmoud Masoud, by and through
her undersigned attorney, Wallace H. Jordan, Jr., moves before this Honorable Court for a
continuance of her Sentencing Hearing which is scheduled for Tuesday, April 25, 2023,
based upon the following:
       1.     Defendant executed a Plea Agreement on December 2, 2022.
       2.     Defendant pled guilty to Count 1 of the Superseding Indictment, on
              December 8, 2022.
       3.     Sentencing was scheduled for Tuesday, April 25, 2023 at 10:30 A.M.
       4.     On Thursday, April 20, 2023, four days prior to Sentencing, the Assistant
              United States Attorney sent an email to defense counsel indicating that due
              to an alleged incident taking place at a grocery store several weeks ago, the
              Government was no longer willing to file a 5K Motion on behalf of the
              Defendant, as previously agreed to months prior.
       5.      On Friday, April 21, 2023, the Government provided counsel with a brief
              video of the alleged incident.
       6.     That on Monday, April 20, 2023, counsel for Defendant spoke to the
              AUSA as to the alleged incident, the potential impact as to sentencing, and
              the need for additional information and investigation as to the alleged
              incident. The AUSA indicated that she had no objection to sentencing
              being continued.
  4:22-cr-00140-JD          Date Filed 04/24/23      Entry Number 218        Page 2 of 2




       7.        That based upon the foregoing, counsel for Defendant needs additional
                 time to meet with Defendant and prepare for sentencing, as well as to
                 determine what, if any, additional pleadings need to be filed and to further
                 investigate the alleged grocery store event.
       Based upon the foregoing, attorney for the Defendant hereby asks the Court for a
Continuance of Defendant’s case for a later date and time.
       Respectfully Submitted,
                                          /s/ Wallace H. Jordan, Jr.
                                        Wallace H. Jordan, Jr.
                                        Federal Id. No.: 10158
                                        626 West Evans Street
                                        Post Office Box 2010
                                        Florence, South Carolina 295053-2010
                                        (843) 662-4474 Tele
                                        (843) 662-6024 Fax

                                        Attorney for Defendant Masoud

April 24, 2023
Florence, SC


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