Opinion
CIVIL 22-CV-3288(LAP) CRIMINAL 17-CR-0439(LAP)
06-29-2022
UNITED STATES OF AMERICA, v. JAMAL GODDARD, Petitioner/Defendant.
MOTION TO STAY THE PROCEEDINGS AFTER THE FILLING OF MOTION PURSUANT TO: TITLE 28, U.S.C. § 2255
COMES NOW the Petitioner/Defendant, JAMAL GODDARD, USM# 79379-054, in Pro Se, in necessity, and hereby Moves th.is Honorable Court to Issue an Order granting a Stay of proceedings of Case No. 22-CV-3288(LAP)-Criminal .Case No. [17-CR-0439(LAP)], after Motion to vacate, set aside, or correct sentence pursuant to 28, U.S.C. § 2255, has been docketed on the Court Docket on Case stated above [22-CV-3288(LAP)], in the alternative to Issue an Order granting a ninety (90) day extension of time to obtain Defendant GODDARD Case Work Files from Criminal Case Counsel Florian Miedel.or Counsel Jesse Siegel, Legal Meno's . from Correctional Staff at U.S. Penitentiary Big Sandy in relation to lockdown of Facility for security reason's [Gang roitting, Staff Shortage because the Criminal Indictments being filed agaainst Correctional Officers for beatings of prisoners at this Facility (Fourty(40) Corr. Officers), which have created a shortage in Corr. Staff and Defendant GODDARD has been unable to obtain his legal property to completely respond to Courts Order dated; April 26, 2022, Case No. 22-CV-3288(LAP), also Defendant/Petitioner GODDARD will need a Memo from USP BIG SANDY Staff in relation to COVID-19 lockdowns at this Facility to show cause why the Motion [2255] should not be denied as untimely.
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The Defendant/Petitioner has just recently discoved several Constitutional violations in the criminal process that produced his Conviction Sentence and wishes to file a correct and complete request for relief/ in Good Faith/ pursuant to Title 28/ U.S.C. § 2255.
The Defendant/Petitioner currently has no other choice but to represent himself in pro se, with the assistance of law library prison clerks/ in necessity. The Defendant/Petitioner GODDARD and the law library clerk [prisoner] have no training in the field of law and need the additional time to research his recent discovery.
The Defendant/Petitioner has access to a limited law library as it contains 3 computes to facilitate 1345 inmates here at USP BIG SANDY. What's more/ after waiting his turn the Defendant/Petitioner is limited to only two(2) hours to research and then must wait his turn again.
This motion is made in Good Faith in the Interest of Justice and not meant to delay the proceedings. The United States nor any other adverse party will be prejudiced by an Order to Stay proceedings and/or a Ninety(90) day delay.
I Jamel Goddard declare under penalty of perjury pursuant to Title 28, U.S.C. $ 1746 that the above stated facts and True and Correct to the best of my knowledge and belief.
WHEREFORE NOW above premises considered the Defendant Petitioner Jamel Goddard USM# 79379-054/ Moves this Honorable Court to GRANT him and or Issue an Order of Stay and or in the alternative to Issue an Order granting a ninety(90)day extension of time in which to file, with supporting documentation/ motion pursuant to Title 28/ U.S.C. § 2255. .
Also review herein submitted motion or petition for Issue of an Order for the Case/Work Files for Defendant/Petitioner Jamel Goddard.
Mr. Jamel Goddard USM# 79379-054