Motion for Continuance of Pretrial Motion Dates, United States v. ROBBERTA MARIE KHAN

Change of Plea Deadline, and Final Pretrial Conference Date Case No. 4:23CR268

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA § 

§ 

V. § NO. 4:23CR268 

§ (Judge Jordan) 

ROBBERTA MARIE KHAN § 

MOTION FOR CONTINUANCE OF PRETRIAL MOTION DATES,

CHANGE OF PLEA DEADLINE, AND FINAL PRETRIAL CONFERENCE DATE

TO THE HONORABLE JUDGE OF THE UNITED STATES DISTRICT COURT FOR THE 

EASTERN DISTRICT OF TEXAS; 

COMES NOW, Defendant, ROBBERTA MARIE KHAN, by and through her undersigned 

attorney, and files this, MOTION FOR CONTINUANCE OF PRETRIAL MOTION DATES, 

CHANGE OF PLEA DEADLINE, AND FINAL PRETRIAL CONFERENCE DATE, and would 

show this Honorable Court as follows, to-wit:

I.

PROCEDURAL HISTORY

On December 12, 2023, the Defendant appeared before United States Magistrate Judge 

Kimberly Priest Johnson for an Initial Appearance and Arraignment on a two-count Indictment, in 

which the Defendant is charged with a violation of 18 U.S.C. §§ 2422(a) & 2 (Coercion and 

Enticement and Aiding and Abetting). At that time, the Office of the Federal Public Defender for 

the Eastern District of Texas was appointed to represent the Defendant. The Final Pretrial 

Conference is scheduled for February 5, 2024. 

II.

GROUNDS FOR MOTION

Defense counsel respectfully requests a continuance of the pretrial dates to receive and 

review the discovery in this case, and to discuss the evidence and sentencing guidelines with the 
Motion for Continuance of Pretrial Motion Dates, United States v. ROBBERTA MARIE KHAN

Change of Plea Deadline, and Final Pretrial Conference Date Case No. 4:23CR268

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Defendant. Because of the possible punishment, the Defendant respectfully requests this additional 

time in order to make a fully informed decision. This request is made in order to ensure that 

effective assistance of counsel is provided to the Defendant. 

This Motion for Continuance is not made for purposes of delay, but only in order that 

justice may be done. The Defendant requests that this Court make a finding that “the ends of 

justice served by taking such action outweigh the best interest of the public and the defendant to a 

speedy trial.” 18 U.S.C. § 3161(h)(7)(A). 

Due to the reasons outlined above, Defendant respectfully requests an additional 60 days 

for the pretrial motion dates, change of plea deadline, and final pretrial conference date.

WHEREFORE PREMISES CONSIDERED, Defendant respectfully requests that the 

pretrial motion dates, change of plea deadline, and final pretrial conference date in this case be 

reset from their current setting for an additional 60 days. 

Respectfully submitted,

/s/ Brian O’Shea 

BRIAN O’SHEA

Assistant Federal Defender

Eastern District of Texas

7460 Warren Parkway, Suite 270 

Frisco, Texas 75034 

(469) 362-8506 

FAX: (469) 362-6010 

 

 Attorney for Defendant 
Motion for Continuance of Pretrial Motion Dates, United States v. ROBBERTA MARIE KHAN

Change of Plea Deadline, and Final Pretrial Conference Date Case No. 4:23CR268

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CERTIFICATE OF CONFERENCE

Prior to filing this motion, I contacted Assistant United States Attorney, Marisa Miller, and 

the Government does not oppose this motion. 

Additionally, I contacted each of the attorneys for the co-defendants and their responses 

are noted below:

Rafael De La Garza II, the attorney for William McKinnley Garland (1), is not opposed. 

Richard Howard, the attorney for Jalen Alexander Bobo (2), is not opposed. 

/s/ Brian O’Shea

BRIAN O’SHEA

Attorney for Defendant

CERTIFICATE OF SERVICE

I hereby certify that on the 8th day of January 2024, a true and correct copy of the foregoing 

Defendant's MOTION FOR CONTINUANCE OF PRETRIAL MOTION DATES, CHANGE OF 

PLEA DEADLINE, AND FINAL PRETRIAL CONFERENCE DATE was sent by CM/ECF to:

Marisa Miller

Assistant U.S. Attorney 

 101 East Park Blvd. 

Suite 500 

Plano, TX 75074 

/s/ Brian O’Shea

BRIAN O’SHEA

Attorney for Defendant