UNITED STATES OF AMERICA v. CLYDE et al

IN THE U NITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
ALBANY DIVISION
U NITED STATES OF AMERICA,
v .
KANDICE CLYDE and
DEVON RAMBO,
Defendants.
ORDER
CASE NO :
1:25-cr-15-WLS-ALS
A status conference was held in the above-styled action on September 2, 2026 . The
Court enters this Order to memorialize the discussions held and instructions given at the status
conference.
TI1e trial of this matter has been continued to the January 2027 Albany Trial Term.
P hilip Cannon, counsel for D evon Rambo ("Rambo ") indicated he had conferred with Rambo
prior to the conference . Mr . Cannon notes that he and R ambo are now working together in
this matter. Rambo confirmed that he is agreeable to working with Mr. Cannon . Other than
two issues Mr . Cannon is investigating, the only remaining pretrial issue for Rambo is to reset
the competency 	hearing. 	Mr. 	Cannon will 	notify 	the 	Court when he 	has 	compl eted
investigations so the competency hearing can be reset . Mr. Cannon expects to be ready to go
to trial in January 202 7.
Mr. Cannon is all representing R ambo in R ambo's appeal of United States of A merica v.
D evon Ram bo, No. 1:25-C R-2-LA G , in the U nited States D istrict Court for the Middle D istrict
of Georgia ("Firearm Case "). TI1e allegations in the Indictment in this case arise from alleged
actions of Rambo and Co -D efendant Kandice Clyde (" Clyde") that occurred in the F irearm
Case. Mr. Cannon did not represent Rambo in the trial of the F irearm Case . The Court and
counsel for the parties discussed whether there was a potential conflict with Mr. Cannon
representing Rambo in this case and in the appeal of the Firearm Case. Mr . Cannon posits that
his representation of R ambo in the appeal of the Firearm Case does not present a conflict.
Rather, his representation in the appeal and in this case benefits R ambo because it is necessary
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for Mr . Cannon to know the facts, procedures , and events that occurred in the F irearm Case
to effectively represent Rambo in the current case. TI1e Court determined that no conflict
exists with Mr. Cannon representing R ambo in the appeal of the F irearm Case and this case.
L eah McEwen , counsel for the G overnment also noted no basis for conflict.
Ms. Mc E wen advised that the Government will be ready to proceed to trial in January
202 7. In the event Rambo is not ready for trial at that time , the Government will cons i der
severing the cases of R ambo and Clyde so Clyde's trial can proceed in January 2027 . In
addition , the hearing on the G overnment's Motion in L mine to P reclude Defendants from
Asserting an Advice of Counsel D efense (D oc . 36) needs to be resolved prior to trial, but only
after Rambo 's competency hearing has concluded. 1
SO ORDERED, this 3rd day of September 2026 .
/s /W. Louis Sands
W. LO U IS SANDS, SR. JUDGE
U NITED STATES DISTRICT CO URT
1 Based on the ordered forensic evaluation provided to the Court and Counsel, and because the conference did
not involve any evidentiary hearings or findings, the Court determined that holding the above conference was
appropriate and beneficial notwithstanding the pending competency hearing. No action adverse to Rambo or
his interests were taken or imposed .
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