Unopposed MOTION to Continue Restitution Hearing of May 23, 2024 re 111 Notice of Hearing by… — Andre Lorquet (Dkt. 124)

Summary

A motion to continue the restitution hearing, entered on the docket 05/23/2024 as Document 124 in United States of America v. Andre Lorquet, Case No. 1:22-cr-20326-KMM, in the U.S. District Court for the Southern District of Florida. Defendant Andre Lorquet asks the Court to continue the restitution hearing of May 23, 2024 for 30 days. The motion states that counsel and the government reached an agreement in principle on the restitution amount, but that Mr. Lorquet was moved from FDC-Miami to FCI-Tallahassee before counsel could confirm whether he would accept the government's most recent proposal. It states that counsel has been unable to reach Mr. Lorquet by phone or Corrilinks, and it is signed s/Henry P. Bell of Bell Rosquete Reyes Esteban, PLLC.

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Case 1:22-cr-20326-KMM Document 124 Entered on FLSD Docket 05/23/2024 Page 1 of 3




                         UNITED STATES DISTRICT COURT
                         SOUTHERN DISTRICT OF FLORIDA

                             CASE NO. 22-20326-CR-KMM

  UNITED STATES OF AMERICA,
        Plaintiff,
  v.

  ANDRE LORQUET

        Defendant.
  _____________________________/
               MOTION TO CONTINUE RESTITUTION HEARING

        Defendant, Andre Lorquet, moves the Court to continue the restitution hearing

  of May 23, 2024.

        The Court scheduled a restitution for May 23, 2024. Although the

  undersigned and counsel for the government have reached an agreement in

  principle over the amount of restitution based on the declaration of victim losses

  and Mr. Lorquet’s position on certain amounts sought or stated in the declaration

  with which he disagreed, Mr. Lorquet was moved from FDC-Miami while the

  parties were still discussing the matter and before the undersigned could meet with

  Mr. Lorquet to confirm whether he would accept the government’s most recent

  proposal to settle the restitution amount and avoid a hearing through a stipulation.

  Being that there was a scheduled hearing and thus far the parties had failed to

  reach an agreement, the undersigned was surprised to learn that Mr. Lorquet was

  transferred out of FDC-Miami with a pending hearing scheduled on the Court’s


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Case 1:22-cr-20326-KMM Document 124 Entered on FLSD Docket 05/23/2024 Page 2 of 3




  docket. In short, we do not have a stipulation that the undersigned has verified

  with Mr. Lorquet that he will, in fact, accept it, and, therefore, the undesigned has

  likewise not secured Mr. Lorquet’s waiver of appearance on May 24, 2024.

        Through this motion, we are asking that the Court to continue the restitution

  hearing to provide the undersigned time to speak Mr. Lorquet who is now at FCI-

  Tallahassee and ascertain whether he will accept the government’s most recent

  proposal and / or waive his appearance. The undersigned called FCI-Tallahassee to

  ascertain how we could schedule some sort of attorney client telephone call and we

  have written to Mr. Lorquet via Corrilinks. But no one answers the phone at FCI-

  Tallahassee and Mr. Lorquet has not replied to the Corrilinks email.

        WHEREFORE, Mr. Lorquet respectfully requests that the Court continue the

  restitution hearing for 30 days.




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Case 1:22-cr-20326-KMM Document 124 Entered on FLSD Docket 05/23/2024 Page 3 of 3




                             CERTIFICATE OF SERVICE

        I HEREBY CERTIFY that, on May 23, 2024, a true and correct copy of the

  foregoing has been furnished electronically via CMCEF to all counsel of record.

                                    Respectfully submitted,

                                    BELL ROSQUETE REYES ESTEBAN, PLLC
                                    Henry P. Bell
                                    Fla. Bar No. 090689
                                    999 Ponce De Leon Blvd.
                                    Suite 810
                                    Coral Gables, Florida 33134
                                    Telephone: (305) 570-1610
                                    Facsimile: (305) 570-1599
                                    Email:       hbell@bresq.com
                                    Counsel to Andre Lorquet

                                    By: ____s/Henry P. Bell_____
                                          Henry P. Bel

  CC: Andre Lorquet – FCI-Tallahassee




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