Court filing
Unopposed MOTION to Continue Restitution Hearing of May 23, 2024 re 111 Notice of Hearing by… — Andre Lorquet (Dkt. 124)
No. 1:22-cr-20326-KMM · Doc. 124 · Docket on CourtListener
Full text
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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