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Home Court filings 005 ECF 28 Gov Uscourts Unopposed Motion to Continue Change of Plea Hearing — USA v. Smith (Dkt. 28, S.D. Fla.)

Court filing

Unopposed Motion to Continue Change of Plea Hearing — USA v. Smith (Dkt. 28, S.D. Fla.)

Filed June 3, 2021 in 005 ECF 28 Gov Uscourts, the only filing from this case in the archive.

Record facts

CourtU.S. District Court for the Southern District of Florida
Filed2021-06-03

U.S. District Court for the Southern District of Florida · No. 1:21-cr-20001-MGC · Doc. 28 · 2021-06-03 · Docket on CourtListener

Full text

1 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
MIAMI DIVISION 
 
CASE NO.:   21-CR-20001-MGC 
 
 
UNITED STATES OF AMERICA,  
 
 
  
v. 
 
DIAMOND BLUE SMITH, 
Defendant, 
_________________________________/ 
 
DEFENDANT’S UNOPPOSED MOTION TO CONTINUE  
CHANGE OF PLEA HEARING 
 
DEFENDANT DIAMOND BLUE SMITH, by and through undersigned counsel, requests the 
Court to continue his change of plea hearing for 60 days.  The good cause for this motion is as 
follows: 
1. On or about April 19, 2021, Diamond Blue Smith was shot during an attempted robbery and 
transported to Memorial Regional Hospital ICU in critical condition.  Mr. Smith suffered 
broken ribs, a punctured lung, and loss of mobility to his left side.   
2. Mr. Smith is recovering from his injuries but is still suffering from physical pain, labored 
breathing, and inability to hold a sustained conversation.  As a result, defense counsel’s 
ability to productively confer with Mr. Smith has been hindered.   
3. Also, undersigned counsel is currently in the process of moving to Denver, Colorado and is 
scheduled to close on the sale of her Florida home on June 14th.   
4. This motion is made in good faith and in the interests of justice. 
 
 
Case 1:21-cr-20001-MGC   Document 28   Entered on FLSD Docket 06/03/2021   Page 1 of 2

2 
 
 
For these reasons, Mr. Smith respectfully asks this Court to continue his change of plea 
hearing for 60 days. 
 
LOCAL RULE 88.9 CERTIFICATION 
 
I CERTIFY that I have discussed this motion with Assistant U.S. Attorneys Phillip Trout 
and Aimee Jimenez, who advised that they do not oppose this motion.   
 
 
 
 
 
 
 
 
Submitted by: 
  
/s/ Adriana Collado-Hudak 
 
 
 
 
 
 
 
Fla. Bar No. 830461 
 
 
 
 
 
 
 
Greenspoon Marder LLP  
 
 600 Brickell Avenue  
 
 36th Floor 
 
 
 
 Miami, FL 33131 
 
 
 
305-789-2713  
 
 
 
 
adriana.collado-hudak@gmlaw.com 
 
 
CERTIFICATE OF SERVICE 
I CERTIFY that I filed a copy of the foregoing via CM/ECF on June 3, 2021, and it was 
thereby served on all parties of record. 
/s/ Adriana Collado-Hudak 
 
 
 
 
 
 
 
Fla. Bar No. 830461 
Case 1:21-cr-20001-MGC   Document 28   Entered on FLSD Docket 06/03/2021   Page 2 of 2

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