Unopposed Motion to Continue Trial by Andre Lorquet. Responses due by 12/27/2022 — USA v. Lorquet (Dkt. 20, S.D. Fla.)

Summary

A Defendant's Unopposed Motion to Continue Trial filed December 9, 2022 in United States of America v. Andre Lorquet, Case No. 22-cr-20326-KMM, in the United States District Court, Southern District of Florida. The motion recites that on July 22, 2022, Mr. Lorquet was charged by Indictment with four counts of Wire Fraud, four counts of Money Laundering and one count of Aggravated Identity Theft, and that trial is currently scheduled for December 19, 2022, with a calendar call scheduled for December 15, 2022. It says the discovery is voluminous and counsel needs additional time to review discovery and pursue a possible resolution. It states that AUSA Jonathan Bailyn does not object, and asks the Court to continue the trial for a period of 60-90 days.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA  
 
CASE NO.: 22-cr-20326-KMM 
 
UNITED STATES OF AMERICA            
                      Plaintiff, 
vs. 
 
ANDRE LORQUET, 
 
           Defendant. 
                                                                      / 
 
DEFENDANT’S UNOPPOSED MOTION TO CONTINUE TRIAL 
 
The Defendant, Andre Lorquet, by and through undersigned counsel, and without 
opposition from the Government, respectfully requests that this Honorable Court continue the 
trial scheduled in this matter and in support states the following: 
1. On July 22, 2022, Mr. Lorquet was charged by Indictment with four counts of Wire 
Fraud, four counts of Money Laundering and one count of Aggravated Identity Theft. 
2. On November 8, 2022, Mr. Lorquet appeared for his initial appearance and was 
arraigned on November 17, 2022. 
3. Mr. Lorquet’s trial is currently scheduled for December 19, 2022, with a calendar call 
scheduled for December 15, 2022. 
4. The discovery in this case is voluminous and the undersigned needs additional time to 
review discovery and pursue a possible resolution. 
5. Pursuant to Local Rule 88.9, undersigned counsel contacted AUSA Jonathan Bailyn, 
who does not object to the requested continuance. 
WHEREFORE, the defendant, Andre Lorquet, through his undersigned counsel and 
without opposition from the Government, respectfully requests that this Honorable Court 

 
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continue the currently scheduled trial for a period of 60-90 days. 
 
CERTIFICATE OF SERVICE 
I HEREBY certify that on December 9, 2022, undersigned counsel electronically filed 
foregoing document with the Clerk of Courts using CM/ECF which will send notification of such 
filing to all counsel of record. 
Respectfully submitted, 
 
BOZANIC LAW, P.A. 
2847 Hollywood Blvd. 
Hollywood, FL 33020 
Telephone: 
954.920.9750 
Facsimile: 
954.400.0335 
E-Mail: Zeljka@bozaniclaw.com 
 
 
 
 
 
 
 
 
/s/Zeljka Bozanic 
By:_________________________________ 
 
 
 
 
 
 
 
Zeljka Bozanic 
 
 
 
 
 
 
 
Florida Bar No.  23707

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