Unopposed MOTION for Extension of Time to File Response as to 70 Objections to Report and… — USA v. Lorquet (Dkt. 74)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20326-KMM · Doc. 74 · 2023-06-26 · Docket on CourtListener

Summary

A defendant's unopposed motion for a seven-day extension of time, filed June 26, 2023 as Document 74 in United States of America v. Andre Lorquet, Case No. 22-20326-CR-KMM (Southern District of Florida). It seeks until July 13, 2023 to respond to the government's objection to Magistrate Judge Louis' Report and Recommendation that the court grant the defendant's motion to withdraw his guilty plea, and states the government has no objection. It recites that the Report and Recommendation was entered June 9, 2023 at ECF 67 and that the government's objection, filed June 22, 2023 at ECF 70, cites recordings of jail calls from FDC-Miami; an index at ECF 73 shows 159 telephone calls being produced. The response was due July 6, 2023, and counsel gives as reasons for more time the review of those recordings with the defendant, a planned absence and other case commitments.

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Full text

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UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF FLORIDA  
 
CASE NO. 22-20326-CR-KMM 
 
UNITED STATES OF AMERICA,  
 
 
 
 
Plaintiff,  
 
 
 
 
 
 
v.  
 
 
 
 
 
 
 
 
ANDRE LORQUET  
 
 
  
 
 
Defendant. 
_____________________________/ 
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO FILE A  
RESPONSE TO THE GOVERNMENT’S OBJECTION TO MAGISTRATE 
JUDGE LOUIS’ REPORT AND RECOMMENDATION 
 
Defendant, Andre Loquet, through undersigned counsel, moves the Court for 
a seven-day extension of time to file his response to the government’s objection to 
Magistrate Judge Louis’ Report and Recommendation that the Court grant Mr. 
Lorquet’s motion to withdraw his guilty plea.  This motion is unopposed, as the 
government has no objection to the one-week extension of time sought through this 
motion. 
On June 9, 2023, Magistrate Judge Louis entered an R&R that the Court grant 
Mr. Lorquet’s motion withdraw his guilty plea.  R&R, ECF 67.  On June 22, 2023, the 
government filed an objection to the R&R, raising arguments, and citing evidence, 
that was not earlier raised. Objection, ECF 70.  That evidence includes recordings of 
Mr. Lorquet’s jail calls from FDC-Miami, which the government is in the process of 
producing for the undersigned and which we shall review with Mr. Lorquet. See ECF 
Case 1:22-cr-20326-KMM   Document 74   Entered on FLSD Docket 06/26/2023   Page 1 of 3

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70 (citing and quoting multiple jail calls). The government’s recently produced index 
or file appendix (ECF 73) shows that it is producing 159 telephone calls, which, once 
received, we must copy to a disk once and mail to Mr. Lorquet at FDC. Mr. Lorquet’s 
response to the R&R is due on July 6, 2023. 
The undersigned will be out of the country, visiting our daughter in Guatemala 
where she works this summer, from Thursday July 29 through the 4th of July holiday.   
Further, after meeting Mr. Lorquet for a second time, on July 24, 2023, the 
undesigned discovered that he does not appear to read or write competently, 
requiring the undesigned to spend more time than expected discussing matters, such 
as the government’s objection to the R&R because the undersigned must read it to 
him aloud.  The undersigned realized that Mr. Lorquet has difficulty reading and 
writing when he asked the undesigned what several words in the R&R were and how 
to pronounce them after the undersigned gave him the R& R and the government’s 
objection to read. He did not appear to understand much of what he was reading.  
The undesigned is also juggling multiple cases and client matters. 
In sum, between juggling multiple client cases and matters, the above-
mentioned trip, listening to, and reviewing with, Mr. Lorquet the recordings which 
the government cites, and the challenges in making sure that Mr. Lorquet 
understands key written materials, undersigned counsel needs additional time to 
respond to the Government’s R&R.   
Case 1:22-cr-20326-KMM   Document 74   Entered on FLSD Docket 06/26/2023   Page 2 of 3

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Wherefore, the defendant, Andre Lorquet, requests an extension of time until 
July 13, 2023 to file a response to the government’s objection to Magistrate Judge 
Louis’ R&R.  
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that, on June 26, 2023, 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 
 
Case 1:22-cr-20326-KMM   Document 74   Entered on FLSD Docket 06/26/2023   Page 3 of 3

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