Unopposed MOTION for Extension of Time to File Response as to 85 Defendant's MOTION to… — USA v. Lorquet (Dkt. 87)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20326-KMM · Doc. 87 · 2023-09-29 · Docket on CourtListener

Summary

The United States' Unopposed Motion for Extension of Time to Respond to the Defendant's Second Motion to Withdraw Plea, filed September 29, 2023 as Doc. 87 in United States v. Andre Lorquet, No. 1:22-cr-20326-KMM, in the U.S. District Court for the Southern District of Florida. The motion states that the defendant's motion at ECF No. 85 was filed September 18, 2023 and that the government's response is due October 2, 2023 under S.D. Fla. L.R. 7.1(c)(1). It requests a 72-hour extension, until October 5, 2023, because government and defense counsel are in good faith negotiations to resolve the defendant's motion without briefing or an evidentiary hearing. It states that defense counsel does not oppose the request, and it is signed by Assistant United States Attorney Jonathan R. Bailyn for United States Attorney Markenzy Lapointe.

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Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO: 22-CR-20326-MOORE 
 
 
UNITED STATES, 
 
 
v. 
 
ANDRE LORQUET, 
 
 
Defendant. 
___________________________/ 
 
 
UNITED STATES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO 
RESPOND TO THE DEFENDANT’S SECOND MOTION TO WITHDRAW PLEA  
 
The United States of America, by and through the undersigned Assistant United States 
Attorney, hereby files this Unopposed Motion for Extension of Time to Respond to the 
Defendant’s Second Motion to Withdraw Plea [ECF No. 85], which was filed on September 18, 
2023.  The United States’ response to the Motion is due Monday, October 2, 2023.  See S.D. Fla. 
L.R. 7.1(c)(1).  The United States’ requests a 72-hour extension of time, until Thursday, October 
5, 2023, to file a response to the Motion.  The United States’ requests this brief extension because 
the undersigned Assistant United States Attorney and Defense Counsel are undertaking good faith 
negotiations, up to and including today, to resolve the Defendant’s Motion without the need for 
briefing or an evidentiary hearing.  The Defendant is in custody at FDC and therefore cannot 
immediately respond to a negotiated resolution.   
 
 
Case 1:22-cr-20326-KMM   Document 87   Entered on FLSD Docket 09/29/2023   Page 1 of 2

  
-2- 
The undersigned Assistant United States Attorney has conferred with Defense Counsel, by 
telephone, and he does not oppose the United States’ request.  
 
 
 
 
 
 
MARKENZY LAPOINTE 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
BY:  
/s/ Jonathan Bailyn    
 
 
 
 
 
 
Jonathan R. Bailyn, AUSA 
Court ID No. A5502602 
500 South Australian Ave, 4th Floor 
West Palm Beach, Florida 33401 
Phone: (561) 209-1050 
jonathan.bailyn@usdoj.gov 
Case 1:22-cr-20326-KMM   Document 87   Entered on FLSD Docket 09/29/2023   Page 2 of 2

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