Unopposed Motion for Extension of Time to File Reply as to 89 Response in Opposition — USA v. Lorquet (Dkt. 90, S.D. Fla.)

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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 UNOPPOSED MOTION FOR EXTENSION OF  
TIME TO FILE A REPLY TO THE GOVERNMENT’S  
RESPONSE TO MOTION TO WITHDRAW GUILTY PLEA 
 
Defendant, Andre Lorquet, through undersigned counsel, moves the Court for 
an extension of time until Tuesday, October 17, 2023 to file a reply to the 
government’s response to his motion to withdraw his plea.  This motion is unopposed.   
The government filed a response to the Defendant’s motion on October 5, 2023. 
Therefore, the defendant’s reply memorandum is due October 12, 2023. However, the 
undersigned has been unable to visit with Mr. Lorquet at FDC to review the 
government’s response and discuss a reply memorandum with him, because on 
October 6, 2023, the date on which the undersigned originally planned to meet with 
Mr. Lorquet, the undersigned was appointed to represent a client arrested in a 
material witness warrant, who, according to the government, was resisting appearing 
in court to testify at trial. He is the victim of a shooting. The undersigned was not on 
CJA duty, but agreed to be available when called by the Court, nevertheless.  Having 

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to deal with that witness/client, including appearing in court on today’s date with 
him, along with a previously scheduled deposition in another case, thwarted the 
undersigned from seeing Mr. Lorquet at FDC when initially planned to review the 
matter and file the reply. Hence, Mr. Lorquet hereby requests an extension of time to 
file the reply to provide his counsel with time to meet with him before filing a reply 
memorandum with the Court.  The undersigned will see him on Saturday, October 
14, 2023 and file the reply on or before October, 17, 2023, if the Court agrees.    
The undersigned conferred with the government, which has no objection to the 
extension requested with this motion.         
WHEREFORE, the Defendant, Andre Lorquet, requests an extension of time 
until October 17, 2023 to file a reply to the government’s response to his motion to 
withdraw his guilty plea.    
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that, on October 12, 2023, a true and correct copy of 
the foregoing has been furnished electronically via CMC/EF 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. Bell, Esq.

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