Defendant's Reply to Response to Motion by Andre Lorquet — USA v. Lorquet (Dkt. 92, S.D. Fla.)

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A Defendant's Reply to Government's Response to the Motion to Withdraw Guilty Plea, Document 92 entered on the docket 10/16/2023 in United States v. Andre Lorquet, Case No. 22-20326-CR-KMM, in the Southern District of Florida, replying to ECF 89. The defense says Mr. Lorquet did not have the close assistance of counsel, and avers that counsel refused to accept his instructions that he did not wish to plead guilty and pressured him. It says the calls the government cites show only some of Mr. Lorquet's thinking and, in part, support him because he repeatedly stated that he wants to go to trial. It responds that any inconvenience to the government does not outweigh due process and the Sixth Amendment, and asks the Court to grant the motion. The certificate of service is dated October 16, 2023 and the filing is submitted by Henry P. Bell, counsel to Andre Lorquet.

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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 REPLY TO GOVERNMENT’S  
RESPONSE MOTION TO WITHDRAW GUILTY PLEA 
 
Defendant, Andre Lorquet, replies to the government’s response to his motion 
withdraw his guilty plea (ECF 89). Citing the transcript from Mr. Lorquet’s guilty 
plea, the government argues that Mr. Lorquet knowingly and voluntarily pled guilty 
with the close of assistance of counsel.  While they may have been physically next 
to each other during the plea hearing, Mr. Lorquet did not have the close assistance 
of counsel. To the contrary, he avers that his counsel refused to accept his 
instructions that he did not wish to plead guilty and instead pressured him to plead 
guilty and made him feel as if he had no choice. While Mr. Lorquet went through 
the motions of pleading guilty, he avers that he did so only because he felt he had 
no choice.   
The government also cites select calls between Mr. Lorquet and his mother 
and another person to argue that Mr. Lorquet was not pressured or under duress 
when pleading guilty. Those conversations, which show only some of Mr. Lorquet’s 
Case 1:22-cr-20326-KMM   Document 92   Entered on FLSD Docket 10/16/2023   Page 1 of 2

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thinking, in part, support Mr. Lorquet in that he repeatedly stated that he wants to 
go to trial.  Finally, the government argues it is prejudiced by allowing the plea to 
be vacating and permitting Mr. Lorquet to proceed to trial. While it may indeed be 
inconvenient, as stated in Mr. Lorquet’s motion, due process, the Sixth Amendment, 
and trials are, by definition, inconvenient.     
For the above stated reasons and the reason averred in Mr. Lorquet’s motion, 
he respectfully requests that the Court grant his motion to withdraw his guilty plea. 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that, on October 16, 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 
 
CC: Andre Lorquet – FDC Miami 
Case 1:22-cr-20326-KMM   Document 92   Entered on FLSD Docket 10/16/2023   Page 2 of 2

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