Pandemic Darlings The pandemic economy, in original documents
Home Court filings USA v. Lorquet United States v. Andre Lorquet — S.D. Fla., No. 1:22-cr-20326-KMM Response to 100 Objections to Report and Recommendations by USA as to Andre Lorquet — USA v. Lorquet (Dkt. 103, S.D. Fla.)

Court filing

Response to 100 Objections to Report and Recommendations by USA as to Andre Lorquet — USA v. Lorquet (Dkt. 103, S.D. Fla.)

Filed January 12, 2024 in USA v. Lorquet; one of 145 filings from this case.

Record facts

CourtU.S. District Court for the Southern District of Florida
Filed2024-01-12

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20326-KMM · Doc. 103 · 2024-01-12 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO: 22-CR-20326-MOORE 
 
 
UNITED STATES, 
 
 
v. 
 
ANDRE LORQUET, 
 
 
Defendant. 
___________________________/ 
 
 
UNITED STATES RESPONSE IN OPPOSITION TO THE DEFENDANT’S 
OBJECTIONS TO THE MAGISTRATE JUDGE’S 
REPORT AND RECOMMENDATION ON THE DEFENDNAT’S 
MOTION TO WITHDRAW HIS PLEA 
 
The United States of America hereby files this Response to the Defendant’s Objections to 
the Magistrate Judge’s Report and Recommendation on the Defendant’s Motion to Withdraw His 
Plea [ECF No. 100].   
BACKGROUND 
On July 21, 2022, the Defendant was indicted by a grand jury for offenses related to 
COVID-relief fraud [ECF No. 1].  The Defendant had his initial appearance on November 8, 2022, 
and retained private counsel, Zeljka Bozanic [ECF No. 13].   
On January 24, 2023, the Defendant pled guilty before the Magistrate Judge to Counts 7 
and 9 of the indictment, which charged the Defendant with money laundering and aggravated 
identity theft, in violation of Title 18, United States Code, Sections 1957 and 1028A(a)(1).  [ECF 
No. 44].  The Magistrate Judge recommended that the Court accept the Defendant’s plea, finding 
that the Defendant was “fully competent and capable of entering an informed plea” and that the 
Defendant was “aware of the nature of the charges and the consequences of the plea.”  [ECF No. 
Case 1:22-cr-20326-KMM   Document 103   Entered on FLSD Docket 01/12/2024   Page 1 of 5

  
-2- 
43, at 3].  On February 9, 2023, the Court adopted the Magistrate Judge’s recommendation [ECF 
No. 50].   
On March 13, 2023, the Defendant filed a Motion to Withdraw his plea, alleging that he 
was “he was under duress” and that he “believed that he was signing paperwork related to the 
reinstatement of his bond.”  [ECF No. 55 at 1].  The same day, Ms. Bozanic moved to withdraw 
as counsel [ECF No. 56].   
The Court held a sentencing hearing on March 30, 2023 [ECF No. 60].  At the hearing, the 
Court granted Ms. Bozanic’s motion to withdraw as counsel, ordered the Defendant to find new 
counsel, and referred the motion to withdraw the plea to the Magistrate Judge [ECF Nos. 61–62].   
On June 16, 2023, the Court appointed Henry Bell to represent the Defendant [ECF N. 69].  
On July 24, 2023, the Defendant moved, unopposed, to withdraw his motion to withdraw his plea 
[ECF No. 76].  The Court scheduled sentencing for August 24, 2023 [ECF No. 77].  At the August 
24, 2023, hearing, the Defendant moved again to withdraw his plea [ECF No. 80].  The Court 
continued sentencing until September 7, 2023.  Id.   
On September 6, 2023, Mr. Bell moved to withdraw as counsel [ECF No. 83].  On 
September 7, 2023, at the sentencing hearing, the Court denied Mr. Bell’s motion to withdraw and 
allowed the Defendant to file a new motion to withdraw the plea [ECF No. 84], which the 
Defendant did on September 18, 2023 [ECF No. 85].  In support of the Motion to Withdraw, the 
Defendant alleged that he “thought he was in court for a hearing relating to his bond revocation” 
and that Ms. Bozanic “pressured him to go through the guilty plea.”  Id. at 4; see also id. at 2 
(arguing that he was “under pressure from his lawyer,” who “insisted and pressured him to plead 
guilty”).  The Government filed a response in opposition [ECF No. 89]. 
Case 1:22-cr-20326-KMM   Document 103   Entered on FLSD Docket 01/12/2024   Page 2 of 5

  
-3- 
On October 20, 2023, the Government produced to the Defendant evidence that it had 
gathered during another investigation into COVID-relief fraud.  [ECF No. 94].1  This evidence 
related to C.D., the victim of the Defendant’s aggravated identity theft in Count 9 of the indictment.  
On October 24, 2023, Magistrate Judge Lauren F. Louis held the first day of an evidentiary hearing 
on the Defendant’s Motion to Withdraw.  [ECF No. 95].  On November 29, 2023, the Government 
produced to the Defendant additional evidence related to C.D.  [ECF No. 98].  On October 31, 
2023, Judge Louis held the second day of the evidentiary hearing.  [ECF No. 96].   
On December 8, 2023, Judge Louis entered a Report and Recommendation, recommending 
that the Defendant’s Motion to Withdraw be denied.  [ECF No. 99].  The Defendant filed timely 
Objections to the Report and Recommendation [ECF No. 100].     
LEGAL STANDARD 
 
For “a pretrial matter not dispositive of a party’s claim or defense,” the “district judge in 
the case must consider timely objections and modify or set aside any part of the order that is clearly 
erroneous or is contrary to law.”  Fed. R. Crim. P. 59(a).  For “any matter that may dispose of a 
charge of defense,” the “district judge must consider de novo any objection to the magistrate 
judge’s recommendation.”  Fed. R. Crim P. 59(b)(3).  The Eleventh Circuit has held that “the 
validity of [a defendant’s] guilty plea” is a dispositive matter.  See United States v. Martinez-
Barrera, 348 F. App’x 533, 534 (11th Cir. 2009) (finding that the court lacked jurisdiction to 
review the defendant’s guilty plea for failure to file objections, and citing to section (b) of Rule 
59); United States v. Flores, 257 F. App’x 164, 165 (11th Cir. 2007) (same).   
 
1 The undersigned AUSA transferred from the Miami to the West Palm Beach branch of the United States 
Attorney’s Office in the middle of 2023, where he was assigned this investigation and began collecting and 
reviewing evidence. 
Case 1:22-cr-20326-KMM   Document 103   Entered on FLSD Docket 01/12/2024   Page 3 of 5

  
-4- 
If “specific objections to findings of facts are timely filed, the district court will conduct a 
de novo review of those facts.” United States v. Perez, No. 8:20-CR-83-CEH-JSS, 2021 WL 
1345973, at *3 (M.D. Fla. Apr. 12, 2021), aff’d, No. 21-12868, 2022 WL 3452470 (11th Cir. Aug. 
18, 2022).  If “specific objections to findings of facts are filed, the district court is not required to 
conduct a de novo review of those findings.”  See Garvey v. Vaughn, 993 F.2d 776, 779 n.9 (11th 
Cir. 1993). During a de novo review, “the district court is bound to defer to the factual 
determinations of the magistrate judge unless those findings are clearly erroneous.”  Id.  A “district 
court is not required to rehear witness testimony when accepting a magistrate judge’s credibility 
findings.” United States v. Cofield, 272 F.3d 1303, 1305 (11th Cir. 2001) (citing United States v. 
Raddatz, 447 U.S. 667, 675–76 (1980)).   
DISCUSSION 
The Defendant makes two objections to the Report and Recommendation.  First, the plea 
was involuntary. Second, newly discovered evidence warrants a withdrawal.  The Defendant’s 
objections are as follows:  
(1) “[The Defendant] only pled guilty because he felt his back was against the wall. His 
lawyer had abandoned him as far as he was concerned. And he had been threatened by 
people who did not want his trial to expose their involvement in the loan fraud scheme 
with which Mr. Lorquet was charged.”  [ECF No. 100 at 2]. 
 
(2) “[N]ewly discovered Brady evidence seriously challenges the notion that anyone used 
CD’s identity without her involvement in the fraudulent loan as alleged in connection 
with the aggravated identity theft offense charged in count 9. As such, the new evidence 
provides a fair and just reason for withdrawal of the guilty plea to count 9.”  Id. at 4. 
 
The Court should overrule the Defendant’s first objection to the Report and 
Recommendation.  The Defendant admits that this objection comprises the same “facts and 
arguments that he made in his motion to withdraw his guilty plea.”  Obj. at 2.  The Magistrate 
Judge reviewed these arguments and found them without merit.  The Magistrate Judge did not 
credit the Defendant’s claim that his lawyer would abandon him because the Defendant “did not 
Case 1:22-cr-20326-KMM   Document 103   Entered on FLSD Docket 01/12/2024   Page 4 of 5

  
-5- 
substantiate why he felt his back was up against a wall even if his retained counsel would not 
represent him at a trial; for example, he did not claim that he could not have retained new counsel 
or asked for appointed counsel.”  R&R at 9.  The Magistrate Judge did not credit the Defendant’s 
claim that he was threatened because “[n]either the speaker nor the threat was identified,” and 
“nothing here would allow me to agree with his characterization that the communication, if it 
occurred at all, was in fact a threat.”  R&R at 10.  In his objections, the Defendant has not raised a 
reason why the Magistrate Judge’s finding is clearly erroneous.  For the reasons stated in the 
Government’s Response to the Motion to Withdraw, the Defendant’s true concern was being 
sentenced by the Court [ECF No. 86 at 8–9].  
The Court should overrule the Defendant’s second objection to the Report and 
Recommendation.  The Defendant is correct that the Government has discovered and produced to 
the Defendant evidence from a separate investigation into COVID-relief that overlaps with the 
Defendant’s.  This is not an objection to the R&R, however, because the R&R does not speak to 
this issue.  If, however, the Defendant’s objection is considered to be an amended motion to 
withdraw, the Court should deny it as moot.  The Government agrees to dismiss Count 9 of the 
indictment, which charges the Defendant with aggravated identity theft, at sentencing. 
Respectfully submitted,        
     
 
 
 
 
 
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 
 
CC: U.S Probation 
Case 1:22-cr-20326-KMM   Document 103   Entered on FLSD Docket 01/12/2024   Page 5 of 5

File and source

File
gov.uscourts.flsd.616975.103.0.pdf
Size
172,278 bytes
SHA-256
964dac53d51582bfee58a589806113f4b9a07400750319023e5fc4fec8d2deb3
Our copy
gov.uscourts.flsd.616975.103.0.pdf
Original
PACER (login required)
Back to top