Court filing
Transcript of evidentiary hearing cont'd as to Andre Lorquet — USA v. Lorquet (Dkt. 129, S.D. Fla.)
Filed May 28, 2024 in USA v. Lorquet; one of 145 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2024-05-28 |
U.S. District Court for the Southern District of Florida · No. 1:22-cr-20326-KMM · Doc. 129 · 2024-05-28 · Docket on CourtListener
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
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MIAMI DIVISION
CASE NO. 22-cr-20326-KMM
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UNITED STATES OF AMERICA,
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Plaintiff,
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vs.
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Miami, Florida
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October 31, 2023
ANDRE LORQUET,
Pages 1-22
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Defendant.
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________________________________________________________________
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TRANSCRIPT OF EVIDENTIARY HEARING (Cont'd)
BEFORE THE HONORABLE LAUREN FLEISCHER LOUIS
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UNITED STATES MAGISTRATE JUDGE
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APPEARANCES:
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FOR THE PLAINTIFF:
By: Jonathan Bailyn, A.U.S.A.
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United States Attorney's Office
99 Northeast 4th Street
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Miami, Florida 33130
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FOR THE DEFENDANT:
By: Henry Philip Bell, Esq.
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Bell, Rosquete, Reyes, Esteban, PLLC
999 Ponce De Leon Boulevard
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Suite 1120
Coral Gables, FL 33134
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TRANSCRIBED BY:
DAWN M. SAVINO, R.P.R., C.R.R.
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Official Federal Court Stenographer
111 North Adams Street
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Tallahassee, Florida 32301
Telephone: 850-521-3674
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Dawn_Savino@flnd.uscourts.gov
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P-R-O-C-E-E-D-I-N-G-S
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COURTROOM DEPUTY: All rise. The United States
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District Court for the Southern District of Florida is now in
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session, the Honorable Lauren Luis presiding.
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Calling case number 22-20326-criminal-Judge Moore,
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United States versus Andre Lorquet.
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Counsel, would you please note your appearances for the
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record, beginning with the government.
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MR. BAILYN: Good morning, Your Honor. Jonathan Bailyn
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on behalf of the United States. I'm joined here at counsel's
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table with Special Agent Jose Hernandez of Homeland Security.
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THE COURT: Thank you.
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MR. BELL: Good morning, Judge. Henry Bell on behalf
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of Mr. Lorquet, the defendant, who is, of course, in court
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standing to my left.
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THE COURT: Thank you so much. And to the deputy
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marshals, I thank you for letting Mr. Lorquet out of cuffs for
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the hearing.
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Go ahead and have a seat, everybody.
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We had taken a recess at our last hearing to give you
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all a chance to decide how you wanted to proceed from last week.
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Who wants to bring me up to date?
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MR. BELL: I'm sorry, Judge. My client was telling me
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something. I apologize.
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So Judge, we did sort of explore some stuff, but in any
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event, we don't have an agreement. I think each party is
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essentially arguing for their respective positions here.
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THE COURT: Okay. Okay. We had stopped sort of
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mid-summation. I don't know if "closing" is the right word, but
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each side was kind of cut off from their opportunity to argue
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their position. So you have the floor if there's anything else
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that you want me to consider or to be heard on. It's your
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motion, Mr. Bell. If you want the floor first?
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MR. BELL: Sure. Thank you, Judge. I'll be brief.
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This has been fully briefed. You heard Mr. Lorquet testify.
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The crux of his testimony was that he had repeatedly told his
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attorney that he did not want to plead guilty and that he felt
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pressured and as if he had no choice but to go through the
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hearing, in which he ultimately pled guilty. I understand the
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government's position, and even the questioning elicited or
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conducted by the court, sort of pointing out that the transcript
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of the hearing and the reality of that hearing was that he
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answered questions that communicated that he understood what he
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was doing, and that he was doing so voluntarily, and that if he
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really had an opportunity to back out of the plea at that point
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and that he didn't do that.
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Acknowledging or accepting that argument and evidence,
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if you will, I would point out that from Mr. Lorquet's
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perspective, however, as a layperson who was relying on his
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lawyer, he felt like he was in a place where he really couldn't
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do anything else but go forward with the plea.
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And that's the bottom line of the argument. And I
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don't know if the court has any questions, but I don't know that
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I have any more to argue about it.
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THE COURT: I do. I don't -- you don't -- I'll leave
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it to you to decide how you want to answer it, if at all, but I
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don't mind telling you my observations and my concerns about how
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to weigh the credibility, as I told you last time, of
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Mr. Lorquet's testimony from one day to the next.
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And so the things that stuck out for me were, for
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example, learning or hearing at the second hearing your
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inability to read and write when I asked you that question at
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the change of plea. And while you have told me that you felt
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pressured to limit your answers to yes or no, you answered yes
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to that question and you could have answered no, and it feels
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confusing and unexplained why that would be the result of being
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pressured by your attorney. And it makes me, again, question
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which Mr. Lorquet I should believe from one day to the next.
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And that is just but one example. There was
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immediately after that another question that now I don't have in
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front of me, but that your answer was different than how you
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would have answered it at this hearing.
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I know what it is. It was with respect to mental
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disease or illness, and not perhaps revealing the impediment
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that would have maybe prevented you from understanding the plea
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agreement and the factual proffer.
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So again, it's not so much a direct question as my
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candid sharing with you my inability to, you know, sit here and
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tell you that from one hearing to the next I know which of your
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statements to credit. And so that makes it difficult for me.
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MR. BELL: Understood, Your Honor. And sort of -- I
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appreciate where the court is coming from, and let me try, in
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some way, at least to address those concerns as expressed by
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Your Honor.
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So first with respect to not having revealed his issues
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with reading and writing, I mean, let me sort of address that
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point if I may. So this is not something that was known to me,
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right. It's not like Mr. Lorquet came out and told me I have a
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problem, I have a disability or impediment. A learning
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disability as apparently it was explained to him as a child. I
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didn't understand that to be the case at all when I started to
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represent him. It was only over time as I went to FDC to
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discuss copies of the motions that -- I gave him a copy and I
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noticed that he was taking a long time getting through it, and
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then he was asking me about certain words, what does this mean,
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that I fleshed out that there's a problem.
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THE COURT: Okay.
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MR. BELL: And to be fair and clear and fully
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transparent about this issue, it's not a situation where
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Mr. Lorquet can't read anything at all and can't write anything
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at all. It's just not very good, if you will. There are
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certain words that he needs his lawyer to explain to him, and if
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I receive something in writing from him I can tell that -- I can
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tell when it's been written by him and I can tell when it hasn't
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been.
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THE COURT: Understood.
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MR. BELL: Okay?
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THE COURT: Okay.
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MR. BELL: And maybe that -- I do think it's -- how
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should I say this. It's not something he enjoys talking about,
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and perhaps it's somewhat humiliating to have to admit to this
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openly.
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THE COURT: Thank you, Mr. Bell.
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MR. BELL: And then in terms of assessing the
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credibility, look, the way I see this, I don't think that it's
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really that he's changed his story so much and evaluating the
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standard and whether it's been met or not.
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THE COURT: The standard of what?
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MR. BELL: The standard that the court has to evaluate
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and whether to withdraw the plea. Right? I mean, it's what
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really rises to the level of involuntariness or not. The
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government is going to argue that hey, even if you credit my
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client's testimony, that you still shouldn't grant this motion,
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and I disagree with Mr. Bailyn about that. But I think that's
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where the issue is. It's not so much that he changed his story,
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but whether or not what he went through rises to the level of
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warranting Your Honor granting the motion. And I don't know if
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I'm making myself clear.
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THE COURT: I understand it now.
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MR. BELL: And I say that because I sense -- well, not
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sense. The court is overt in mentioning the issues of
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credibility here and whether you believe my client's testimony
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and whether he was misleading you in some way. And I don't
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think he was misleading you. I just think that putting
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ourselves in his shoes, if you will, even though he told the
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court at the change of plea that he was acting voluntarily and
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that he wanted to plead guilty, that down inside apparently,
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according to him, that it was a emotional hearing, overtly
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emotional, if the court would have seen him crying or something
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to that effect, and that behind the scenes he felt pressured by
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his lawyer. Whether or not that rises to the level of this
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court having to grant the motion, I will let the court decide
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and I will disagree with Mr. Bailyn's arguments that are
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obviously diametrically opposed to mine. But from the
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defendant's perspective, he felt as if he had no choice and
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that's -- it's not that he didn't know what was happening or
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that someone put a gun to his head, but it is that he -- things
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had broken down with his lawyer, and he felt that he had no
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choice and he felt that his lawyer would not continue to labor
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in defending and representing him at trial, and that it was a
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very emotional situation. And none of this is made any better
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by the fact that he does have a reading comprehension problem.
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THE COURT: Okay.
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MR. BELL: And some kind of impairment, the bottom of
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which I haven't really gotten to, to be candid. I don't know
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the full extent of it, but I have some ideas.
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THE COURT: Understood. Okay. And I guess at the end
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of the day, I really just have to ask the direct question: Do
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you want to go to trial?
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THE DEFENDANT: Yes, ma'am.
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THE COURT: Mr. Bailyn?
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MR. BAILYN: Thank you, Your Honor.
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THE COURT: Can I likewise forecast for you what I'm
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thinking about?
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MR. BAILYN: Absolutely, Your Honor.
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THE COURT: I can't remember, and candidly couldn't
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find where I read that part of the government's opposition
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because I think -- did you take the position that one of the
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factors the court should consider is the impact on the victim
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who does not want to go to trial?
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MR. BAILYN: Yes, Your Honor. That's in the -- that
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would be the fourth buck {als} factor, which was the --
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THE COURT: But did you -- I mean, are you taking that
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position, or did I just understand Mr. Bell to be responding to
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what he anticipated your position to be? Do you take the
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position that the court should not allow Mr. Lorquet to withdraw
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his plea because of the impact on the purported victim?
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MR. BAILYN: That is a consideration.
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THE COURT: But is it still your position.
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MR. BAILYN: Well, we've removed it from our -- our
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second opposition -- Your Honor, if I can, I think you're
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probably remembering there was a first motion to withdraw. In
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the response that was added.
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THE COURT: That's why I couldn't find it. I didn't go
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back that far. So that had been the government's position.
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MR. BAILYN: Yes.
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THE COURT: But you're not traveling on the victim
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shouldn't have to go through this again.
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MR. BAILYN: No, Your Honor. That's a very close read,
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but as things have changed the government's position on that
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particular consideration sub-factor has changed as well.
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THE COURT: Okay. So as you sit or stand here, you are
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prepared to go to trial and present the victim who is the
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subject of the aggravated identity count.
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MR. BAILYN: We are, Your Honor. However, I'm still,
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as we mentioned the last time, conducting my investigation up in
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Palm Beach. It's possible that what that trial will look like
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will be different than how it was indicted.
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THE COURT: Understood. I just want to make sure that
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I -- because if that was -- I wanted to make sure the government
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wasn't traveling on any representation that the victim has
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decided to forgo any right to restitution because it would be so
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traumatic to go through a trial. But that's not the
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government's position.
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MR. BAILYN: No, Your Honor. And your close read
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certainly noticed the difference between our position, so I
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appreciate that. Thank you.
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THE COURT: Done my best.
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MR. BAILYN: No, it's great.
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So let me just first address the credibility of the
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defendant briefly, and the story that I believe has changed.
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In his first motion to withdraw, the defendant argued
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that he believed the plea hearing we were at was a bond
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revocation hearing and that he was under duress by his attorney.
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Now that's changed. That changed in the second motion
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to withdraw. He believed that he was supposed to go to a bond
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revocation hearing, but again, that he was still under duress by
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his attorney.
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Then when he testified before Your Honor, we heard a
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new allegation, that the duress didn't just come from his
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attorney but it came from some third parties who were
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threatening him. We don't know who those were or how they were
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threatening him, but he said that he was being threatened.
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It's hard to get a grip as to what the defendant's
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exact position and rationale is, but if it is what has been
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stated, at least repeatedly, that this was duress by his
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attorney, I just find that not to be credible.
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THE COURT: Can I give you -- again, forecasting where
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you need to go and not need to go?
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MR. BAILYN: Sure.
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THE COURT: The assertion that there are third parties
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who were pressuring him is too vague for me to do anything with.
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I am focused on the relationship between him and his attorney.
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So you're welcome to make the record you want, but I will just
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tell you you don't have to persuade me that that is not a basis
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that has been substantiated.
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MR. BAILYN: Okay. Thank you, Your Honor.
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Then allow me one moment to switch gears. I'm not
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privy to the conversations the defendant had with his attorney,
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but I will say what I'd said in my motion, that the defendant
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had privately retained counsel, spent thousands of dollars for
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privately retained counsel. Ms. Bozanic is a certified criminal
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trial attorney. She's practiced before this court, she's
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well-aware of the sentencing guidelines, how pleas work. And
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when she represented to the court that she had reviewed
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everything with the defendant, I don't believe that the
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defendant's statement that he felt pressured should contradict
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that.
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But even if he did feel pressured, the defendant, when
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he testified, never articulated any pressure that would rise to
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a legal reason for the plea to have found to be sort of
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involuntarily or unknowing.
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So the standard or -- under the Buckles ruling, which
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is 843 F.2d at 472, is quote, a defendant cannot complain of
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coercion where his attorney, employing her best professional
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judgment recommends that the defendant plead guilty. I have no
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doubt that Ms. Bozanic recommended that the defendant plead
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guilty, and he has a lot of benefits from this plea agreement
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despite claiming that it's an open plea.
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The statutory maximum term of imprisonment has been
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reduced, because he pled guilty to money laundering, not wire
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fraud.
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The government has agreed to recommend a two-level
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reduction for acceptance of responsibility, even though Judge
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Moore disagrees with the government's assessment. We've
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maintained that position because it's within the plea agreement.
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So there were benefits that he received.
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And he has not articulated, and did not testify, that
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Ms. Bozanic did anything that would be a true pressure or
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coercion. She never physically threatened him, she never, as I
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understood it, threatened to withdraw as counsel or do anything
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to undermine his case.
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I'm not sure what the duress is. But I do know that
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when the defendant testified, he repeatedly used the term
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duress. Using that term, for someone who allegedly doesn't read
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or write well, is peculiar, because duress is a legal term.
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It's not the term that most people consider when they're forced
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to do something.
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And I think it's very telling. I think the defendant
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has, through whatever jailhouse attorney he's consulted with,
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learned about what the appropriate legal standard is and found a
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way to sort of wedge whatever he believes happened to him into
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that particular standard.
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THE COURT: Mr. Bailyn, I'm not going to rely on
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speculation from the government any more than vagueness from the
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defendant. So I understand that that may be what you surmise
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happened, but I have to make a record.
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MR. BAILYN: Sure. So then, Your Honor, that was
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argument.
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But as a pure factual matter, we have nothing here that
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would show that there was anything to color that claim of
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duress. We have no factual allegations that would -- or
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testimony from the defendant that would allow us to understand
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what that, quote, duress is.
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Your Honor, I can focus on this, the four Buckles
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considerations briefly, unless Your Honor doesn't need argument
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on those areas.
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THE COURT: I would encourage you to make the record
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that you want. There's going to be a report and recommendation
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and thus objections, so you have the floor.
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MR. BAILYN: Thank you, Your Honor. So first, there's
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four factors. The first is whether the close assistance of
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counsel was available. The defendant has privately retained
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counsel. She was there during the plea hearing, I have no doubt
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that she, although I'm not privy to her conversations, advised
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the defendant. I certainly was in contact with her frequently.
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Second, whether the plea was knowing and voluntary. As
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the government explained in its motion, the plea agreement was
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written, was reviewed with the defendant, he answered all of the
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court's questions appropriately, and the court made a
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recommendation that it was knowing and voluntary. The
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allegation the defendant has made that he was under duress I
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believe is not something that can be factually supported.
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Third, whether judicial resources would be conserved.
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I think that's obviously in this case. We've already expended a
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significant amount of judicial resources just with two motions
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to withdraw, the sentencing hearings that have had to be
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continued, the appointment of court counsel.
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THE COURT: But it's not about backward-looking
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inquiry, it's forward-looking.
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MR. BAILYN: Sure. So we would be avoiding, I think,
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the need for the court to have a trial; the court to have a
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sentencing hearing all over again to simply repeat what it had
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already done.
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THE COURT: Isn't that always the case on a motion to
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withdraw a guilty plea? I find it a difficult factor to assess
2
myself, and that's why I'm asking you. How is this different
3
from a motion that gets granted?
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MR. BAILYN: So Your Honor, I also understand that. So
5
I've had to look at the way that Judge Moore has considered this
6
factor, and in my briefing I've cited a couple of cases of his.
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And if you don't mind may I just read --
8
THE COURT: Of course.
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MR. BAILYN: Sure. So in two cases in which Judge
10
Moore denied the defendant's motion to withdraw the plea, he
11
explained that judicial resources should not be expended, quote,
12
in the conduct of a trial on issues to which the defendant has
13
already freely admitted.
14
So in this case the defendant has admitted particular
15
facts, and we would then be having a trial to re-establish facts
16
that the defendant has already admitted. That would be a use of
17
judicial resources to prove what has already been proven.
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THE COURT: Were there factual objections filed to the
19
PSI? Are there facts in dispute at sentencing? Were there?
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MR. BAILYN: The government didn't file factual
21
objections to the PSI, Your Honor.
22
THE COURT: Did you have to respond to factual
23
objections to the PSI filed by the defendant?
24
MR. BAILYN: So let me just briefly go back. They
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weren't -- it's hard to parse factual -- the dispute was between
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whether or not the defendant's application for a passport would
2
rise to the level of obstruction of justice. One of the facts
3
in that would have been the purpose of applying for that
4
passport, but those factual allegations were outside the
5
relevant offense conduct.
6
THE COURT: Hmm-hmm.
7
MR. BAILYN: That was post-indictment conduct.
8
THE COURT: Did you come to the sentencing hearing
9
prepared to put on evidence?
10
MR. BAILYN: I did, Your Honor.
11
THE COURT: I'll be candid with you. The only time
12
that I had a defendant withdraw her plea in front of Judge
13
Moore, it was because of contested facts at sentencing and that
14
the sentencing was going to essentially be a trial, and he tried
15
the case instead of going forward with the sentencing.
16
MR. BAILYN: Oh, I see. So in this case the sentencing
17
hearing would not have been that. I was prepared to put on
18
evidence and testimony from the agent about the reason for
19
applying for a passport, as well as to show just pictures of
20
what the defendant had spent the stolen money on. But in terms
21
of the factual issues in the PSI and the offense conduct, that
22
wasn't at issue.
23
THE COURT: I don't know that it's determinative. I'm
24
just, again, sharing with you the questions that I have.
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MR. BAILYN: I understand, Your Honor.
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And then finally prejudice to the defendant. I guess I
2
have to speak personally then. As the trial attorney I'm no
3
longer in Miami. I would have to be traveling down to Miami,
4
and I know that's a minimal imposition, but my trial partner has
5
been called to military duty so we'll have to find another trial
6
partner to prepare this case.
7
The government was prepared to go to trial. The
8
defendant pled guilty shortly before the trial was supposed to
9
commence. Trying these cases so long after the offense conduct
10
can be quite difficult.
11
THE COURT: When did it occur?
12
MR. BAILYN: So the offense conduct occurred throughout
13
the COVID crisis. So in 2020 until the end of 2021. And the
14
reason for that --
15
THE COURT: I was thinking about the poor economic
16
crime section.
17
MR. BAILYN: And I'll explain that. What makes them
18
very difficult, Your Honor, is that -- well, we've all read the
19
news, a lot of the lenders that were providing these PPP loans
20
were recently instituted Fintech companies. Some of them have
21
absolutely no relationship to Florida other than the fact they
22
provided loans to people in Florida. That is one of the lenders
23
in this case, and I believe the name's in the factual proffer,
24
and it eludes me.
25
But corralling these witnesses to come to Florida is
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difficult because many of these lenders have other trials to
2
attend to now that these cases have become more manifold. These
3
are difficult cases to try, and there's a huge benefit to the
4
government when the defendant decides to plead guilty.
5
THE COURT: I understand this is going to sound like a
6
familiar response, but can I credit that generic complaint that
7
it is difficult to marshal them without evidence that any of the
8
particular witnesses would be difficult to corral?
9
MR. BAILYN: So I -- I could proffer, Your Honor, that
10
one of the witnesses, and I believe it's ALC Lending has -- I
11
did serve them with a trial subpoena for the previous trial.
12
Their counsel called me and said that they would not attend the
13
trial, and that we would have to litigate a motion to quash.
14
That eventuality didn't occur because the defendant chose to
15
plead guilty, but I don't know that would be like now. But
16
these things have happened.
17
THE COURT: Okay. I have to ask this candid question
18
in the same way that I asked Mr. Lorquet if he wanted a trial.
19
If you had to, is the government still prepared to
20
prove its case?
21
MR. BAILYN: Yes, Your Honor.
22
THE COURT: Is it still capable of proving its case?
23
MR. BAILYN: The government is capable of proving its
24
case. The trial would likely look slightly differently. We may
25
call more agent testimony to help explain some of the documents
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as opposed to some of the true custodians of the records, for
2
example, the lenders. But I still think that we can -- I don't
3
want to say "I still think", we certainly could prove our case
4
beyond a reasonable doubt. I could definitely marshal that
5
evidence.
6
THE COURT: Okay.
7
MR. BAILYN: So Your Honor, I think the standard to
8
withdraw your plea is a tough one, and it's the defendant's
9
burden. And I've not heard sufficient facts from the
10
defendant's testimony, other than this generic claim of duress,
11
that would rise to the level of an involuntary or an unknowing
12
plea. The defendant committed a significant amount of fraud.
13
All of this was paper fraud. So that would he certainly belie
14
any allegation that the defendant had trouble with comprehension
15
or anything like that. He certainly seemed to be comprehending
16
the PPP loan applications, and I believe that he had the ability
17
to comprehend the short plea colloquy as well.
18
THE COURT: Understood. All right. Thank you,
19
Mr. Bailyn.
20
Mr. Bell, if there's anything else?
21
MR. BELL: No, Judge. I don't know. Unless you have
22
any questions. I did notice you asked about the sentencing
23
hearing. I mean, we disputed an obstruction of justice
24
enhancement. Judge Moore unfortunately disagreed, which meant
25
that the defendant also lost his acceptance of responsibility
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according to Judge Moore. The issue was whether a bond
2
violation rose to the level of obstruction of justice or not.
3
The government conceded it did not, and was in agreement with
4
us, but Judge Moore had a different view.
5
THE COURT: Got it.
6
MR. BELL: To sort of put a fine point on your
7
question.
8
THE COURT: Understood. Okay. I'm going to write up
9
an R and R. If we can get it on file today, we will, but I'll
10
be candid with you, I do want to take it under advisement. I
11
want to read the change of plea colloquy one more time with the
12
benefit of your explanation, which was meaningful.
13
But, you know, Mr. Lorquet, you know, I've been direct
14
with you about what my concerns are, but Mr. Bell makes good
15
points. I will review it again before I render a final
16
decision. Any way around it you'll have the period of time to
17
object, to file objections to my findings or analysis therefrom
18
to Judge Moore, and he'll ultimately decide whether you'll be
19
permitted to withdraw the plea or to go to trial -- withdraw the
20
plea or not. Okay?
21
All right. If there's anything else, somebody let me
22
know. Otherwise I'm going to let you all go. From the
23
government?
24
MR. BAILYN: No, Your Honor. Thank you, Your Honor.
25
MR. BELL: May I have a moment?
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THE COURT: Of course.
2
MR. BELL: Okay. So there is one thing, although I
3
don't know if the court can address it or not, but since you
4
brought it up, and my client has brought it up, and my client's
5
mother has brought it up --
6
THE COURT: Okay.
7
MR. BELL: -- you asked me whether Mr. Lorquet had been
8
evaluated. The answer to the question is no, but we're probably
9
at a point where I'm being asked to seek that evaluation.
10
THE COURT: Okay. Like a 4142 evaluation? Okay.
11
So let me try to say it this way without saying too
12
much, a couple of things. First and foremost, whether you want
13
to advance anything under seal in writing, or if you want to do
14
-- if you want this discussed in open court at the hearing.
15
MR. BELL: That's a good point. I hadn't thought about
16
that. So why don't I file something, and I'll do it the
17
old-fashioned way.
18
THE COURT: I mean --
19
MR. BELL: You're right. You're absolutely right.
20
I'll do it the old-fashioned way. I'll put something in writing
21
under seal for the court.
22
THE COURT: I appreciate it.
23
MR. BELL: I'd forgotten about that, and I apologize to
24
you and to my client.
25
THE COURT: Listen, I'm the one who interjected it.
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MR. BELL: It's okay. But it's true.
2
THE COURT: Okay.
3
MR. BELL: Forgot there. But you're right.
4
Absolutely.
5
THE COURT: Got it.
6
MR. BELL: Thank you so much.
7
And then therefore we don't have anything further at
8
this time.
9
THE COURT: I appreciate it. Okay. Thank you
10
Ms. Lorquet for always being here in support of your son.
11
Okay. We're adjourned.
12
COURTROOM DEPUTY: All rise.
13
(PROCEEDINGS CONCLUDED)
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* * * * *
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C E R T I F I C A T E
I certify that the foregoing is a correct transcript
16
from the digital recording of the proceedings in the
above-entitled matter. Any redaction of personal data
17
identifiers pursuant to the Judicial Conference Policy on
Privacy is noted within the transcript.
18
19
5-28-2024 /s/ Dawn M. Savino, R.P.R., C.R.R.
Date
DAWN M. SAVINO, R.P.R., C.R.R.
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