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Home Court filings USA v. Vazquez — U.S. District Court, Southern District of Florida Unopposed MOTION to Continue Report Re: Counsel, Preliminary Examination and Arraignmen…

Court filing

Unopposed MOTION to Continue Report Re: Counsel, Preliminary Examination and Arraignment… — USA v. Vazquez (Dkt. 16)

Record facts

CourtU.S. District Court for the Southern District of Florida
Filed2021-04-09

Summary

Defendant Carlos Vazquez's amended unopposed motion to continue the report re: counsel, preliminary examination and arraignment in United States v. Carlos Vazquez, Case No. 21-mj-02512-CMM, in the U.S. District Court for the Southern District of Florida, filed April 9, 2021. The motion asks the court to move the April 12, 2021 hearing at 10:00 a.m. to April 26, 2021 so the defendant can secure funds to pay for his legal defense. It states that the initial appearance was on March 29, 2021 and that the $500,000.00 personal surety bond and $50,000.00 10 percent bond with a Nebbia requirement were satisfied on March 31, 2021. The defendant waives speedy trial for the continuance, and the motion reports that AUSA Hayden O'Byrne does not oppose. It is signed by defense counsel Jacob A. Cohen.

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Full text

UNITED STATES DISTRICT COURT 
 SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO:  21-mj-02512-CMM 
 
 
 
 
 
UNITED STATES OF AMERICA, 
 
 
 
 
Plaintiff, 
vs. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CARLOS VAZQUEZ,  
 
 
 
Defendant. 
____________________________________/ 
 
AMENDED UNOPPOSED MOTION TO CONTINUE REPORT RE: COUNSEL, 
 PRELIMINARY EXAMINATION AND ARRAIGNMENT 
 
 
The Defendant, Carlos Vazquez, by and through his undersigned counsel and pursuant to 
the Federal Rules of Criminal Procedure, respectfully requests that the Honorable Court enter an 
Order continuing the April 12, 2021 at 10:00 a.m. hearing date for the Report Re: Counsel, 
Preliminary Examination and Arraignment to April 26, 2021.  As grounds for this request, the 
Defendant states the following:   
 
1.  Mr. Vazquez’ initial appearance is on March 29, 2021. [DE 6]. 
2. Mr. Vazquez satisfies the $500,000.00 personal surety bond and the $50,000.00                  
10 percent bond with a Nebbia requirement ordered in this case [DE 6] on March 31, 2021. 
3.  The Report Re: Counsel, Preliminary Examination and Arraignment hearing date is set 
for April 12, 2021 at 10:00 a.m. [DE 6]. 
4.  Mr. Vazquez requests that the Honorable Court continue this hearing to April 26, 2021 
so that he can secure the funds to pay for his legal defense in this case. 
5.  Mr. Vazquez waives his right to a speedy trial for the purpose of this continuance request. 

 
2 
6.  AUSA Hayden O’Byrne does not oppose Mr. Vazquez’ request for a two-week 
continuance.  
WHEREFORE, Mr. Vazquez respectfully requests that the Honorable Court grant the relief 
requested in this Unopposed Motion to Continue the April 12, 2021 at 10:00 a.m. hearing date for 
the Report Re: Counsel, Preliminary Examination and Arraignment to April 26, 2021. 
CERTIFICATE OF SERVICE 
 
 
I HEREBY CERTIFY that on April 9, 2021, I electronically filed the foregoing document with the 
Clerk of the Court using CM/ECF.  I also certify that the foregoing document is being served this 
day on all counsel of record or pro se parties, either via transmission of Notices of Electronic Filing 
generated by CM/ECF or in some other authorized manner for those counsel or parties who are 
not authorized to receive electronically Notices of Electronic Filing.  
 
Respectfully submitted, 
 
JACOB A. COHEN, ESQ. 
Law Offices of Jacob A. Cohen, PLLC 
 
 
 
 
 
 
750 South Dixie Highway 
 
 
 
 
 
 
Boca Raton, FL 33432 
 
 
 
 
 
 
Telephone 561-715-7866 
 
 
 
 
 
 
E-mail – jacob@jacobcohenlaw.com  
 
By: /s/ Jacob A. Cohen, Esq. 
 
 
 
 
 
 
       Jacob A. Cohen, Esq. 
                                                                               Fla. Bar No. 0162530

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gov.uscourts.flsd.591071.16.0.pdf
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Our copy
gov.uscourts.flsd.591071.16.0.pdf
Original
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  1. Text of Proposed Order — USA v. Vazquez (Dkt. 16.1)same docket · 2021-04-09
  2. INDICTMENT and FORFEITURE as to Carlos Vazquez (1) count(s) 1-2. (mdc) (mdc). (Main Document… — USA v. Vazquez (Dkt. 19)same docket · 2021-04-15
  3. Text of Proposed Order — USA v. Vazquez (Dkt. 14.1)same docket · 2021-04-08
  4. Order Setting Jury Trial as to Carlos Vazquez — USA v. Vazquez (Dkt. 20, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same docket · 2021-04-20
  5. $500K PSB Bond Entered as to Carlos Vazquez Approved — USA v. Vazquez (Dkt. 12, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same docket · 2021-04-02
  6. Order granting 8 Motion to Modify Conditions of Release as to Carlos Vazquez (1) — USA v. Vazquez (Dkt. 9, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same docket · 2021-03-31
  7. Government's Response to the Standing Discovery Ordersame docket · 2021-05-10
  8. Text of Proposed Order — USA v. Vazquez (Dkt. 8-1, S.D. Fla. No. 1:21-mj-02512)same case · 2021-03-31
  9. Government's Second Response to the Standing Discovery Ordersame case · 2021-05-18
  10. Agreed Motion to Modify Conditions of Release — USA v. Vazquez (Dkt. 8, S.D. Fla. No. 1:21-mj-02512)same case · 2021-03-31
  11. Motion to Continue Calendar Call by Carlos Vazquez. Responses due by 6/30/2021 — USA v. Vazquez (Dkt. 25, S.D. Fla. No. 1:21-mj-02512)same case · 2021-06-16
  12. Notice of Temporary Attorney Appearance — USA v. Vazquez (Dkt. 7, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same case · 2021-03-31
  13. Order Continuing Trial as to Carlos Vazquez — USA v. Vazquez (Dkt. 26, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same case · 2021-06-17
  14. $50K 10% PSB Bond Entered as to Carlos Vazquez Receipt — USA v. Vazquez (Dkt. 13, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same case · 2021-03-31
  15. ORDER SETTING TRIAL as to Carlos Vazquez:… — USA v. Vazquez (Dkt. 29)same case · 2021-07-13
  16. Notice of Seizure of Firearm by USA as to Carlos Vazquez — USA v. Vazquez (Dkt. 11, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same docket · 2021-03-31
  17. ORDER SETTING TRIAL as to Carlos Vazquez:… — USA v. Vazquez (Dkt. 33)same docket · 2021-07-23
  18. Stipulation and Order as to Carlos Vazquez re: Nebbia Conditions — USA v. Vazquez (Dkt. 10, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same docket · 2021-03-31
  19. Permanent Notice of Appearance (Trial Only) — USA v. Vazquez (S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)same docket · 2021-07-27

Part of: USA v. Vazquez · U.S. District Court for the Southern District of Florida · Paycheck Protection Program (PPP) · Criminal prosecutions · Motions · 2021 · Court filings

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