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)

Summary

In this Unopposed Motion to Continue, filed in Case No. 21-20231-CR-DMM in the Southern District of Florida, defendant Carlos Vazquez asks to continue the Calendar Call for 60 days. The calendar call is set before the Honorable United States Judge Donald M. Middlebrooks on June 22nd, 2021 at 10:30 a.m. The motion says the government tendered initial discovery on or about May 11th, 2021, is still providing outstanding discovery, and that the defense needs more time to prepare. It says Assistant United States Attorney Hayden O'byrne has no objection and asks that the trial date and associated deadlines also be extended, with a certificate of service dated June 15, 2021.

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UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF FLORIDA 
 
 
 
UNITED STATES OF AMERICA  
     CASE NO. 21-20231-CR-DMM 
 
Plaintif, 
v. 
 
CARLOS VAZQUEZ, 
 
Defendant.  
___________________________/ 
 
 
UNOPPOSED MOTION TO CONTINUE   
 
 COMES NOW, the Defendant, Carlos Vazquez, through undersigned counsel, moves the 
court to continue the Calendar Call date in this matter for a period of 60 days and states 
the following as grounds therefore: 
 
1. 
This matter is set in front of the Honorable United States Judge Donald M.
 
Middlebrooks for Calendar Call on June 22nd, 2021 at 10:30 a.m.  
2. 
On or about May 11th, 2021, The Government tendered initial discovery pursuant  
to the Standing Discovery Order.  
3. 
The Government is still in the process of providing several items of outstanding  
Discovery to Defendant. 
4. 
Discovery is ongoing and Defendant requires additional time to adequately  
            prepare this matter. 
5. 
The Government, through Assistant United States Attorney Hayden O’byrne has 
            indicated that it has no objection to the relief sought in this Motion. 
 
WHEREFORE, Defendant respectfully requests that Calendar Call, Trial date, and all 
associated deadlines in the matter be extended for a period of 60 days. 
 
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing notice was served by 
electronic filing on this 15th day of June 2021. 
 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
CARLOS M. FLEITES, P.A. 
 
 
 
 
 
 
Attorney for the Defendant 
 
 
 
 
 
 
407 Lincoln Road, Suite 12-E 
 
 
 
 
 
 
Miami Beach, Florida 33139  
 
 
 
 
 
 
Tel: (305) 672-8434 
 
 
 
 
 
 
Fax: (305)534-7087  
 
 
 
 
 
 
FL. Bar No.: 0370850 
 
 
 
 
 
 
Cmfleites@mylawyr.com 
 
                                    
 
BY:/s/Carlos M. Fleites  
 
  
 
 
 
 
 
        CARLOS M. FLEITES, ESQ.

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