Motion to Continue Trial by Carlos Vazquez. Responses due by 8/24/2021 — USA v. Vazquez (Dkt. 38, S.D. Fla. No. 1:21-mj-02512, docketed in No. 1:21-cr-20231)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:21-cr-20231-DMM · Doc. 38 · 2021-08-10 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 21-20231-MIDDLEBROOKS 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
 
CARLOS VAZQUEZ,  
Defendant. 
__________________________________/ 
 
MOTION FOR CONTINUANCE 
 
 
COMES NOW, undersigned counsel for Defendant CARLOS VAZQUEZ and files this, 
his Motion for Continuance and would furthermore state as follows: 
1.          This matter is set for trial on August 30, 2021, in the Miami Division of this 
Court. 
2.             On July 20, 2021, this Honorable Court granted Defendant’s request to relieve 
his prior counsel. This occurred at the 2nd setting of a change of plea hearing.   
3.             On July 27, 2021, the undersigned filed his Notice of Appearance on behalf of 
Mr. Vazquez.  
4.          Since entering his appearance, the undersigned has been working furiously, 
reviewing pertinent documents and conferring with Mr. Vazquez.  Unfortunately, Mr. 
Vazquez has been in ill health and was hospitalized the week after he appeared before 
this Honorable Court. Since his release from the hospital, he has experienced additional 
health related issues, which has interrupted the in person client conferences which had 
Case 1:21-cr-20231-DMM   Document 38   Entered on FLSD Docket 08/10/2021   Page 1 of 3

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been occurring between the undersigned and his client in order to be prepared for the 
August 30th setting. 
5.             The undersigned would respectfully be requesting a 3 week Continuance to 
allow for additional time for continued conversations and preparation of possible 
defenses to this matter.  It is anticipated, even though this matter has been set twice 
before for a change of plea, that Mr. Vazquez will in all likelihood be resolving this case 
with a change of plea and not a trial.   
6.                   The undersigned has conferred with Hayden P. O’Byrne, Assistant U.S. 
Attorney, who has no objection to the relief requested herein.  
                 
 
WHEREFORE, the undersigned respectfully requests that this Honorable Court grant the 
foregoing Motion. 
Respectfully submitted, 
By:  /s/ Albert Z. Levin, Esq.      
 
 
 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that on August 10, 2021, I electronically filed the foregoing document 
with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being 
served this day on all counsel of record via transmission of Notices of Electronic Filing 
generated by CM/ECF. 
 
 
 
 
 
 
By:  /s/ Albert Z. Levin, Esq.      
  
ALBERT Z. LEVIN, P.A. 
Courthouse Center 
Case 1:21-cr-20231-DMM   Document 38   Entered on FLSD Docket 08/10/2021   Page 2 of 3

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40 N.W. 3rd Street, Suite 200 
Miami, Florida 33128 
Telephone: (305) 379-7101 
Facsimile: (305) 381-6869  
Florida Bar No. 316581 
 
 
 
 
 
 
albert@albertlevinlaw.com 
 
Case 1:21-cr-20231-DMM   Document 38   Entered on FLSD Docket 08/10/2021   Page 3 of 3

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