Motion to Continue Sentencing Hearing by Carlos Vazquez. Responses due by 11/15/2021 — USA v. Vazquez (Dkt. 51, 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. 51 · 2021-11-01 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
 
SOUTHERN DISTRICT OF FLORIDA 
 
MIAMI DIVISION 
 
 
CASE NO. 21-20231-CR-MIDDLEBROOKS 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
 
CARLOS VAZQUEZ, 
Defendant. 
                                                             / 
 
 DEFENDANT VAZQUEZS’MOTION TO CONTINUE SENTENCING 
 
COMES NOW, undersigned counsel for Defendant CARLOS VAZQUEZ and files 
this, his Motion to Continue the Sentencing scheduled for November 16, 2021 and would 
furthermore state as follows:  
1. 
Sentencing in this matter is scheduled for November 16, at 1:30 p.m.   
2. 
Defendant Vasquez is requesting additional time to be fully prepared.  The 
Government is seeking a 2 level enhancement for obstruction of justice on matters 
seemingly collateral to the offense herein.  In addition, the Defendant has entered a guilty 
plea, has  accepted responsibility, yet the Government and Probation are taking the position 
that he be denied an offense level reduction for acceptance. 
3. 
The Defendant and counsel need additional time to be able to adequately 
respond to the allegations alleged in the Government’s Objections filed at D.E. 50.  In 
addition, the Defendant’s bond conditions were modified which resulted in his living in the 
apartment he has been living in (5249 NW 7th Street), wherein he initially was ordered to 
Case 1:21-cr-20231-DMM   Document 51   Entered on FLSD Docket 11/01/2021   Page 1 of 3

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be staying with an Annabel Lee at her residence.  This was apparently changed at the 
request of probation and to this date, the Defendant has never been told why this condition 
was modified.   
4. 
Finally, as a result of the remote nature of PSI interviews certain medical 
releases were not signed and it is essential that the Court has a complete picture of his 
medical issues, not only for the determination of an appropriate sentence, but for BOP 
designation as well.  
5. 
The undersigned was not in this case when Mr. Vazquez tried on 2 occasions 
to plead guilty, however, after extensive attorney client communication, his plea was 
accepted.  The Defendant at no time intended to delay the proceedings but does need an 
opportunity to clarify the allegations being levied by the Government which could greatly 
affect the ultimate outcome of this case.   
6. 
The Government opposes the requested relief. 
 
WHEREFORE, the undersigned would respectfully request that this Honorable 
Court grant the foregoing motion. 
 
 
 
 
 
 
ALBERT Z. LEVIN, P.A. 
Courthouse Center 
40 N.W. 3rd Street, Suite 200 
Miami, FL  33128 
Tel: 305-379-7101 
Fax: 305-381-6869 
albert@albertlevinlaw.com 
 
By:   /s/ Albert Z. Levin, Esq. 
Florida Bar No.: 316581
Case 1:21-cr-20231-DMM   Document 51   Entered on FLSD Docket 11/01/2021   Page 2 of 3

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CERTIFICATE OF SERVICE 
I hereby certify that on November 1, 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. 
Florida Bar No.: 316581 
 
ALBERT Z. LEVIN, P.A. 
Courthouse Center 
40 N.W. 3rd Street, Suite 200 
Miami, FL  33128 
Tel: 305-379-7101 
Fax: 305-381-6869 
albert@albertlevinlaw.com 
 
 
 
Case 1:21-cr-20231-DMM   Document 51   Entered on FLSD Docket 11/01/2021   Page 3 of 3

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