Renewed Motion to Continue Sentencing Hearing by Carlos Vazquez. Responses due by 11/29/2021 — USA v. Vazquez (Dkt. 60, 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. 60 · 2021-11-15 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
 
SOUTHERN DISTRICT OF FLORIDA 
 
 
 
 
CASE NO. 21-20231 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
 CARLOS VAZQUEZ, 
Defendant. 
                                                             / 
 
 DEFENDANT VASQUEZS’ EMERGENCY RENEWED MOTION FOR 
CONTINUANCE 
 
COMES NOW, undersigned counsel for Defendant CARLOS VAZQUEZ, and files 
this, his Renewed Motion for Continuance and would furthermore state as follows:  
1. 
Defendant Vazquez is scheduled for Sentencing on November 16, 2021 at 
1:00p.m. 
2. 
Defendant Vasquez was in the hospital for a week and was discharged on 
November 14, 2021.  The undersigned has in his file a copy of the hospital discharge 
instructions. The Defendant was admitted with cardiomyopathy 45% and he is in declining 
health.   
3. 
In addition, the Government is seeking sentencing enhancements which 
concern his Immigration status.  The undersigned had scheduled a meeting with the 
prosecutor over a week ago to review the defendant’s Immigration file, however, the 
meeting was cancelled by the prosecutor.  The documents were reportedly made available 
for pickup this past Friday, however, the undersigned was unavailable to pick them up.   
Case 1:21-cr-20231-DMM   Document 60   Entered on FLSD Docket 11/15/2021   Page 1 of 3

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4. 
The undersigned is not seeking to delay this matter, however, does need 
additional time to review documents and speak to his client further with regard to the issues 
to be confronted at Sentencing.  Also, the Defendant’s health is in jeopardy.   
5. 
The Government opposes this requested relief.  
 
WHEREFORE, the undersigned would respectfully request that this Honorable 
Court grant the foregoing motion. 
 
 
 
 
 
 
 
 
CERTIFICATE OF SERVICE 
I hereby certify that on November 15, 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. 
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 60   Entered on FLSD Docket 11/15/2021   Page 2 of 3

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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 60   Entered on FLSD Docket 11/15/2021   Page 3 of 3

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