Joint MOTION to Continue the Preliminary Hearing and the Arraignment by… — USA v. Denton - Cindi Ellis Denton (Dkt. 10)

Summary

Joint Motion to Continue the Preliminary Hearing and the Arraignment, Document 10, entered 04/20/2021 in Case 0:21-cr-60171-RS (CASE NO. 21-6149-HUNT), United States of America v. Cindi Ellis Denton, Southern District of Florida, three pages. The parties ask to continue both matters until May 21, 2021 from April 21, 2021, saying the government cannot seek an Indictment because of the unavailability of Grand Juries during the COVID-19 pandemic and the parties are negotiating to proceed by Information with a Waiver of Indictment. The motion states that Denton is charged by Criminal Complaint with wire fraud, bank fraud, and conspiracy/attempt to commit wire fraud/bank fraud, and is released on a $26,000 personal surety bond. It states that she waives her right to a preliminary hearing through May 21, 2021, and that the signature block names Manuel Gonzalez, Jr.

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UNITED STATES DISTRICT COURT 
 
SOUTHERN DISTRICT OF FLORIDA 
 
 
 
CASE NO.: 21-6149-HUNT   
 
UNITED STATES OF AMERICA 
 
 
 
 
Plaintiff, 
vs. 
 
 
 
 
 
 
 
 
 
 
 
 
 
CINDI ELLIS DENTON,   
 
Defendant. 
___________________________________/ 
 
 
JOINT MOTION TO CONTINUE  
THE PRELIMINARY HEARING AND THE ARRAIGNMENT 
 
 
The parties, through undersigned counsel, file this Joint Motion to Continue 
the Preliminary Hearing and Arraignment in this matter. The parties request that 
these matters be continued until May 21, 2021, and as grounds state:  
1. Ms. Denton is charged by Criminal Complaint with Wire Fraud, in violation 
of 18 U.S.C. §§ 1343 and 2, Bank Fraud, in violation of 18 U.S.C. §§ 1344 and 
2, and conspiracy/attempt to commit wire fraud/bank fraud, in violation of 18 
U.S.C. § 1349. [ECF No. 1] She is scheduled to appear on April 21, 2021, for 
her preliminary hearing and arraignment. [ECF No. 7] 
2. Ms. Denton, who resides in California, is currently released on a $26,000 
personal surety bond, with the conditions of bond as where set in the Central 
District of California. [ECF No. 7-8]    
3. Due to the unavailability of Grand Juries caused by the COVID-19 pandemic, 
the government is unable to seek an Indictment at this time. On April 6, 
2021, Chief Judge Moore ordered that “[jury] trials in the Southern District of 
Case 0:21-cr-60171-RS   Document 10   Entered on FLSD Docket 04/20/2021   Page 1 of 3

 
 
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Florida, … are continued until July 6, 2021.” Administrative Order 2021-33,  
Ninth Order Concerning Jury Trials and Other Proceedings. The Chief Judge 
further ordered that the period of any continuance during this time shall be 
excluded under the Speedy Trial Act until July 6, 2021. Two grand juries per 
week commenced on November 16, 2020. Id.  Furthermore, the parties are in 
negotiation to proceed by Information and the execution of a Waiver of 
Indictment.  
4. Ms. Denton, through counsel, acknowledges that she has discussed with 
counsel her right to a timely preliminary hearing or examination of probable 
cause. Counsel acknowledges that Ms. Denton waives her right to a 
preliminary hearing through May 21, 2021.    
5. Due to the ongoing pandemic, and in light of the Chief Judge’s Order, the 
government’s inability to present this case to a Grand Jury, and the parties 
ongoing negotiations, the parties request that the preliminary hearing and 
arraignment be continued until May 21, 2021.    
6. Counsel for the government, Assistant United States Attorney Lindsey 
Friedman, joins in this motion. The parties agree that the ends of justice 
served by continuing this matter outweigh the interests of the parties and the 
public in a speedy trial. 
Respectfully submitted,  
 
 
 
 
 
 
MANUEL GONZALEZ, JR., ESQ. 
 
 
 
 
 
 
 
By: 
 /s/ Manuel Gonzalez, Jr.                                      
 
 
 
 
 
  
Florida Bar No.: 0397997 
Case 0:21-cr-60171-RS   Document 10   Entered on FLSD Docket 04/20/2021   Page 2 of 3

 
 
3
 
 
 
 
 
 
 
                                                                 121 Alhambra Plaza, Suite 1500  
 
 
 
 
 
 
Coral Gables, Florida 33134 
 
 
 
 
 
 
Tel: (305) 444-1400  
 
 
 
 
 
 
Fax: (305) 938-5009  
 
 
 
 
 
 
E-mail: mannylaw7@yahoo.com 
 
 
 
CERTIFICATE OF SERVICE 
 
 
I HEREBY certify that on April 20, 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 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. 
 
 
 
 
 
 
 
 /s/ Manuel Gonzalez, Jr. 
nuel Gonzalez, Jr. 
nuel Gonzalez, Jr. 
nuel Gonzalez, Jr. ________                                 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 0:21-cr-60171-RS   Document 10   Entered on FLSD Docket 04/20/2021   Page 3 of 3

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