Unopposed MOTION for Extension of Time for 1-week extension of… — USA v. Denton - Cindi Ellis Denton (Dkt. 18)

Summary

Document 18, a three-page Second Unopposed Motion for a One-Week Extension of Arraignment, filed 06/18/2021 by the government in the Southern District of Florida, United States v. Cindi Ellis Denton. The arraignment is set for June 21, 2021, and the government asks to move it seven days to June 28, 2021 because the parties have agreed to a resolution that still awaits final approval from the United States Attorney, after which an Information would be filed. It says the case stems from an investigation into a $35 million conspiracy with more than 30 participants, being investigated by the Southern District of Florida U.S. Attorney's Office and the Department of Justice in Washington, D.C. It cites a COVID-19 administrative order excluding time under the Speedy Trial Act, and notes the defense does not oppose and has filed a waiver of appearance and a not guilty plea (D.E. 17).

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 21-6149-MJ-HUNT 
UNITED STATES OF AMERICA, 
 
 
 
Plaintiff, 
v. 
CINDI ELLIS DENTON, 
 
 
Defendant. 
_________________________________/ 
 
SECOND UNOPPOSED MOTION FOR A ONE-WEEK EXTENSION OF 
ARRAIGNMENT 
 
The United States of America, through the undersigned Assistant United 
States Attorney, respectfully moves the Court for entry of an order briefly extending 
the date of arraignment by one week, seven (7) days and in further support states: 
 
1. 
The Defendant in this matter is charged in a complaint with wire fraud, 
bank fraud, and conspiracy to commit bank fraud and wire fraud (D.E. 1).   
 
2. 
The matter is set for an arraignment on June 21, 2021. (D.E. 15).  The 
Parties have agreed to a resolution of this case, but the undersigned Assistant United 
States Attorney is awaiting final approval on the resolution from the United States 
Attorney.  As such, the undersigned Assistant United States Attorney respectfully 
requests an extension of the arraignment date by seven (7) days, until June 28, 2021, 
to permit time to receive approval and file the Information.  
Case 0:21-cr-60171-RS   Document 18   Entered on FLSD Docket 06/18/2021   Page 1 of 3

2 
 
 
3. 
On April 6, 2021, Chief Judge K. Michael Moore issued an 
administrative order concerning the global COVID-19 pandemic.  (See 9th Order 
Concerning Jury Trials available at:  
https://web.flsd.uscourts.gov/uploads/adminOrders/2021/2021-33.pdf). 
This 
Administrative Order continued all jury trials in the Southern District of Florida to 
July 6, 2021, and continued all trial related deadlines.  (Id. at ¶¶ 6–7).   
 
4.  
The Administrative Order continued these deadlines in accordance with 
the Speedy Trial Act (18 U.S.C. § 3161(h)(7)(A)) and excluded all time from March 30, 
2020 until July 6, 2021, finding that the “ends of justice [are] served by taking that 
action outweigh the interests of the parties and the public in a speedy trial.” (Id. at 
¶ 10). 
 
5. 
The Parties have diligently worked to resolve this matter and expect 
approval within a few days.  This case stems from an investigation into a $35 million 
conspiracy involving more than 30 participants and is being investigated by both the 
United States Attorney’s Office for the Southern District of Florida and the 
Department of Justice in Washington, D.C.  Accordingly, a resolution has required 
input from multiple offices and attorneys, and a review of a significant amount of 
data and evidence. 
6. 
The United States has conferred with counsel for the Defense.  Counsel 
for the Defense does not oppose this request, and has filed a waiver of appearance 
and a plea of not guilty.  (D.E. 17).  
 
Case 0:21-cr-60171-RS   Document 18   Entered on FLSD Docket 06/18/2021   Page 2 of 3

3 
 
Dated: June 18, 2021 
 
 
Respectfully Submitted, 
JUAN ANTONIO GONZALEZ 
ACTING UNITED STATES ATTORNEY 
By:/s/ Lindsey Lazopoulos Friedman             
Lindsey Lazopoulos Friedman  
Florida Bar No. 091792 
Assistant United States Attorney 
99 Northeast 4th Street 
Miami, Florida 33132-2111 
Tel: (305) 961-9168 
Lindsey.Friedman@usdoj.gov 
 
CERTIFICATE OF SERVICE 
 
 
I HEREBY certify that on June 18, 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 in the manner specified, 
either via transmission of Notices of Electronic Filing generated by CM/ECF. 
 
By: s/Lindsey Lazopoulos Friedman 
Lindsey Lazopoulos Friedman 
Assistant United States Attorney 
     
 
Case 0:21-cr-60171-RS   Document 18   Entered on FLSD Docket 06/18/2021   Page 3 of 3

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