Unopposed Motion to Continue Unopposed Motion to Reschedule Arraignment — USA v. Sheppard (Dkt. 10, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20290-BB · Doc. 10 · 2022-07-14 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FORIDA 
CASE No. 22-20290-CR-BLOOM/OTAZO-REYES 
 
UNITES STATES OF AMERICA 
v.  
ERIC DEAN SHEPPARD, 
 
Defendant. 
____________________________________/ 
UNOPPOSED MOTION TO 
RESCHEDULE ARRAIGNMENT AND REPORT RE: COUNSEL 
 
Defendant, Eric Dean Sheppard, respectfully submits this unopposed motion to reschedule 
the arraignment and report re: counsel, which is currently set for tomorrow, July 15, 2022, to next 
Friday, July 22, 2022. In the alternative, Defendant respectfully requests that the Court excuse 
Defendant from appearing tomorrow, July 15, 2022, given that counsel will be requesting a new 
date for the arraignment. In support of this Motion, Defendant states: 
1. 
The arraignment and report re: counsel is currently set for July 15, 2022. 
2. 
Defense counsel requires additional time to determine if it will be entering a 
permanent appearance.  
3. 
Therefore, Defendant respectfully requests that this Court reschedule the 
arraignment and report re: counsel to July 22, 2022. 
4. 
Defendant is currently released on bond. He knowingly and intelligently waives his 
speedy trial rights as necessary for purposes of this Unopposed Motion, and requests, in the 
interests of justice, that the Court exclude speedy trial time from July 15, 2022, through the new 
date set for the arraignment and report re: counsel. 
Case 1:22-cr-20290-BB   Document 10   Entered on FLSD Docket 07/14/2022   Page 1 of 3

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5. 
Undersigned counsel conferred with Assistant United States Attorney Marty 
Fulgueira Elfenbein regarding the relief sought in this Unopposed Motion. AUSA Elfenbein does 
not oppose the relief sought. 
6. 
In the alternative, Defendant respectfully requests that this Court excuse Defendant 
from appearing at the hearing currently set for tomorrow, July 15, 2022, given that counsel will be 
requesting a new date for the arraignment and report re: counsel. 
WHEREFORE, Defendant, Eric Dean Sheppard, respectfully requests that the 
arraignment and report re: counsel be rescheduled to July 22, 2022, for the reasons stated above. 
In the alternative, Defendant requests that he be excused from appearing at the hearing currently 
set for tomorrow, July 15, 2022, given that counsel will be requesting a new date for the 
arraignment and report re: counsel. 
Dated: July 14, 2022   
 
 
Respectfully submitted,  
NELSON MULLINS RILEY & SCARBOROUGH 
One Biscayne Tower, 21st Floor  
2 S. Biscayne Boulevard  
Miami, FL 33131  
Telephone: 305.373.9400  
Facsimile: 305.995.6449  
 
By: /s/ Christopher Cavallo 
Christopher Cavallo  
Florida Bar No. 0092305  
Jon A. Sale  
Florida Bar No. 246387  
Mark F. Raymond  
Florida Bar No. 373397  
Jonathan Etra  
Florida Bar No. 686905  
 
 
 
 
Case 1:22-cr-20290-BB   Document 10   Entered on FLSD Docket 07/14/2022   Page 2 of 3

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CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on July 14, 2022 the foregoing document was filed via the 
Court’s CM/ECF system.  
/s/ Christopher Cavallo  
Christopher Cavallo 
Case 1:22-cr-20290-BB   Document 10   Entered on FLSD Docket 07/14/2022   Page 3 of 3

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