Expedited Unopposed Motion to Continue Drew Lieberman’s Change of Plea Hearing — United States v. Lieberman (Dkt. 486, S.D. Fla.)

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An expedited unopposed motion by Dr. Drew Lieberman to continue his change of plea hearing in United States v. Drew Lieberman, Case No. 21-CR-60020, in the U.S. District Court for the Southern District of Florida, entered February 9, 2022 as Document 486. Through counsel, Lieberman asks the court to continue the change of plea hearing set for the next day, February 10, 2022, and reschedule it for a later date. The motion is filed by his counsel, Jacqueline Z. DerOvanesian.

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Case 0:21-cr-60020-WPD Document 486 Entered on FLSD Docket 02/09/2022 Page 1 of 2




                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA
                         CASE NO. 21-CR-60020-DIMITROULEAS

   UNITED STATES OF AMERICA

   vs.

   DREW LIEBERMAN
                                               /

                      EXPEDITED UNOPPOSED MOTION TO CONTINUE
                      DREW LIEBERMAN’S CHANGE OF PLEA HEARING

         Defendant Dr. Drew Lieberman, through undersigned counsel, respectfully moves this

  Court to continue his change of plea hearing currently scheduled for tomorrow, February 10, 2022.

  In support of the motion, Dr. Lieberman states as follows:

     1. Dr. Lieberman’s change of plea hearing is currently scheduled for February 10, 2022 at

  1:30 p.m. ECF No. 474.

     2. Today, on February 9, 2022, Dr. Lieberman experienced a medical event that required him

  to seek medical attention this afternoon. Given the uncertainty created by this medical issue, we

  are requesting a very brief continuance of Dr. Lieberman’s change of plea hearing. If it would

  assist the Court’s consideration of this motion, undersigned counsel is prepared to file

  medical documentation under seal.

     3. This motion is not being filed to create an unwarranted delay, and the relief requested will

  not prejudice the government.

     4. Prior to filing this Motion, pursuant to Local Rule 7.1(a)(3), undersigned counsel for Dr.

  Lieberman conferred with counsel for the United States, who stated she does not oppose the relief

  requested herein.

Case 0:21-cr-60020-WPD Document 486 Entered on FLSD Docket 02/09/2022 Page 2 of 2




         WHEREFORE, Dr. Lieberman respectfully moves this Court for an order continuing his

  change of plea hearing, to be rescheduled at a later date.

  Date: February 9, 2022                        Respectfully Submitted,

                                                STUMPHAUZER FOSLID SLOMAN
                                                ROSS & KOLAYA, PLLC
                                                Two South Biscayne Boulevard, Suite 1600
                                                One Biscayne Tower
                                                Miami, FL 33131
                                                Telephone: (305) 614-1400
                                                Facsimile: (305) 614-1425

                                        By:      /s/ Jacqueline Z. DerOvanesian
                                                Ryan K. Stumphauzer, Esq.
                                                Fla. Bar No. 0012176
                                                rstumphauzer@sfslaw.com
                                                Jacqueline Z. DerOvanesian, Esq.
                                                Fla. Bar No. 125662
                                                jderovanesian@sfslaw.com

                                                Attorneys for Drew Lieberman

                                   CERTIFICATE OF SERVICE

         I certify that on this 9th day of February, 2022, I electronically filed this document with the

  Clerk of the Court using CM/ECF, causing a copy to be served on counsel of record.

                                                /s/ Jacqueline Z. DerOvanesian
                                                Jacqueline Z. DerOvanesian




                                                   2

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