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Motion for Continuance of Change of Plea Hearing — United States v. Ligia Maria Lemus de Pentzke

Summary

Motion for continuance of change of plea hearing filed in the District of Puerto Rico for defendant Ligia Maria Lemus de Pentzke. The motion states that the Change of Plea Hearing is scheduled for Friday, December 20, 2024, and that the government has requested a mitigation package that includes medical records of the defendant in order to assist in reaching a plea agreement. It states that the defendant needs additional time to obtain and review the medical documentation and asks the Court to continue the hearing by thirty (30) days. It also states that Assistant United States Attorney (AUSA) Daniel Olinghouse has expressed no objections. The motion is dated December 17, 2024 and bears the signature text of Luis Rafael Rivera.

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Cite this document

“Motion for Continuance of Change of Plea Hearing — United States v. Ligia Maria Lemus de Pentzke.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-3-23-cr-00130-dkt-304-d-p-r-9b8ed094fb/, SHA-256 c8f9fd989c55a5ff90af6d3a81a6ecd0269c8bb0fe303672fcc9486cb511189e.

Full text

   Case 3:23-cr-00130-ADC-MDM      Document 304    Filed 12/17/24   Page 1 of 2


                 IN THE UNITED STATES DISTRICT COURT
                   FOR THE DISTRICT OF PUERTO RICO

   UNITED STATES OF AMERICA               CRIMINAL NO.: 23-CR-130-5 (ADC)

                Plaintiff

                   v.

 LIGIA MARIA LEMUS DE PENTZKE,
  AKA “LIGIA LEMUS LANUZA” [5]

               Defendant


           DEFENDANT LIGIA MARIA LEMUS DE PENTZKE’S MOTION
             FOR CONTINUANCE OF CHANGE OF PLEA HEARING

TO THE HONORABLE COURT:

      COMES NOW, defendant LIGIA MARIA LEMUS DE PENTZKE (hereby

“Defendant Lemus de Pentzke”), by and through the undersigned attorney, and

very respectfully STATES, ALLEGES and PRAYS as follows:

      1.     This Honorable Court has scheduled the Change of Plea Hearing for

Friday, December 20, 2024, at 9:30 a.m.

      2.     The government has requested a mitigation package, which includes

medical records of the defendant, in order to assist in reaching a plea agreement.

      3.     In order to provide the government with the required medical

records, the defendant needs additional time to obtain and review the relevant

medical documentation.

      4.     The defendant’s medical records will support the conditions relevant

to the plea agreement.

      5.     To ensure that the defendant has adequate time to gather and

submit these records, she respectfully requests that the Court continue the
   Case 3:23-cr-00130-ADC-MDM       Document 304      Filed 12/17/24   Page 2 of 2


Change of Plea Hearing by thirty (30) days, extending the hearing date to January

30, 2024.

      6.     This request for continuance has been discussed with Assistant

United States Attorney (AUSA) Daniel Olinghouse, who has expressed no

objections to the proposed extension.

      WHEREFORE, it is respectfully requested to this Honorable Court that the

information provided herein BE NOTED and that it grants an additional thirty

(30) days to finalize plea negotiations, due on January 30, 2024.

      RESPECTFULLY SUBMITTED.

      In San Juan, Puerto Rico, this 17th day of December 2024.

      I HEREBY CERTIFY: That on this same date the foregoing motion has

been filed electronically with the Clerk of Court for the District of Puerto Rico,

through the CM/ECF Electronic Filing System, which will provide notification of

this filing to the United States Attorney’s Office for the District of Puerto Rico.

                                      s/Luis Rafael Rivera
                                      LUIS RAFAEL RIVERA
                                      USDC-PR 129411
                                      Luis Rafael Rivera Law Offices
                                      Capital Center Bldg. Suite 401
                                      239 Arterial Hostos Avenue
                                      Hato Rey, Puerto Rico 00918
                                      Telephone: (787) 763-1780
                                      Fax: (787) 763-2145
                                      E-Mail: luiswichyrivera@hotmail.com

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