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Joint Motion to Continue Sentencing and Forfeiture Hearings — United States v. Heidi Cid (Document 112)

Summary

Joint Motion to Continue Sentencing and Forfeiture Hearings, entered on the docket November 15, 2024, in United States of America v. Heidi Cid, Case Nos. 23-20421-CR-SCOLA and 23-20422-CR-SCOLA. The hearings are currently scheduled for December 5, 2024. The motion states that Ms. Cid pleaded guilty on April 22, 2024, cooperated with the government, and testified this month against Lazaro Verdecia Hernandez and Yadier Rodriguez Arteaga, who were convicted at trial. The parties seek a continuance until the week of February 10, 2025, and the motion is signed /s/ by Thomas Haggerty, A. Margot Moss, and David Oscar Markus.

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“Joint Motion to Continue Sentencing and Forfeiture Hearings — United States v. Heidi Cid (Document 112).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-fla-no-1-23-cr-20421-dkt-112-s-d-fla-91343f7210/, SHA-256 45ca493fd5ae4f63345381dbb0fb446642b9352554900c66075861363aa88282.

Full text

Case 1:23-cr-20421-RNS Document 112 Entered on FLSD Docket 11/15/2024 Page 1 of 2




                         UNITED STATES DISTRICT COURT
                         SOUTHERN DISTRICT OF FLORIDA
                                MIAMI DIVISION

                               CASE NO. 23-20421-CR-SCOLA
                               CASE NO. 23-20422-CR-SCOLA


  UNITED STATES OF AMERICA

  vs.

  HEIDI CID
  _________________________________________/


                  JOINT MOTION TO CONTINUE SENTENCING
                        AND FORFEITURE HEARINGS

        The United States and Heidi Cid respectfully file this Joint Motion to Continue

  Ms. Cid’s Sentencing and Forfeiture hearings which are currently scheduled for

  December 5, 2024 (Docs. 34, 106, and 109).

        1.     On October 25, 2023, Heidi Cid was charged in two separate cases, one

  case charging offenses related to PPP fraud and one for access device fraud and

  aggravated identity theft.

        2.     On April 22, 2024, Ms. Cid pleaded guilty to charges in both cases. Her

  sentencing and forfeiture hearing are currently scheduled for December 5, 2024.

        3.     Ms. Cid has cooperated with the government and testified this month in

  case number 23-cr-20421 against Lazaro Verdecia Hernandez and Yadier Rodriguez

  Arteaga. Both defendants were convicted at trial.

        4.     Ms. Cid’s cooperation will continue through and until the sentencing of

  Verdecia Hernandez and Rodriguez Arteaga.


                                     MARKUS/MOSS PLLC
                                           −1−
Case 1:23-cr-20421-RNS Document 112 Entered on FLSD Docket 11/15/2024 Page 2 of 2




        5.    To complete her cooperation and allow the Government and Court an

  opportunity to make a full assessment of Ms. Cid’s contributions, both parties

  respectfully seek a continuance of her sentencing and forfeiture hearing until the

  week of February 10, 2025 (one week after the sentencing of Verdecia Hernandez and

  Rodriguez Arteaga.

        6.    Ms. Cid is currently out on bond and fully compliant with all conditions

  that have been set by the Court.

        We respectfully request that the Court continue Ms. Cid’s Sentencing and

  Forfeiture hearings until the week of February 10, 2025.



                           Respectfully submitted,

  MARKENZY LAPOINTE                             MARKUS/MOSS PLLC
  UNITED STATES ATTORNEY                        40 N.W. Third Street, PH1
                                                Miami, Florida 33128
  /s/ Thomas Haggerty                           Tel: (305) 379-6667
  THOMAS HAGGERTY                               markuslaw.com
  Assistant United States Attorney
  Florida Bar No. 46136                         By:     /s/ A. Margot Moss
  U.S. Attorney’s Office – SDFL                         A. Margot Moss
  99 N.E. 4th Street                                    Florida Bar No. 091780Miami,
  FL 33132                                              mmoss@markuslaw.com
  Telephone: (305) 961-9002
  Email: Thomas.Haggerty@usdoj.gov              By:     /s/ David Oscar Markus
                                                        David Oscar Markus
                                                        dmarkus@markuslaw.com
                                                        Florida Bar No. 119318




                                     MARKUS/MOSS PLLC
                                           −2−

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