Defendant's Unopposed Motion to Continue Plea Hearing — United States v. Rivero (S.D. Fla., Document 15)

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Defendant's Unopposed Motion to Continue Plea Hearing, entered on the docket June 7, 2021 as Document 15 in United States of America v. Leonel Rivero, Case No. 21-20160-CR-KMW, U.S. District Court for the Southern District of Florida. The motion states that the plea hearing is scheduled for June 25, 2021, that counsel needs additional time to review voluminous discovery of over 48,500 items and 329 recordings, and that counsel will be unavailable because of a trial beginning June 21, 2021. It requests a sixty (60) day continuance and states that counsel for the government confirmed that they do not object. The signature block names Michael Mirer, Esq., with s/ Michael Mirer. A form of order on the motion for the Honorable Kathleen M. Williams follows.

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Case 1:21-cr-20160-KMW Document 15 Entered on FLSD Docket 06/07/2021 Page 1 of 3




                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA


                                     CASE NO. 21-20160- CR-KMW


  UNITED STATES OF AMERICA,
            Plaintiff,
  vs.

  LEONEL RIVERO,
              Defendant.
  _____________________________/


         DEFENDANT’S UNOPPOSED MOTION TO CONTINUE PLEA HEARING


                 The Defendant, LEONEL RIVERO, by and through the undersigned counsel,
  respectfully files this Unopposed Motion to Continue the Plea Hearing and in support thereof
  states as follows:

         1.      This matter is scheduled for plea hearing on June 25, 2021.

         2.      However, the undersigned needs additional time to review the discovery which is

  voluminous. In fact, there are over 48,500 items of discovery comprised of images, documents

  and/or text messages as well as 329 recordings.

         3.      The undersigned needs additional time to review these materials to properly

  counsel Mr. Rivero.

         4.      Furthermore, On June 21, 2021 the undersigned will be commencing trial in the

  middle district of Florida on United States v. Andrew Hammock, Case # 3:20-cr-00058-MMH-

  JRK and will be unavailable on the scheduled plea date of June 25, 2021.

         5.      Accordingly, undersigned counsel respectfully requests a sixty (60) day

  continuance of the plea hearing.
Case 1:21-cr-20160-KMW Document 15 Entered on FLSD Docket 06/07/2021 Page 2 of 3




         6.      Undersigned counsel contacted counsel for the government, Chris Browne and

  Della Sentilles who confirmed that they do not object to this motion.


         7.       This Motion is made in good faith and with no purpose of delay. The

  defendant understands that the time of the continuance will be excluded under the speedy trial

  act.



         WHEREFORE, the Defendant respectfully requests that this Court grant his Unopposed
  Motion to Continue the Plea Hearing and enter an Order in accordance herewith.



                                  CERTIFICATE OF SERVICE

         I HEREBY CERTIFY that a true and correct copy of the above and foregoing was

  furnished to: Chris Browne & Della Sentilles, Assistant United States Attorney’s

  on this 7th day of June 2021.



                                               Respectfully submitted,

                                               By: s/ Michael Mirer
                                                  MICHAEL MIRER, ESQ.
                                                  Florida Bar No. 0119490
                                                  Attorney for the Defendant
                                                  100 Biscayne Blvd, Suite 1300
                                                  Miami, Florida 33130
                                                  Tel.: 305-536-6177
                                                  Fax: 305-536-6179
Case 1:21-cr-20160-KMW Document 15 Entered on FLSD Docket 06/07/2021 Page 3 of 3




                                UNITED STATES DISTRICT COURT
                                SOUTHERN DISTRICT OF FLORIDA


                                  CASE NO. 21-20160-CR-KMW


  UNITED STATES OF AMERICA,
            Plaintiff,
  vs.

  LEONEL RIVERO,
              Defendant.
  _____________________________/

  ORDER ON DEFENDANT’S UNOPPOSED MOTION TO CONTINUE PLEA HEARING

          THIS CAUSE, having come on for consideration before the Court, upon the Defendant’s
  Unopposed Motion to Continue Plea Hearing said Motion and being otherwise fully advised on
  its premises, it is hereby:


          ORDERED AND ADJUDGED that the Defendant’s Unopposed Motion to Continue
  Plea Hearing is hereby___________________________________________________________.
          _______________________________________________________________________
          _______________________________________________________________________
          _______________________________________________________________________


          DONE AND ORDERED in Miami, FL this _________ day of ________________
  2021.

                                       ______________________________________________
                                       THE HONORABLE KATHLEEN M. WILLIAMS
                                       U.S. DISTRICT COURT JUDGE

  cc:     Michael Mirer, Esq.
          Chris Browne, AUSA
          Della Sentilles, AUSA


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