Unopposed Motion to Continue — United States v. Edward Moise (Dkt. 16)

Summary

An Unopposed Motion to Continue entered on the docket January 31, 2022 as Document 16 in United States of America v. Edward Moise, Case No. 0:21-cr-60293-WPD, in the U.S. District Court for the Southern District of Florida. The Defendant states that sentencing is scheduled for February 11, 2022, at 1:30 p.m., and that the undersigned is unavailable because of a scheduled appearance in Tallahassee, Florida in the capacity of a State Representative. The motion requests that the matter be reset for March 14-17, 2022. It states that AUSA Stephanie Hauser has advised that she has no objection.

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Full text

Case 0:21-cr-60293-WPD Document 16 Entered on FLSD Docket 01/31/2022 Page 1 of 2



                                   UNITED STATES DISTRICT COURT
                                   SOUTHERN DISTRICT OF FLORIDA

                                        Case No. 21CR60293-WPD-1

  UNITED STATES OF AMERICA,

           Plaintiffs,
  vs.

  EDWARD MOISE,

        Defendant.
  ____________________________/

                                UNOPPOSED MOTION TO CONTINUE


           COMES NOW the Defendant, EDWARD MOISE, by and through undersigned counsel and

  files this Unopposed Motion to Continue.

           As grounds for this motion, the Defendant would show the following:

        1. The Defendant is scheduled for a Sentencing on February 11, 2022, at 1:30 p.m.

        2. The undersigned is currently unavailable for sentencing on that date, as he is scheduled to be

           in Tallahassee, Florida, in his capacity as a State Representative.

        3. The undersigned had anticipated a schedule change allowing for his return to the Southern

           District prior to February 11, 2022, however the current schedule has the undersigned

           returning the night of the 11th at 9 pm and leaving again, Sunday, February 13, 2022.

        4. Due to the unpredictability of the undersigned’s schedule, he is requesting this matter be reset

           for March 14-17, 2022.

        5. That undersigned counsel contacted AUSA Stephanie Hauser, who has advised that she has

           no objection to the sentencing being continued.
Case 0:21-cr-60293-WPD Document 16 Entered on FLSD Docket 01/31/2022 Page 2 of 2




         WHEREFORE, the Defendant respectfully requests this Honorable Court to grant this motion

  and enter an order continuing the Sentencing scheduled February 11, 2022.


                                                         /s/ Michael A. Gottlieb

                                                        Michael A. Gottlieb
                                                        Counsel for the Defendant
                                                        1311 SE 2nd Avenue
                                                        Ft. Lauderdale, Florida 33316
                                                        954.462.1005
                                                        mike@mgottlieblaw.com
                                                        Florida Bar No.: 981133




                                    CERTIFICATE OF SERVICE

         I hereby certify that on this 31st day of January, 2022, this pleading has been electronically

  filed with the Clerk of the Court and all parties of record via CMECF.



                                                        /s/Michael A. Gottlieb
                                                        Michael A. Gottlieb, Esquire


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