Frances Acevedo Pide Cambio Fecha Sentencia

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Case 3:20-cr-00248-SCC Document 587 Filed 01/15/24 Page 1 of 3

12236
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO

|
UNITED STATES OF AMERICA |
|
Plaintiff(s) | CRIMINAL NO. 20-248-02 (SCC)
|
vs. |
|
FRANCES ACEVEDO-CEBALLOS [2] |
|
Defendant(s) |
________________________|

MOTION REQUESTING CONTINUANCE


OF SENTENCE HEARING

TO THE HONORABLE COURT:

COMES NOW, co-defendant Frances Acevedo-Ceballos, through her undersigned counsel

who very respectfully States and Prays:

1. The sentence hearing in the instant case is set to be held on Monday,February 5, 2024

AT 9:00 A.M.;

2. Undersigned counsel has been involved on a trial that has prevented the required

meeting between attorney and client to adequately discuss the Pre Sentence Report

submitted in the case in order to evaluate the same, present their objections,

corrections and/or modifications to the same and also submit its Sentencing

Memorandum;

3. The referred trial is still ongoing and a continuance of the sentence hearing in the

instant case is hereby requested;

4. In order to fully comply with his obligations towards client and the court a thirty (30)

day continuance is hereby requested;


Case 3:20-cr-00248-SCC Document 587 Filed 01/15/24 Page 2 of 3

5. To prevent any calendar conflict the following dates/hours are suggested to the court

and are available in undersigned counsel’s working calendar:

a. March 25, 26 and 27 at any time available to the court;

b. April 1, 2 4 and 5 at any time available to the court.

6. The herein requested continuance will cause no hardship to any of the involved

parties and its granting will allow the appearing to adequately prepare for the referred

hearing.

WHEREFORE it is respectfully prayed from the court that this Motion be GRANTED in

its entirety.

RESPECTFULLY SUBMITTED

In San Juan, Puerto Rico on this the 15th day of January, 2024.

s/ Benito I. Rodríguez-Massó
BENITO I. RODRÍGUEZ MASSÓ
USDC/PR 124801
Urbanización El Vedado
407 Calle Bonafoux
San Juan, Puerto Rico 00918-3023
Tel.: 787-763-8999/8555
Fax.: 787-763-8917
CM/ECF: birmlaw@gmail.com
E-Mail: birmlaw2@gmail.com

CERTIFICATE OF SERVICE: I hereby certify that on this same date I electronically filed

the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of

said filing to all attorneys of record.


Case 3:20-cr-00248-SCC Document 587 Filed 01/15/24 Page 3 of 3

S/ Benito I. Rodríguez-Massó

BENITO I. RODRÍGUEZ MASSÓ


USDC/PR 124801

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