USA v. Quinonez-Soto et al

Middle District of Florida, flmd-8:2017-cr-00355-339530

WAIVER of speedy trial through June 30, 2018 by Brian Quinonez-Soto

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PageID 159 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION UNITED STATES OF AMERICA CASE NO: 8:17-Cr-355-T-35TGW BRIAN QUINONEZ-SOTO WAIVER OF SPEEDY TRIAL The Defendant, BRIAN QUINONEZ-SOTO, by and through the undersigned counsel, files this Waiver of Speedy Trial and alleges the following: 1. The Defendant is charged by way of Indictment in the Middle District of Florida; 2. After being fully advised of his speedy trial guarantees under the Sixth Amendment to the United States Constitution and under the Speedy Trial Act, 18 U.S.C. $ 3161 et seq., BRIAN QUINONEZ-SOTO, hereby waives those rights through June 30, 2018. RELIEF REQUESTED The undersigned and the Defendant seek a continuance of the underlying case and waives speedy trial through June 30, 2018. PageID 160 MEMORANDUM OF LAW Pursuant to 18 U.S.C. $ 3161(h)(8) and United States vs. McKay, 30 F.3d 1418 (11th Cir. 1994), an "ends-of-justice" excludable time period may be justified by need to complete the discovery process or for a continuance if the court expressly finds that the ends of justice is served because granting the continuance outweighs the best interest of the public in a speedy trial. United States vs. Davenport, 935 F.2d 1223 (11th Cir. 1991). Date: /-2978 BRIAREGUINONEZ-SOTO Defendant DAVID E. LITTLE, ESQUIRE Attorney for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that the original of the foregoing has been furnished by Electronic Filing to Elizabeth M. Warren, Clerk of the Court, U.S. District Court, Middle District of Florida, located at U.S. Courthouse, 801 N. Florida Ave., #223, Tampa, FL 33602-3800, and that e-mail notification of this filing will be sent to all interested persons on this 197 day of January, 2018 DAVID E. LITTLE, ESQUIRE Brown & Doherty, P.A. 450 Carillon Parkway, Suite 120 St. Petersburg, FL 33716 (727) 299-0099, Fax (727) 299-0044 FBN 0089124 david United States v. QUINONEZ-SOTO CASE NO: 8:17-Cr-355-T-35TGW Waiver of Speedy Trial Page 2 of 2