IN THE UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF FLORIDA

CASE NO: 20-MC-22829

IN THE MATTER OF THE EXTRADITION OF

CESAR HORACIO DUARTE JACQUEZ

 /

RESPONDENT’S UNOPPOSED MOTION FOR EXTENSION TO 

FILE HIS RESPONSE TO THE GOVERNMENT’S

MEMORANDUM IN SUPPORT OF EXTRADITION

Respondent, CESAR DUARTE, moves the Court for an extension until 

December 30, 2020 to file his Response to the Government’s Memorandum in Support 

of Extradition (“Memorandum”). The Government, as further detailed below, does not 

oppose the relief sought herein. In light the proposed new deadlines set forth herein, a 

status conference is also requested. In support thereof, Mr. Duarte states:

1. Mr. Duarte’s Response to the Government’s Memorandum is due 

December 15, 2020 per this Court’s November 25, 2020 Order [DE 55]. 

2. COVID-19 Outbreak in Mr. Duarte’s Unit. Mr. Duarte’s counsel has 

been unable to review with and discuss the draft response to the Government’s 

Memorandum with their client due to a recent COVID-19 outbreak in his FDC unit. 

Undersigned counsel, Mr. Bell, personally received a call from FDC cancelling a legal 

visit because of restrictions in Mr. Duarte’s unit and Mr. Duarte called the undersigned 

yesterday evening to inform him that those restrictions persist. 

Case 1:20-mc-22829-UNA Document 56 Entered on FLSD Docket 12/15/2020 Page 1 of 3
3. Pending Affidavits. Mr. Duarte and his counsel are also waiting on 

witness affidavits that they intend to include in his response to the Government’s 

Memorandum that have taken longer than expected. 

4. Pending Motion to Dismiss. Lastly,the parties await the Court’s ruling 

on Mr. Duarte’s Motion to Dismiss the Extradition Complaint [DE 29], which, 

depending on the Court’s ruling, could eliminate or impact the scope of any potential 

hearing on the Extradition Complaint. 

5. Good-Faith Conference Certification. The parties met and conferred 

consistent with the Court’s Local Rules and the Government does not oppose the 

extension sought herein. If the Court grants an extension until December 30, 2020 for 

Mr. Duarte to respond to the Government’s Memorandum, the Government informed 

the undersigned that it would request that their reply be due on or before January 14, 

2021. Mr. Duarte’s counsel does not oppose that reply deadline. 

6. Proposed Status Conference. In light of these proposed new deadlines

Mr. Duarte and the Government agree that a status conference prior to the holidays 

would be advisable assuming, of course, that the Court has time available. 

WHEREFORE, the Respondent, CESAR DUARTE, respectfully requests that 

the Court enter an order adopting the above-mentioned schedule and deadlines. A 

proposed order is attached. 

Case 1:20-mc-22829-UNA Document 56 Entered on FLSD Docket 12/15/2020 Page 2 of 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on December 15, 2020 a true and correct copy of the 

foregoing has been furnished electronically via CMCEF to all counsel of record.

Respectfully submitted, 

BELL ROSQUETE REYES ESTEBAN, PLLC.

999 Ponce De Leon Blvd.

Suite 1120 - Penthouse

Coral Gables, Florida 33134

Telephone: (305) 570-1610

Direct Line: (305) 570-1576

Cellular: (305) 781-8111

Facsimile: (305) 570-1599

Email: hbell@brresq.com

By: s/ Henry P. Bell

 HENRY P. BELL

 Fla. Bar No. 0090689

Case 1:20-mc-22829-UNA Document 56 Entered on FLSD Docket 12/15/2020 Page 3 of 3