IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF FLORIDA

GAINESVILLE DIVISION

UNITED STATES OF AMERICA

CASE# 1:10CR00027-SPM

vs.

CARLINE CENEUS,

CABIOCH BONTEMPS, and

WILLY PAUL EDOUARD

_____________________________/

GOVERNMENT’S NOTICE OF INTENT TO PRESENT A SECOND SUPERSEDEING 

INDICTMENT AND REQUEST FOR THE COURT TO TEMPORARILY SUSPEND THE

TIMELINE TO FILE MOTIONS

COMES NOW the United States of America, by and through the undersigned Assistant 

United States Attorney and United States Department of Justice Trial Attorneys, and file this 

notice of intent to supersede the existing indictment and request that this Court temporarily 

suspend the timeline to file motions. The United States would rely on the following:

1. Defendants Carline Ceneus, Cabioch Bontemps, and Willy Paul Edward are charged 

together in a multi-count indictment filed June 22, 2010. (ECF No. 1). A superseding indictment 

was filed in this cause on October 19, 2010. (ECF No. 56).

2. On November 17, 2011, this Court set a trial date of February 13, 2012. (ECF No. 

68). On December 28, 2011, this Court directed all parties to file motions to dismiss by January 

6, 2012, and all defense pretrial motions by January 9, 2012, with the Government having an 

additional 6 days to respond. (ECF No. 177). 

3. The United States hereby gives notice of its intention to submit this case to a Grand 

Jury for the Northern District of Florida for a second superseding indictment by January 31, 

2012. It is anticipated that the second superseding indictment may resolve some pretrial legal 
issues and may affect the length of the trial. In the interest of judicial economy and in good 

faith, the United States files this notice of its intention to supersede the existing indictment. 

4. On January 5, 2012, AUSA Frank Williams informed defense counsels of the United 

States’ intention to supersede the current indictment and attempted to have counsels agree to a 

joint extension for time to file motions and a continuance of the trial date. Defense counsels 

were unable to agree on a unified position. 

5. On Friday, January 7, 2012, defendants Edouard and Bontemps hand-delivered 

and emailed, respectively, their Motions to Dismiss with Prejudice. As of this filing, neither 

defendant Edouard nor Bontemps has electronically filed their motion to dismiss, as required by 

Rule 5.1 of the Local Rules for the United States District Court, Northern District of Florida. 

N.D. Fla. Loc. R. 5.1. 

WHEREFORE, the government respectfully requests, in light of the United States’ 

intention to file a second superseding indictment by the end of January, 2012, this Court 

temporarily suspend the filing deadlines until after the United States has the opportunity to 

present a second superseding indictment to the grand jury at the end of January, 2012. 

Respectfully Submitted,

PAMELA C. MARSH THOMAS E. PEREZ

United States Attorney Assistant Attorney General

Civil Rights Division

/s/ F. T. Williams /s/ Adriana Vieco 

F. T. WILLIAMS ADRIANA VIECO

Assistant United States Attorney Trial Attorney, Civil Rights Division

Northern District of Florida Criminal Section

Florida Bar No. 936219 U.S. Department of Justice

300 E University Ave, Suite 310 New York Bar No. 2687036

Gainesville, FL 32601 601 D Street NW, Room 5542

(352) 378-0996 Washington, DC 20530

(202) 305-4116
 /s/ Roy Conn III 

 ROY CONN III

Trial Attorney, Civil Rights Division

 Criminal Section

U.S. Department of Justice

District of Columbia No. 388208

601 D Street NW, Room 5528

Washington, DC 20530

(202) 514-4164

CERTIFICATE OF SERVICE

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

electronic delivery this 9th day of January, 2012, to Lloyd L. Vipperman, Jr., Attorney for 

Defendant Carline Ceneus; Huntley Johnson, Attorney for Defendant Willy Paul Edouard; and 

Darren J. Johnson, Assistant Federal Public Defender, Attorney for Defendant Cabioch 

Bontemps.

 /s/ Adriana Vieco 

ADRIANA VIECO

Trial Attorney, Civil Rights Division