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Case 1:14-cr-20555-DPG Document 42 Entered on FLSD Docket 01/14/2015 Page 1 of 4

UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF FLORIDA
Case No. 14-20555-CR-GAYLES
UNITED STATES OF AMERICA
v.
ANTHONY P. BOSCH,
Defendant.
/

UNOPPOSED MOTION TO CONTINUE SENTENCING


The Defendant, ANTHONY BOSCH, through undersigned counsel, respectfully moves
for a 60-day continuance of his sentencing, stating as follows:
1.

On October 16, 2014, Mr. Bosch pled guilty to a single-count Information

charging him with conspiracy to distribute testosterone, in violation of Title 21, U.S.C. Section
841(a)(1). [D.E. 1].
2.

On October 16, 2014, after a hearing, this Court reinstated Mr. Boschs bond and

ordered him to be placed in an approved inpatient substance abuse treatment facility within the
Southern District of Florida. [D.E. 34]. He was placed in an approved facility that same day.
3.

After successfully completing this initial drug rehabilitation program, the

treatment facility recommended an extension of substance abuse treatment at another outpatient


facility within the Southern District of Florida. To facilitate his recovery process, Mr. Bosch
requested that his sentencing be continued. [D.E. 37].
4.

On November 12, 2014, this Court granted Mr. Boschs Unopposed Motion to

Continue Sentencing. [D.E. 39]. Mr. Bosch is presently scheduled to be sentenced on February
17, 2015. Id.

3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133

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Case No. 14-20555-CR-GAYLES
5.

With his team of professionals Mr. Bosch is working hard to earn and validate the

Courts trust in placing him in substance abuse treatment.

On November 18, 2014, after

successfully completing his first phase of treatment, Mr. Bosch voluntarily admitted himself
immediately into the recommended outpatient treatment facility.
6.

Similar with his time at the first treatment facility, Mr. Bosch is on virtual

lockdown. He has limited access to his family. He has limited access to his attorneys as well.
Private telephone calls with Mr. Bosch are limited. In-person access to Mr. Bosch is restricted
and limited. At his second treatment facility, Mr. Bosch is making progress, but consistent with
his counselors recommendations, he needs to continue his treatment to support the foundation of
his post-treatment recovery.
7.

For the final phase of his treatment plan, Mr. Boschs counselors are

recommending he commit to a transition living place or sober living house. Mr. Bosch has
located a facility within the Southern District of Florida that will allow him to attend
appointments with his current counselors. In turn, this will provide a seamless transition into this
phase of treatment.
8.

This phase will not only allow Mr. Bosch to fully complete his recommended

substance abuse treatment, but it will also allow Mr. Bosch and his counsel the access required to
prepare for his sentencing. Mr. Bosch will remain in full compliance with the conditions of his
bond.
9.

In addition, Mr. Bosch continues to comply with the terms of his plea agreement,

including his full and complete cooperation with the government.

Mr. Bosch is currently

scheduled to testify in United States v. Sucart, et al., Case No. 14- 20550-CR-ALTONAGA,
which is set for trial during the two-week period that begins on April 6, 2015.
2

3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133

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Case No. 14-20555-CR-GAYLES
10.

Defendant, therefore, respectfully requests that his sentencing be continued for 60

days from February 17, 2015, until April 20, 2015, to allow him additional time to complete his
treatment and to allow for additional opportunities to meet with counsel.
11.

This request is made in good faith and not for the purpose of delay.

12.

Undersigned counsel has conferred with counsel for the government and Mr.

Boschs U.S. Probation Officer to discuss the relief sought herein. Senior Litigation Counsel,
Michael Patrick Sullivan, indicated that the government does not oppose the relief sought in
this motion. U.S. Probation Officers, Thomas Felasco and David Sutherland, also indicated that
they not oppose the relief sought in this motion.
WHEREFORE, Defendant Anthony Bosch respectfully requests that this Court enter an
Order continuing sentencing for 60 days until April 20, 2015.

Respectfully submitted,
LEWIS TEIN, P.L.
Counsel for Anthony Bosch
3059 Grand Avenue, Suite 340
Coconut Grove, Florida 33133
Tel: (305) 442 1101
Fax: (305) 442 6744
By:

/s/ Guy A. Lewis


GUY A. LEWIS
Fla. Bar No. 623740
lewis@lewistein.com
MICHAEL R. TEIN
Florida Bar No. 993522
mtein@lewistein.com

3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133

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Case No. 14-20555-CR-GAYLES
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 14, 2015, I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document
is being served this day on all counsel of record identified on the following service list via
transmission of Notices of Electronic Filing generated by CM/ECF.
/s/ Guy A. Lewis
GUY A. LEWIS
SERVICE LIST
Michael P. Sullivan, Esq.
U.S. Attorneys Office
99 N.E. 4th Street
Miami, Florida 33132
Sharad Anand Motiani, Esq.
United States Attorneys Office
99 NE 4th Street
Miami, FL 33132

3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133