Case 3:20-cr-00258-FAB Document 11 Filed 08/25/20 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

UNITED STATES OF AMERICA,

Plaintiff, CRIMINAL CASE NO.: 20-258 (FAB)

v.

RAFAEL PINA-NIEVES,

Defendant.

CONSENT MOTION FOR EXTENSION OF TIME TO POST BOND

TO THE HONORABLE COURT:

COMES NOW Defendant Rafael Pina-Nieves, through the undersigned counsel, and

hereby requests an extension of time until September 4, 2020 to post the $1,000,000.00 bond

imposed by Magistrate Judge Camille Velez-Rive in the instant case. In support thereof, Mr. Pina-

Nieves respectfully states as follows:

1. On August 14, 2020, Mr. Pina-Nieves surrendered to the Government, was arraigned, and

was released subject to the posting of $1,000,000.00 bond within ten (10) days. (Docket

No. 9).

2. Mr. Pina-Nieves intends to post one of his wholly owned businesses, Rogelio’s Ice Plant,

as bond in this case, as the value of his business exceeds the amount of bond imposed.

3. Despite his best efforts to comply with the Court’s directives, Mr. Pina-Nieves is still

awaiting the official appraisal of his property, as well as several other documents required

by the Clerk of the Court prior to processing his bond.

4. Some of the documents, however, were seized by the Government from Rogelio’s Ice Plant

during the execution of a search warrant several months ago. Mr. Pina-Nieves’ counsel
 Case 3:20-cr-00258-FAB Document 11 Filed 08/25/20 Page 2 of 2

communicated with counsel for the Government to request copies of those documents and

counsel explained that investigators would need several days to locate and copy the

documents prior to producing them to Mr. Pina-Nieves.

5. Because these documents are essential to the process of posting bond, Mr. Pina-Nieves

respectfully requests an extension of time until Friday, September 4, 2020, to post his bond.

6. This request was discussed with counsel for the Government who graciously expressed no

objection to the relief sought herein.

WHEREFORE, the parties respectfully request that the Court GRANT this motion, with

any relief it deems necessary and just.

Respectfully submitted on this 25th day of August, 2020, in San Juan, Puerto Rico.

I HEREBY CERTIFY that on this date, I electronically filed the foregoing with the Clerk

of the Court, using the CM/ECF system, which will provide access to all parties of record.

By:

s/Maria A. Dominguez
Maria A. Dominguez
USDC-PR No. 210908
maria.dominguez@dmralaw.com

s/ Javier Micheo Marcial

Javier Micheo Marcial
USDC-PR No. 305310
javier.micheo@dmralaw.com

DMRA Law LLC

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