Unopposed MOTION to Travel by Alexandra Acosta — USA v. Alexandra Acosta (Dkt. 140)

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An Unopposed Motion for Permission to Travel entered on the docket 04/09/2025 as Document 140 in United States of America v. Alexandra Acosta, Case No. 23-CR-60170-RNS, in the U.S. District Court for the Southern District of Florida. The Defendant, by counsel, asks the court for an order allowing her to travel to Cullman, Alabama for several days in April 2025. The motion recites that she was charged with Conspiracy to Defraud the United States, Making a False Statement to the SBA and Wire Fraud, was found guilty after a jury trial, and was sentenced to four months on each Count concurrently followed by one year of supervised release. It states that the Probation Officer does not object. The signature line reads S/RICHARD L. ROSENBAUM, with a certificate of service dated April 9, 2025.

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Case 0:23-cr-60170-RNS Document 140 Entered on FLSD Docket 04/09/2025 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA

UNITED STATES OF AMERICA, CASE NO: 23-CR-60170-RNS
Plaintiff,
V.
ALEXANDRA ACOSTA,
Defendant.
/
UNOPPOSED

MOTION FOR PERMISSION TO TRAVEL

COMES NOW, the Defendant, Alexandra Acosta, by and through her undersigned counsel,

and respectfully requests this Honorable Court enter an Order allowing her to travel to Cullman,

Alabama from April 23, 22025 through and including April 27, 2025, and as grounds and in support

thereof states as follows:

i

The Defendant, Alexandra Acosta, was charged with Conspiracy to Defraud the United
States contrary to Title 18 USC Section 371 (Count I); Making a False Statement to the
SBA contrary to Title 15 USC Section 645(a) (Counts II and II); and Wire Fraud contrary to
Title 18 USC Section 1343 (Count IV).

After a trial by Jury, Alexandra Acosta was found guilty as charged.

Sentencing was conducted on August 28, 2024.

Judgment was entered on August 28, 2024. Pursuant to the Judgment, Alexandra Acosta
was sentenced to a term of four months as to each Count, to be served concurrently, in the
custody of the Bureau of Prisons, followed by one year supervised release with mandatory
and special conditions.

The Defendant desires to travel to with her son to Cullman, Alabama from April 23, 22025
Case 0:23-cr-60170-RNS Document 140 Entered on FLSD Docket 04/09/2025 Page 2 of 2

through and including April 27, 2025.

6. The Defendant shall be traveling to Alabama via automobile and will be staying at the
Palomino Resort, 1315 County Road 222, Cullman, AL 35057.

7. The Defendant shall continue to abide by all terms of her probation term.

1. The Defendant's Probation Officer, Mackenzie Hilaire, has advised that the Department of
Probation does not object to the relief sought herein.
WHEREFORE, based upon the foregoing grounds, the Defendant, Alexandra Acosta,

respectfully requests this Honorable Court enter an Order allowing her to travel to Cullman,

Alabama from April 23, 22025 through and including April 27, 2025.

| hereby certify that on April 9, 2025 | electronically filed the foregoing document with the
Clerk of the Court using CM/ECF. | also certify that the foregoing document is being served this
day on all counsel of record via transmission of Notices of Electronic Filing generated by CM/ECF.
Respectfully submitted,

LAW OFFICES OF RICHARD ROSENBAUM
Primary Email: Richard@RLRosenbaum.com
Secondary Email: Pleadings@RLRosenbaum.com

S/RICHARD L. ROSENBAUM
Richard L. Rosenbaum, Esq.
Fla. Bar No: 394688

315 SE 7" Street, Suite 300
Fort Lauderdale, FL 33301
Telephone (954) 522-7007
Facsimile (954) 522-7003

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