Unopposed MOTION to Travel by Amber Rewis Bruey. (Lappan, James) Motions referred to… — USA v. Bruey et al (Dkt. 53)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:21-cr-00074 · Doc. 53 · 2022-01-24 · Docket on CourtListener

Summary

An unopposed motion to permit the defendant to travel, filed January 24, 2022 as Document 53 in United States v. Amber Bruey, Case No. 2:21-CR-74-TPB-MRM (Middle District of Florida). It asks for an order allowing her to travel to Norfolk, Virginia for an appointment on January 31, 2022 and to return to the Eastern District of North Carolina before February 1, 2022. It recites that the Federal Defender was appointed September 17, 2021, that she pleaded not guilty, and that Condition 7(f) at Doc. 14-1 restricts her travel to the Eastern District of North Carolina. The destination is about 60 miles from her residence while alternatives within that district, in Raleigh and Greenville, are about 165 and 80 miles away. It states the government advised on January 21, 2022 that it does not object, and that her pre-trial officer advised that the court's permission is required.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

1 
UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
FORT MYERS DIVISION 
UNITED STATES OF AMERICA 
v.  
Case No. 2:21-CR-74-TPB-MRM 
AMBER BRUEY  
____________________________________/ 
UNOPPOSED MOTION TO PERMIT DEFENDANT TO TRAVEL 
COMES NOW, Amber Bruey, through counsel, and seeks an Order 
permitting her to travel to Norfolk, Virginia, to confer with a mental-health 
counselor on Monday, January 31, 2022.  In support of this motion, Ms. Bruey 
states as follows: 
1. On September 17, 2021, the Federal Defender was appointed to represent
Ms. Bruey.  (Docs. 23, 28).  She pleaded not guilty at that Court date
and the conditions of her release were adopted by this Court.  (Docs. 14-
1 and 23).
2. No condition of release requires Ms. Bruey to participate in mental-
health counseling if directed by her United States Pre-Trial Officer.
3. The conditions of release, however, do restrict Ms. Bruey’s travel to the
Eastern District of North Carolina.  (Condition 7(f) at Doc. 14-1).
4. Ms. Bruey has an appointment to confer with a mental-health counselor
in Norfolk, Virginia, beginning at 10 a.m. on Monday, January 31, 2022.
Case 2:21-cr-00074-TPB-K_D     Document 53     Filed 01/24/22     Page 1 of 4 PageID 122

2 
5. The mental-health counselor with whom Ms. Bruey is scheduled to 
confer is a licensed clinical psychologist in the Commonwealth of 
Virginia.   
6. Upon information and belief, the source being investigation conducted 
by the Office of the Federal Defender, while the distance from Ms. Bruey’s 
North Carolina residence to Norfolk, Virginia, is about 60 miles, the 
distance from Ms. Bruey’s residence to mental-health counselors situated 
in the Eastern District of North Carolina – Raleigh and Greenville, 
respectively --  is about 165 miles and 80 miles.  
7. On January 21, 2022, Assistant United States Attorney Trent Reichling 
advised undersigned counsel that the government did not object to an 
Order permitting Ms. Bruey to travel outside of the Eastern District of 
North Carolina and to Norfolk, Virginia, on January 31, 2022, to confer 
with a mental-health counselor. 
8. If permitted to travel to Norfolk, Virginia, on January 31, 2022, Mr. Bruey 
will return to the Eastern District of North Carolina before February 1, 
2022. 
9. Finally, on January 24, 2022, Ms. Bruey’s pre-trial officer advised 
undersigned counsel that Ms. Bruey would not be permitted to leave the 
Eastern District of North Carolina on January 31, 2022, to confer with a 
mental-health counselor in Norfolk, Virginia, absent permission to do so 
Case 2:21-cr-00074-TPB-K_D     Document 53     Filed 01/24/22     Page 2 of 4 PageID 123

3 
from this Court.   
10. In light of all of the above, Ms. Bruey now respectfully seeks an Order 
permitting her to travel outside of the Eastern District of North Carolina 
on January 31, 2022.  This Order would allow her to travel to Norfolk, 
Virginia and require her to return to the Eastern District of North 
Carolina before February 1, 2022. 
WHEREFORE, premises considered, Ms. Bruey respectfully moves for an 
Order allowing her to travel to Norfolk, Virginia, on January 31, 2022, to confer 
with a mental-health counselor located in Norfolk, Virginia. 
 
 
 
 
 
 
Respectfully Submitted, 
A. Fitzgerald Hall, Esq.   
Federal Defender 
Middle District of Florida 
 
By: /s/James Lappan         
James Lappan, Esq. 
Florida Bar No. 160792  
Assistant Federal Defender 
2075 West First St., Suite 300 
Ft. Myers, Florida 33901 
Telephone: 239-334-0397 
Fax: 239-334-4109 
E-Mail: jim_lappan@fd.org 
 
 
 
 
 
 
 
 
 
Case 2:21-cr-00074-TPB-K_D     Document 53     Filed 01/24/22     Page 3 of 4 PageID 124

4 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on the 24th day of January 2022, the foregoing 
was electronically filed with the Clerk of Court and a copy will be sent electronically 
to Trent Reichling, Assistant United States Attorney, 2110 First Street, Fort Myers, 
FL 33901. 
 
/s/ James Lappan           
James Lappan, Esq. 
Assistant Federal Defender 
Case 2:21-cr-00074-TPB-K_D     Document 53     Filed 01/24/22     Page 4 of 4 PageID 125

File and source

File

gov.uscourts.flmd.393556.53.0.pdf

Size

121,778 bytes

SHA-256

dc3c7ac200f80919ee0df09a8525909a471b508240fe9b6b4a782bb13bdece9c

Our copy

gov.uscourts.flmd.393556.53.0.pdf

Original

PACER (login required)