Unopposed MOTION to Travel by Amber Rewis Bruey. (Lappan, James) Motions referred to… — USA v. Bruey et al (Dkt. 83)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:21-cr-00074 · Doc. 83 · 2022-05-02 · Docket on CourtListener

Summary

An unopposed motion to permit the defendant to travel, filed May 2, 2022 as Doc. 83 in United States v. Amber Bruey, No. 2:21-cr-00074, in the U.S. District Court for the Middle District of Florida. The motion asks the court to allow the defendant to travel from North Carolina to Fort Myers, Florida, to attend her co-defendant's sentencing hearing set for May 20, 2022. It states that she would leave on May 17, 2022 and return on or before May 22, 2022, and that her own sentencing is set for June 24, 2022. The motion reports that her Pretrial Services Officer does not object if the court approves, and that Assistant United States Attorney Trent Reichling advised that the government did not object. It is filed by Assistant Federal Defender James Lappan and runs three pages with a certificate of service.

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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 from her North Carolina residence to Fort Myers, Florida, 
to attend the sentencing hearing for her co-defendant scheduled in this Division to 
take place on May 20, 2022.  (Doc. 60).  In further 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).  Ms. Bruey pleaded guilty to 
the indictment on March 16, 2022 (Doc. 69) and her sentencing is set 
for June 24, 2022.  (Doc. 73). 
2. 
Throughout this matter, Ms. Bruey was been released on conditions 
originally established in Eastern Division of North Carolina and 
subsequently adopted by this Court.  (Docs. 14-1 and 23). 
Case 2:21-cr-00074-TPB-K_D     Document 83     Filed 05/02/22     Page 1 of 3 PageID 248

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3. 
As the May 20 sentencing hearing in Fort Myers is not Ms. Bruey’s 
sentencing hearing, Ms. Bruey requires permission from this Court to 
travel.  See Condition 7(f) at Doc. 14-1. 
4. 
Ms. Bruey respectfully seeks permission to leave North Carolina by 
automobile with her co-defendant and their children on May 17, 2022.  
If this is granted, then she seeks permission to return to her North 
Carolina residence on or before Sunday, May 22, 2022. 
5. 
On May 2, 2022, undersigned counsel spoke telephonically with Ms. 
Bruey’s U.S. Pretrial Services Officer in North Carolina and was 
advised that that officer does not object to the travel outlined in this 
motion so long as the Court approves the travel. 
6. 
On May 2, 2022, Assistant United States Attorney Trent Reichling 
advised undersigned counsel that the government did not object to the 
relief sought herein. 
7. 
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 and to Fort Myers on May 17, 2022.  This Order would allow 
her to the Eastern District of North Carolina on or before May 22, 
2022. 
 
 
Case 2:21-cr-00074-TPB-K_D     Document 83     Filed 05/02/22     Page 2 of 3 PageID 249

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WHEREFORE, premises considered, Ms. Bruey respectfully moves for an 
Order permitting the relief sought herein. 
 
 
 
 
 
 
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 
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on the 2nd day of May 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 83     Filed 05/02/22     Page 3 of 3 PageID 250

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