Response in Opposition by USA as to Amber Rewis Bruey — USA v. Bruey et al. (Dkt. 147, M.D. Fla.)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:21-cr-00074 · Doc. 147 · 2023-03-28 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
FORT MYERS DIVISION 
 
UNITED STATES OF AMERICA 
 
v. 
CASE NO. 2:21-cr-74-TPB-NPM 
 
AMBER REWIS BRUEY 
 
UNITED STATES’ RESPONSE IN OPPOSITION TO  
DEFENDANT’S AMENDED MOTION FOR A 90-DAY  
EXTENSION OF HER PRISON REPORT DATE 
 
 
The United States responds in opposition to defendant Amber Bruey’s 
(Bruey) amended motion for a 90-day extension of her prison report date. 
Doc. 144. Bruey’s request for an additional 90-day delay of her surrender to 
the Bureau of Prisons (BOP) is unreasonable in light of the fact that Bruey has 
had since July 13, 2022, to prepare for her surrender. Additionally, Bruey has 
not submitted medical records to the Court that corroborate the health issues 
outlined in her motion. Bruey’s amended motion should respectfully be 
denied.  
BACKGROUND 
 
On March 16, 2022, Bruey pleaded guilty to an Indictment that charged 
her with Conspiracy to Commit Wire Fraud (18 U.S.C. § 1349), ten counts of 
Wire Fraud (18 U.S.C. § 1343), Conspiracy to Commit Money Laundering 
(18 U.S.C § 1956(h), and four counts of Illegal Monetary Transactions (18 
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U.S.C. § 1957). Doc. 69. The crimes, related to Paycheck Protection Program 
(PPP) and Economic Injury Disaster Loan (EIDL) fraud committed by Bruey 
and her husband and co-defendant, Anthony Bruey, in 2020. Doc. 3. On May 
18, 2022, the United States Probation Office (USPO) filed Bruey’s initial 
Presentence Investigation Report (PSR), which calculated her sentencing 
guidelines range as 63 to 78 months of imprisonment. Initial PSR ¶ 109. The 
same guidelines calculation was also contained in the final PSR, filed June 16, 
2022. Final PSR ¶ 111.  
At Bruey’s initial sentencing hearing, on June 24, 2022, Bruey informed 
the Court that she was pregnant. Doc. 133 at 58-59. Bruey was thereafter 
sentenced to 48 months of imprisonment on July 13, 2022, at her continued 
sentencing hearing. Docs. 108, 109. The Court, in considering Bruey’s 
pregnancy and due date in February 2023, gave her a surrender date of April 
3, 2023. Doc. 133 at 18-19. Bruey was designated to FPC Alderson by BOP on 
March 7, 2023.  
ARGUMENT 
 
Bruey now seeks a 90-day extension of her prison report date because of 
health problems related to her premature pregnancy and her children’s health 
issues. See Doc 144. Before filing her motion, Bruey’s counsel reached out to 
the government to get its position on a 90-day extension. The government 
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asked Bruey’s counsel for medical records, so that it could determine the 
legitimacy of the request. Bruey’s counsel provided medical records only 
related to Bruey’s medical treatment before and after her pregnancy. Records 
related to Bruey’s most recent medical visit, dated March 3, 2023, do not 
appear to present medical issues that would prevent her from surrendering to 
BOP. Specifically, the medical records noted she had good respiration efforts 
that were not labored, and that she was a well-appearing female in no acute 
distress. The government did not see a record of heart or asthma issues in 
Bruey’s March 3rd medical visit, which Bruey claims as a basis for a further 
delayed surrender. Doc.  144 at 3.  Bruey also requests a 90-day delay so that 
she can continue her medical treatments. Id. at 5. There is no reason to believe 
that Bruey cannot continue to seek medical treatment in BOP custody. Bruey 
can submit her medical records to BOP and make requests for medical 
treatment.  
 
In addition to Bruey’s own medical issues, she requests a 90-day delay of 
her surrender because of the health of her children. Neither the government, 
nor the Court, have been provided with medical records for Bruey’s children. 
Without these records, the government can only rely on Bruey’s 
representations of her children’s health. Given Bruey’s history of fraud, the 
government would need to see her children’s medical records before 
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considering Bruey’s request. Moreover, as contained in Bruey’s Final PSR, she 
has been aware of one of her child’s separation anxiety issues, as well as other 
physical health issues suffered by her children, well before being sentenced to 
prison in this case. Doc. 97 at ¶ 82.  
Bruey became pregnant after pleading guilty to serious federal felony 
offense on March 16, 2022. She has also been on notice of an impending prison 
sentence since at least May 18, 2022, the date of her initial PSR. Further, on 
July 13, 2022, the Court gave Bruey a considerable amount of time, until April 
3, 2023, to make arrangements for the care of her children. The government 
fears that Bruey will find further reason to delay surrender if the Court were to 
grant her request, which is why it opposes Bruey’s requested delay.  
 
 
 
 
 
 
 
 
 
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CONCLUSION 
The United States respectfully requests that the Court deny Bruey’s 
amended motion for a 90-day extension of her prison report date.  
Respectfully submitted, 
 
ROGER B. HANDBERG 
United States Attorney  
 
By: 
 /s/Trent Reichling              
Trenton J. Reichling  
Assistant United States Attorney 
Florida Bar No. 0084601 
2110 First Street, Suite 3-137 
Ft. Myers, Florida 33901 
Telephone:  (239) 461-2200 
Facsimile: 
 (239) 461-2219 
E-mail: Trenton.Reichling@usdoj.gov  
 
 
 
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U.S. v. Amber Rewis Bruey                            Case No. 2:21-cr-74-TPB-KCD 
CERTIFICATE OF SERVICE 
 
I hereby certify that on March 28, 2023, I electronically filed the 
foregoing with the Clerk of the Court by using the CM/ECF system which 
will send a notice of electronic filing to the following: 
 
 
Shehnoor Kaur Grewal 
 
 
Shehnoor_Grewal@fd.org  
  
 
 
 
 
 
 
 
 
/s/ Trent Reichling         
 
 
 
 
 
 
 
Trenton J. Reichling  
 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
 
 
 
 
 
 
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