Unopposed Motion to Continue Hearing Set for May 12, 2023 by Amber Rewis Bruey — USA v. Bruey et al. (Dkt. 150, M.D. Fla.)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:21-cr-00074 · Doc. 150 · 2023-04-20 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
FORT MYERS DIVISION 
 
 
UNITED STATES OF AMERICA 
v. 
Case No. 2:21-cr-74-JLB-MRM 
AMBER REWIS BRUEY 
____________________________________/ 
MOTION TO CONTINUE 
HEARING SET FOR MAY 12, 2023 
 
COMES NOW, the Defendant, Amber Rewis Bruey, by and through 
undersigned counsel and pursuant to Local Rule 3.08,1 hereby moves this 
Honorable Court to continue the hearing scheduled for May 12, 2023, at 
2:30 p.m. EST. In support of this motion, Ms. Bruey states: 
1. 
Ms. Bruey filed a motion to extend her report date by 90 days 
to allow her time to address her own health problems, as well as the new 
autism diagnosis for one of her children. See Doc. 143. A hearing on that 
motion is currently scheduled for May 12th, 2023, at 2:30 p.m. See Doc. 149. 
 
1  
Local Rule 3.08 provides that “[a] party must timely move for a 
continuance and explain in detail the reason a continuance is warranted 
and the effort to resolve any scheduling conflict.” It is respectfully submitted 
that the foregoing motion is made in good faith, and good cause has been 
shown for granting the requested continuance.  
 
Case 2:21-cr-00074-TPB-K_D     Document 150     Filed 04/20/23     Page 1 of 3 PageID 1090

2 
2. 
Counsel for Ms. Bruey has a personal out-of-state commitment 
that conflicts with the May 12th hearing date: counsel is scheduled to be 
out of the Fort Myers area between May 11th to May 14th, 2023. 
Accordingly, counsel respectfully requests this Court reschedule the 
hearing to allow her to fulfill her obligations with the prior commitment. 
3. 
Counsel is not seeking to substantially delay the hearing; 
counsel is available to attend a hearing prior to the current May 12th 
hearing date, as well as any date after May 14th. Counsel is also available 
to travel to Tampa as a more convenient forum for this Court. 
4. 
Counsel contacted Assistant United States Attorney Trent 
Reichling, who does not object to an earlier hearing date, either in Fort 
Myers or Tampa. Mr. Reichling does oppose moving the hearing to a later 
date. 
5. 
A continuance would not be an abuse of this Court’s discretion 
and would be in the interest of justice to allow counsel familiar with this 
motion to come before this Court. 
 
 
 
 
Case 2:21-cr-00074-TPB-K_D     Document 150     Filed 04/20/23     Page 2 of 3 PageID 1091

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WHEREFORE, the Defendant, Amber Rewis Bruey, respectfully 
requests this Honorable Court to reschedule the hearing. 
Dated: April 20, 2023 
 
Respectfully submitted, 
 
A. Fitzgerald Hall, Esq.  
Federal Defender 
Middle District of Florida 
 
/s/ Shehnoor Kaur Grewal 
Shehnoor Kaur Grewal, Esq. 
Appellate Attorney 
Utah Bar No. 14662 
2075 W. First Street, Suite 300 
Fort Myers, Florida 33901 
Telephone: (239) 334-0397 
E-Mail: shehnoor_grewal@fd.org 
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on the 20th day of April 2023, the foregoing 
was filed with the Clerk of Court and a copy will be sent electronically to 
Trent Reichling, Assistant United Stated Attorney. 
/s/ Shehnoor Kaur Grewal 
Shehnoor Kaur Grewal, Esq. 
Appellate Attorney 
Case 2:21-cr-00074-TPB-K_D     Document 150     Filed 04/20/23     Page 3 of 3 PageID 1092

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