Response 34 Motion to Travel by USA as to Bridgitte Keim — USA v. Keim (Dkt. 36, M.D. Fla.)

Record facts

U.S. District Court for the Middle District of Florida · No. 8:21-cr-00370 · Doc. 36 · 2024-02-02 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
TAMPA DIVISION 
UNITED STATES OF AMERICA 
v. 
BRIDGITTE KEIM 
CASE NO. 8:21-cr-370-CEH-JSS 
UNITED STATES’ RESPONE TO DEFENDANT’S 
PRO SE MOTION TO TRAVEL 
The United States of America, by Roger B. Handberg, United States Attorney 
for the Middle District of Florida, respectfully files this response to defendant Keim’s 
pro se Motion to Travel (hereinafter “Motion”). (Doc. 34).  
On January 16, 2024, the defendant filed her Motion seeking approval for the 
following overseas trips: 
1. Travel to the Dominican Republic from February 12, 2024, through
February 16, 2024; and
2. Travel to Nova Scotia, Canada July 17, 2024, through August 17, 2024.
Undersigned counsel contacted United States Probation Officer Amanda 
Goble to ascertain her position for both travel requests. On February 2, 2024, 
undersigned counsel received a written response from USPO Goble. Ms. Goble 
advised that she had spoken with Ms. Keim about the proposed overseas travel. 
Regarding the proposed trip to the Dominican Republic, Ms. Goble advised that Ms. 
Keim’s travel plans to the Dominican Republic are no longer valid as Ms. Keim has 
Case 8:21-cr-00370-CEH-T_W     Document 36     Filed 02/02/24     Page 1 of 3 PageID 163

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already canceled her trip. Regarding the trip to Nova Scotia, Canada, Ms. Gorman 
verified Ms. Keim’s travel arrangements and has no objection to the proposed travel. 
Based on conversations with Ms. Gorman the United States respectfully 
requests that the Court deny the defendant’s Motion in part regarding travel to the 
Dominican Republic as Keim has canceled her travel and grant the defendant’s 
Motion in part to travel to Nova Scotia, Canada.  
 
 
 
 
 
Respectively submitted, 
 
 
 
 
 
 
ROGER B. HANDBERG 
 
 
 
 
 
 
United States Attorney 
 
 
 
By: 
/s/ Christopher Poor  
 
Christopher Poor 
Special Assistant United States Attorney 
United States Attorney No.: 152 
400 N. Tampa Street, Suite 3200 
Tampa, Florida 33602-4798 
Telephone: (813) 274-6000 
Facsimile: 
(813) 274-6125 
E-mail: Christopher.Poor@usdoj.gov 
Case 8:21-cr-00370-CEH-T_W     Document 36     Filed 02/02/24     Page 2 of 3 PageID 164

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U.S. v. Keim 
 
 
 
 
 
Case No. 8:21-cr-370-CEH-JSS 
CERTIFICATE OF SERVICE 
 
I hereby certify that on February 2, 2024, the foregoing document was 
filed under seal with the Clerk of the Court, and a true copy was furnished by United 
States Mail to the following: 
 
Bridgitte Keim 
 
105 Glen Ridge Avenue 
 
Temple Terrace, FL 33617 
 
 
 
 /s/ Christopher Poor 
 
 
Christopher Poor 
Special Assistant United States Attorney 
United States Attorney No.: 152 
400 N. Tampa Street, Suite 3200 
Tampa, Florida 33602-4798 
Telephone: (813) 274-6000 
Facsimile: 
(813) 274-6125 
E-mail: Christopher.Poor@usdoj.gov 
 
Case 8:21-cr-00370-CEH-T_W     Document 36     Filed 02/02/24     Page 3 of 3 PageID 165

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