Unopposed Motion for Leave to File Document /Reply by USA — USA v. Crowther (Dkt. 150, M.D. Fla. No. 2:20-mj-01094, docketed in No. 2:20-cr-00114)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:20-cr-00114 · Doc. 150 · 2021-06-14 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
FORT MYERS DIVISION 
 
UNITED STATES OF AMERICA 
 
v. 
 
 
Case No. 2:20-cr-114-JES-MRM 
 
 
CASEY DAVID CROWTHER 
 
UNITED STATES’ UNOPPOSED MOTION FOR LEAVE TO REPLY 
 
The United States of America respectfully moves, pursuant to Middle District 
of Florida Local Rule 3.01(d), for leave to file, no later than seven days after the 
granting of this Motion, a reply of no more than 12 pages to the defendant’s 
Response to the United States’ Motion for Order of Forfeiture and Preliminary Order 
of Forfeiture for Direct Assets (Doc. 149). The United States’ reply will address the 
defendant’s contentions that the requested forfeiture orders violate the Excessive 
Fines Clause of the Eighth Amendment, that the requested forfeiture amount is 
incorrect because portions of the fraudulently obtained loans have or will be repaid, 
and that the Court lacks authority to enter forfeiture money judgments. 
In support of this motion, the United States submits that a brief response is 
necessary to address these arguments which are legally unsupportable.  The United 
States believes that the legal authority it will provide in its reply will assist the Court 
in assessing the merits of the pending motion and the defendant’s objection. 
The United States has conferred with Nicole Waid, counsel for the defendant, 
who has advised that she has no opposition to this motion. 
 
Case 2:20-cr-00114-JES-M_M     Document 150     Filed 06/14/21     Page 1 of 2 PageID 3503

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WHEREFORE, the United States hereby requests that the Court grant it leave 
to file a reply of no more than 12 pages to the defendant’s Response. 
Respectfully submitted, 
KARIN HOPPMANN 
Acting United States Attorney 
 
 
By: 
s/Suzanne C. Nebesky____________                                
 
 
 
 
 
 
SUZANNE C. NEBESKY 
Assistant United States Attorney 
Fla. Bar No. 59377 
400 N. Tampa Street, Suite 3200 
Tampa, Florida 33602 
Tel:   (813) 274 6000 
 
E-mail: suzanne.nebesky@usdoj.gov 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that on June 14, 2021, 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 counsel of record. 
 
s/Suzanne C. Nebesky___________                       
SUZANNE C. NEBESKY 
Assistant United States Attorney 
 
Case 2:20-cr-00114-JES-M_M     Document 150     Filed 06/14/21     Page 2 of 2 PageID 3504

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