Unopposed Motion for Return of Property/PreTrial — USA v. Sheppard (Dkt. 44, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20290-BB · Doc. 44 · 2023-02-17 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FORIDA 
CASE No. 22-20290-CR-BLOOM/OTAZO-REYES 
 
UNITES STATES OF AMERICA 
 
 
Plaintiff,  
v.  
 
ERIC DEAN SHEPPARD, 
 
 
Defendant. 
____________________________________/ 
 
UNOPPOSED MOTION FOR RETURN OF SPOUSE’S PASSPORT 
 
Defendant, Eric Sheppard, by and through his undersigned counsel, hereby files this 
Unopposed Motion for Return of Spouse’s Passport, and as grounds therefore states: 
1. 
Bond in this case was agreed to on July 12 and entered on July 15, 2022. [D.E. 14; 
D.E. 15]. 
2. 
During initial bond discussions, the defense agreed to turn over the passport of 
Defendant’s wife, Jennifer Sheppard, as a condition of the bond. [D.E. 14 at 2; D.E. 15 at 2]. 
3. 
Ms. Sheppard is not a defendant in this case. She was born and raised in Miami. 
4. 
Presently, Ms. Sheppard’s passport is with pre-trial services, as dictated by the 
conditions of the bond.  
5. 
Defendant’s daughter, a sophomore in college, is traveling to Puerto Vallarta, 
Mexico on spring break, February 26 through March 3, 2023.  Additionally, she is scheduled to 
travel to Israel on the Birthright program in May 2023.  
6. 
If for some reason Defendant’s daughter needs a parent, or circumstances warrant 
a parent’s presence in Mexico, neither parent will be permitted to travel outside the country given 
the turnover of their passports. 
Case 1:22-cr-20290-BB   Document 44   Entered on FLSD Docket 02/17/2023   Page 1 of 2

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7. 
In addition to general parental concerns about Defendant’s daughter traveling to 
Mexico, the daughter also has special medical issues that could require immediate attention and 
parental involvement. 
8. 
The government has no objection to the Court eliminating the condition of 
Defendant’s bond that Ms. Sheppard surrender her passport, and that Ms. Sheppard’s passport be 
returned to her. 
9. 
Defendant has been fully compliant with pre-trial services and all requirements of 
his bond. 
WHEREFORE, for the foregoing reasons, undersigned counsel respectfully requests that 
the passport of Defendant’s wife, Jennifer Sheppard, presently held by pre-trial services, be 
returned to her forthwith. 
Dated: February 17, 2023. 
 
 
 
Respectfully submitted,  
NELSON MULLINS  
One Biscayne Tower, 21st Floor  
2 S. Biscayne Boulevard  
Miami, FL 33131  
Telephone: 305.373.9400  
Facsimile: 305.995.6449  
 
By: /s/ Jayne C. Weintraub 
Jayne C. Weintraub 
Florida Bar No. 320382 
Jonathan Etra  
Florida Bar No. 686905 
 
 
CERTIFICATE OF SERVICE 
 
 
I HEREBY CERTIFY that on February 17, 2023, the foregoing document was filed via 
the Court’s CM/ECF system to all counsel of record.  
/s/ Jayne C. Weintraub  
Jayne C. Weintraub 
Case 1:22-cr-20290-BB   Document 44   Entered on FLSD Docket 02/17/2023   Page 2 of 2

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