Unopposed Motion to Travel by Eric Dean Sheppard — USA v. Sheppard (Dkt. 51, S.D. Fla.)

Summary

Unopposed Motion to Travel, Document 51, filed 07/26/23 in United States v. Eric Dean Sheppard, No. 22-20290-CR (S.D. Fla.). Sheppard, released on a personal surety bond limited to four federal districts, asks to travel from July 31 to August 4, 2023 between Philadelphia and New York. The stated purposes are his daughter's medical procedure at Children's Hospital of Philadelphia, a meeting with counsel in New York, and picking up and dropping off his son around medical appointments. He plans to fly home from Newark to Miami on August 4. The motion says Assistant U.S. Attorney Aimee Jimenez does not oppose it; it is signed by Jayne C. Weintraub of Nelson Mullins, with Jon A. Sale, Jonathan Etra and Christopher Cavallo also listed.

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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 TO TRAVEL 
 
 
Defendant, Eric Dean Sheppard, respectfully submits this unopposed motion (“Motion”) 
permitting 
him 
to 
travel 
to 
the 
Southern 
District 
of 
New 
York 
and 
the  
Middle District of Pennsylvania to attend his daughter’s medical procedure.  In support of the 
Motion, Mr. Sheppard states as follows: 
1. 
Mr. Sheppard surrendered in this matter and made his initial appearance and 
arraignment on July 12, 2022. 
2. 
Mr. Sheppard was released on a personal surety bond. Pursuant to that bond, Mr. 
Sheppard’s travel is limited to the Southern District of Florida, the Middle District of Florida, 
Eastern District of Michigan, and Eastern District of Pennsylvania, as long as Pre-Trial is notified 
of his departure and arrival. 
3. 
On July 31, 2023, Mr. Sheppard plans to travel to Philadelphia (staying at the 
Rittenhouse Hotel) to attend his daughter’s medical procedure at Children’s Hospital of 
Philadelphia where she has been receiving medical treatment for the past five (5) years.  
4. 
On August 1, 2023 to August 2, 2023, Mr. Sheppard respectfully requests to travel 
from the Eastern District of Pennsylvania to the Southern District of New York to meet with 
undersigned counsel. Mr. Sheppard will be staying at the Palace in New York.  
Case 1:22-cr-20290-BB   Document 51   Entered on FLSD Docket 07/26/2023   Page 1 of 2

2 
 
5. 
On August 3, 2023, Mr. Sheppard will travel from the Southern District of New 
York to Philadelphia to pick up his daughter and wife and together travel to pick up his son at a 
summer camp nearby. Mr. Sheppard will then travel to the Southern District of New York to drop 
his son off where he has several medical appointments scheduled.  
6. 
On August 4, 2023, Mr. Sheppard will travel from Newark International Airport   
to Miami.  
7. 
Undersigned counsel conferred with AUSA Aimee Jimenez regarding the relief 
sought in this Motion who did not oppose the relief sought. 
8. 
A proposed order granting the Motion is attached as Exhibit A. 
WHEREFORE, Defendant, Eric Dean Sheppard, respectfully requests entry of an order 
permitting him to travel  between Philadelphia  and New York and any intervening districts on the 
way, from July 31, 2023, to August 4, 2023 . 
 
Dated July 26, 2023  
 
 
 
Respectfully submitted, 
NELSON MULLINS  
2 S. Biscayne Boulevard, Suite 2100 
Miami, FL 33131  
Telephone: 305.373.9400  
Facsimile: 305.995.6449  
By: /s/ Jayne C. Weintraub 
Jon A. Sale  
Florida Bar No. 246387  
Jayne C. Weintraub 
Florida Bar No. 320382 
Jonathan Etra  
Florida Bar No. 686905 
Christopher Cavallo  
Florida Bar No. 0092305 
Case 1:22-cr-20290-BB   Document 51   Entered on FLSD Docket 07/26/2023   Page 2 of 2

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