Agreed Motion for Return of Property/PreTrial — USA v. Sheppard (Dkt. 109, S.D. Fla.)

Summary

Document 109, filed 09/27/23 in No. 1:22-cr-20290-BB in the U.S. District Court for the Southern District of Florida, is a two-page Agreed Motion for Return of Son's Passport filed by defendant Eric Sheppard's counsel. It recalls that his bond, agreed July 12 and entered July 15, 2022, required surrender of his wife's and his son's passports. The son is a minor and not a defendant, and his expired passport is with pre-trial services. The defense says he wants to take a school trip abroad and needs a valid passport, so it asks for the expired one back to obtain a new one. The government has no objection, and the motion says Sheppard has fully complied with pre-trial services. The ruling is not in this text.

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Record facts

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. 
____________________________________/ 
 
AGREED TO MOTION FOR RETURN OF SON’S PASSPORT 
 
Defendant, Eric Sheppard, by and through his undersigned counsel, hereby files this 
Agreed to Motion for Return of Son’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 and son as a condition of the bond. [D.E. 14 at 2; D.E. 15 at 2]. 
3. 
The Defendant’s minor son is not a defendant in this case.  
4. 
Presently, the Defendant’s son’s passport, which is expired, is with pre-trial 
services, as dictated by the conditions of the bond.  
5. 
Defendant’s son seeks to travel out of the country with his school and requires his 
passport.  To be eligible for this trip, the Defendant’s son needs to have a valid, up to date passport.   
6. 
Accordingly, Defendant seeks the return of this son’s expired passport, so that his 
son can get an up to date, valid passport, for use with the school trip. 
7. 
The Government has no objection and agrees to the Court returning the Defendant’s 
son’s passport. 
Case 1:22-cr-20290-BB   Document 109   Entered on FLSD Docket 09/27/2023   Page 1 of 2

2 
 
8. 
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 son presently held by pre-trial services, be returned to him forthwith. 
Dated: September 27, 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 September 27, 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 109   Entered on FLSD Docket 09/27/2023   Page 2 of 2

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