Unopposed MOTION to Travel by Ernest Bernard Gonder, Jr — USA v. Gonder (Dkt. 14)

Record facts

U.S. District Court for the Southern District of Florida · No. 0:24-cr-60003-KMW · Doc. 14 · 2024-03-08 · Docket on CourtListener

Summary

A motion to travel filed March 8, 2024 by defendant Ernest Bernard Gonder Jr. in United States of America v. Gonder, No. 0:24-cr-60003-KMW, in the U.S. District Court for the Southern District of Florida. Through counsel Michael B. Cohen, the defendant asks permission to travel while out on bond for two personal reasons set out in the motion. One request covers travel on dates listed in a season schedule attached as Exhibit A; the other covers travel to Atlanta, Georgia between March 29 – March 31. Counsel states that AUSA Marc Anton does not object to the motion. It is Doc. 14, four pages including the Exhibit A cover page.

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Full text

IN THE UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 24-CR-60003-Williams/Hunt 
 
UNITED STATES OF AMERICA 
 
Vs.  
 
ERNEST BERNARD GONDER JR., 
 
 
 
 
Defendant.  
__________________________________ /  
 
MOTION TO TRAVEL  
 
COMES NOW, the Defendant, ERNEST BERNARD GONDER JR., (“Mr. Gonder”) by 
and through undersigned counsel who respectfully requests permission for Mr. Gonder to travel 
while out on bond to attend his son’s basketball game and to assist a second son with a move. As 
grounds therefore undersigned would state as follows:  
1. Mr. Gonder’s son, Johnathon Gonder, plays basketball for the Strive 4 Excellence team. 
Mr. Gonder is requesting permission to travel for his son’s basketball games for the 
season pursuant to the season schedule (Attached hereto as Exhibit A).  
2. Mr. Gonder’s second son, Ernest Gonder III, recently moved to Atlanta, Georgia to 
attend Gupton Jones College and is moving into a new apartment. Mr. Gonder is 
requesting permission to travel to provide his son assistance with the move between 
March 29 – March 31.   
3. Undersigned counsel has spoken to AUSA Marc Anton who does not object to this 
Motion. 
WHEREFORE undersigned counsel respectfully requests this instant motion be GRANTED.  
 
Dated: March 8, 2024.   
 
Case 0:24-cr-60003-KMW   Document 14   Entered on FLSD Docket 03/08/2024   Page 1 of 4

Respectfully submitted, 
 
Michael B. Cohen 
Michael B. Cohen, Esq. 
Florida Bar No:  210196 
6400 North Andrews Ave., Ste 505 
Fort Lauderdale, Florida 33309 
Ph (954) 928-0059 
 
 
 
 
 
 
   Email: micheal@mcohenlaw.com  
   Email: eservice@mcohenlaw.com  
 
 
 
Case 0:24-cr-60003-KMW   Document 14   Entered on FLSD Docket 03/08/2024   Page 2 of 4

 
 
 
 
EXHIBIT A 
 
 
 
 
Case 0:24-cr-60003-KMW   Document 14   Entered on FLSD Docket 03/08/2024   Page 3 of 4

Case 0:24-cr-60003-KMW   Document 14   Entered on FLSD Docket 03/08/2024   Page 4 of 4

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