Unopposed MOTION to Modify Conditions of Release by Gregory Scott Keough.… — USA v. Keough (Dkt. 46)

Record facts

U.S. District Court for the Southern District of Florida · No. 9:23-cr-80154-DMM · Doc. 46 · 2023-11-20 · Docket on CourtListener

Summary

Defendant Gregory Scott Keough's unopposed motion to modify conditions of release, filed November 20, 2023 as Doc. 46 in United States v. Keough, Case No. 23-CR-80154-DMM, in the U.S. District Court for the Southern District of Florida. The motion asks the Court to change home confinement to a curfew from 10:00 pm to 8:00 am and to remove the requirement that he give Probation a schedule a week in advance. Its background section recounts the eleven-count Indictment returned August 24, 2023, the $1,500,000 personal surety bond and $1,500,000 corporate surety bond with GPS monitoring and home detention, and a change of plea on November 13, 2023, with sentencing set for February 8, 2024. The motion states that the assigned probation officer recommended the curfew and that the government does not object. It is signed by defense counsel David J. Joffe and Patrick R. McKamey.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO.  23-CR-80154-DMM 
 
UNITED STATES OF AMERICA 
 
vs. 
 
GREGORY SCOTT KEOUGH, 
 
 
 
 
Defendant. / 
 
DEFENDANT’S UNOPPOSED MOTION TO  
MODIFY CONDITIONS OF RELEASE 
 
Greg Scott Keough, through undersigned counsel, respectfully files this unopposed motion 
to modify conditions of release, that is, modify home confinement to permit a curfew from 10:00 
pm to 8:00 am.  In support, the Defendant states as follows:  
BACKGROUND 
1. 
On August 8, 2023, a Federal complaint was filed against Greg Scott Keough charging 
him with conspiracy to commit wire fraud, in violation of Title 18, United States Code, Section 1349; 
wire fraud, in violation of Title 18, United States Code, Section 1343; and engaging in monetary 
transactions in criminally derived proceeds, in violation of Title 18, United States Code, Section 
1957(a) (DE 3). 
2. 
On August 9, 2023, the Defendant appeared before U.S. Magistrate Judge William 
Matthewman for his initial appearance and was advised of the pending charges (DE10).   
3. 
On August 24, 2023, a Federal Grand Jury sitting in the Southern District of Florida, 
returned an eleven-count Indictment charging Greg Scott Keough with conspiracy to commit wire 
fraud, in violation of Title 18, United States Code, Section 1349 (Count 1); wire fraud, in violation of 
Title 18, United States Code, Section 1343 (Counts 2-7); and engaging in monetary transactions in 
Case 9:23-cr-80154-DMM   Document 46   Entered on FLSD Docket 11/20/2023   Page 1 of 4

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criminally derived proceeds, in violation of Title 18, United States Code, Section 1957(a) (Counts 8-
11)(DE 17). 
4. 
At the government’s request for pre-trial detention, the Court held a detention hearing 
on August 25, 2023, which was continued on August 31, 2023, and September 6, 2023 (DE 14, 23, 
26). 
5. 
At the conclusion of the detention hearing, the Court entered a $1,500,000 personal 
surety bond and $1,500,000 corporate surety bond with co-signers (DE 26). Along with the standard 
conditions, the Court also imposed special conditions, which included GPS monitoring and home 
detention (DE 28, 29).   
6. 
On November 13, 2023, without the benefit of a written plea agreement, Greg Scott 
Keough entered a change of plea as to Counts 4, 5 and 8 of the Indictment (DE 43).  Sentencing in this 
matter is scheduled for February 8, 2024 (DE 44).  
7. 
The undersigned counsel represents that Greg Scott Keough has been in compliance 
with all conditions of release.  Further, on November 13, 2023, counsel conferred with the government 
and the assigned Probation Officer Lucien Michel, re: modification of bond conditions.    P.O. Lucien 
Michel recommended a modification of home detention to include a curfew to the residence on record 
from 10:00 pm to 8:00 am, or as directed by the supervising officer.  The government does not object.   
8. 
As a part of Greg Scott Keough’s supervision, he is obligated to provide Probation 
each Tuesday, a schedule for the following 7-day week commencing Wednesday.  Such a 
requirement has hindered Keough’s ability to spontaneously meet with counsel as each counsel 
becomes available.   In light of the Defendant’s family members visitation during the holidays, the 
potential likelihood of Probation’s unavailability during the holidays, and the active GPS, the 
Defendant respectfully requests that the requirement to provide Probation a schedule a week in 
advance be eliminated.  The undersigned counsel has twice attempted contact the assigned 
Case 9:23-cr-80154-DMM   Document 46   Entered on FLSD Docket 11/20/2023   Page 2 of 4

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Probation officer; however, counsel has not heard back as to Probation’s position.  The government 
indicates that it would defer to Probation and the Court regarding this condition.  
DISCUSSION 
Although the Court found Defendant Greg Keough a risk of flight, the Court also determined 
that conditions of release could be fashioned to ensure the Defendant’s appearance in court.  The Court, 
having entered a bond, the Defendant was released and has been in compliance with all the conditions 
of release.   With the impending holidays, Greg Scott Keough anticipates engaging with various family 
members, to include participating in family events in the evening hours.  Greg Scott Keough will 
remain on GPS monitoring and only wishes to take part with family, who intends to visit with the 
Defendant.  The modification sought will not hinder Probation’s ability to monitor the Defendant.  
WHEREFORE, the Defendant respectfully request that the Court grant the unopposed motion 
to modify the conditions of release to include curfew of 10:00 pm to 8:00 am, as a part of home 
confinement.  
 
Respectfully submitted, 
 
 
 
 
 
 
/s/ David J. Joffe 
 
 
 
 
 
DAVID JONATHAN JOFFE 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
Florida Bar #: 814164 
 
 
 
 
 
110 SE 6th Street, Ste 1700 
 
 
 
 
 
Fort Lauderdale, FL 33301 
 
 
 
 
 
Tel: (954) 723-0007 
 
 
 
 
 
Fax: (954) 723-0033 
 
 
 
 
 
 
/s/ Patrick R. McKamey 
 
 
 
 
 
PATRICK R. McKAMEY 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
Florida Bar #: 103624 
 
 
 
 
 
515 N. Flagler Dr. Ste P300 
 
 
 
 
 
West Palm Beach, FL 33401 
 
 
 
 
 
Tel: (561) 370-7424 
 
 
 
 
 
Fax: (561) 370-7401 
 
Case 9:23-cr-80154-DMM   Document 46   Entered on FLSD Docket 11/20/2023   Page 3 of 4

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CERTIFICATE OF SERVICE 
The Defendant certifies that on November 20, 2023, a copy of the foregoing document was 
filed electronically with the Clerk of the Court using CM/ECF.     
/s/ David Joffe                   
 
 
DAVID JOFFE 
Counsel for Defendant 
Case 9:23-cr-80154-DMM   Document 46   Entered on FLSD Docket 11/20/2023   Page 4 of 4

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