Unopposed MOTION to Modify Conditions of Release by Gregory Scott Keough.… — USA v. Keough (Dkt. 48)

Record facts

U.S. District Court for the Southern District of Florida · No. 9:23-cr-80154-DMM · Doc. 48 · 2023-12-21 · Docket on CourtListener

Summary

Defendant Gregory Scott Keough's unopposed motion to modify conditions of release, filed December 21, 2023 in United States v. Keough, Case No. 23-CR-80154-DMM (No. 9:23-cr-80154-DMM), in the U.S. District Court for the Southern District of Florida, as Doc. 48. The motion recounts the procedural history: an eleven-count Indictment returned August 24, 2023, a $1,500,000 personal surety bond and $1,500,000 corporate surety bond with GPS monitoring and home detention, a change of plea on November 13, 2023 as to Counts 4, 5 and 8, and sentencing set for February 8, 2024. It notes the court's November 21, 2023 order replacing home detention with a 10:00 p.m. to 8:00 a.m. curfew. Citing the holidays, it asks that the curfew run from 12:00 a.m. to 8:00 a.m., and states that the government and probation do not object. It is signed by 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 (DE 10).   
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 48   Entered on FLSD Docket 12/21/2023   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. 
On November 21, 2023, this Court granted Greg Scott Keough’s Unopposed Motion 
to Modify Conditions of Release as follows: “The Home Detention component of Defendant’s release 
conditions is hereby terminated. In lieu of Home Detention, a daily curfew of 10:00 p.m. to 8:00 a.m. 
is hereby imposed. Defendant shall at all times be at his approved place of residence each day between 
10:00 p.m. and 8:00 a.m.” (DE 47).  
8. 
Greg Scott Keough respectfully requests the modification of his conditions of release 
as follows:  daily curfew at his place of residence between 12:00 a.m. and 8:00 a.m.    
9. 
The undersigned counsels represent that Greg Scott Keough has been in compliance 
with all conditions of release. 
10. 
AUSA Robin Waugh and Greg Scott Keough’s probation officer, Lucien Michel, have 
no objection to the modification of the pretrial release.   
 
Case 9:23-cr-80154-DMM   Document 48   Entered on FLSD Docket 12/21/2023   Page 2 of 4

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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 requests that the Court grant the unopposed motion 
to modify the conditions of release to include curfew of 12:00 a.m. to 8:00 a.m., 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 48   Entered on FLSD Docket 12/21/2023   Page 3 of 4

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CERTIFICATE OF SERVICE 
The Defendant certifies that on December 21, 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 48   Entered on FLSD Docket 12/21/2023   Page 4 of 4

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