Motion — United States v. David T. Hines (Dkt. 24, S.D. Fla. No. 1:21-cr-20011, FLSD 584464)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:21-cr-20011-DPG · Doc. 24 · 2020-11-02 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
MIAMI DIVISION 
 
CASE NO.  20-mj-3237-BECERRA 
 
UNITED STATES OF AMERICA,  
 
 
Plaintiff, 
v. 
 
 
 
 
 
 
 
DAVID TYLER HINES, 
 
 
Defendant. 
_________________________________/ 
 
 
DEFENDANT’S UNOPPOSED MOTION TO CHANGE ADDRESS 
 
 
David Hines, through undersigned counsel, files this motion to change address 
and in support, states the following:    
1. 
Mr. Hines made his initial appearance before Chief Magistrate Judge John 
J. O’Sullivan on July 27, 2020. [D.E. 4]. A stipulated personal surety bond 
of $100,000 with home detention and electronic monitoring was granted. 
2. 
The required bond was entered on July 29, 2020, and Mr. Hines was 
released from FDC custody. 
3. 
Mr. Hines has been residing with his mother at the address supplied to his 
United States Probation Officer. 
4. 
Mr. Hines wishes to relocate and reside with his wife and minor stepson. 
The proposed address has been supplied to United States Probation. 
5. 
Undersigned counsel has communicated with AUSA Michael Berger, who 
does not object. 
6. 
Undersigned has communicated with USP Officer Stwarka, who does not 
object. 
Case 1:21-cr-20011-DPG   Document 24   Entered on FLSD Docket 11/02/2020   Page 1 of 3

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WHEREFORE, the defendant respectfully requests that he be permitted to 
change his address to that provided to his assigned United States Probation 
Officer. 
 
 
 
 
Respectfully Submitted, 
 
 
 
 
 
MICHAEL CARUSO 
 
 
 
 
FEDERAL PUBLIC DEFENDER 
 
 
 
 
 
BY: 
   s/Elizabeth Blair_________                      
 
 
 
 
 
Elizabeth Blair 
 
 
 
 
 
Assistant Federal Public Defender 
 
 
 
 
 
Florida Bar No. 106280 
 
 
 
 
 
150 W. Flagler Street, Suite 1700 
 
 
 
 
 
Miami, Florida 33130-1556 
 
 
 
 
 
(305) 530-7000 
 
 
 
 
 
(305) 536-4559, Fax 
 
 
 
 
 
E-Mail:  elizabeth_blair@fd.org 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 1:21-cr-20011-DPG   Document 24   Entered on FLSD Docket 11/02/2020   Page 2 of 3

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CERTIFICATE OF SERVICE 
 
 
I HEREBY certify that on November 2, 2020, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF.  I also certify that the foregoing 
document is being served this day on all counsel of record via transmission of Notices of 
Electronic Filing generated by CM/ECF or in some other authorized manner for those 
counsel or parties who are not authorized to receive electronically Notices of Electronic 
Filing. 
 
 
 
 
 
 
 
 
s/Elizabeth Blair  
 Elizabeth Blair 
Case 1:21-cr-20011-DPG   Document 24   Entered on FLSD Docket 11/02/2020   Page 3 of 3

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