Motion - United States v. David Tyler Hines

Summary

A Defendant's Unopposed Motion to Change Residence in United States v. David Tyler Hines, Case No. 21-20011-CR-COOKE, in the U.S. District Court for the Southern District of Florida, entered on the docket February 4, 2021 as Document 36. The motion asks permission to change the defendant's present residence, stating that the lease expires on February 7, 2021 and that the defendant will move to a nearby apartment. It states that counsel spoke with Assistant United States Attorney Emily Scruggs, who has no objection, and with United States Probation Officer Raymond Gravie, who does not object. A footnote cites Federal Rule of Criminal Procedure 49.1(a)(5) as the reason only the city and state of the address are included. The signature block names Elizabeth Blair.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO.  21-20011-CR-COOKE 
 
UNITED STATES OF AMERICA,  
 
Plaintiff, 
v. 
 
 
 
 
 
 
 
DAVID TYLER HINES, 
 
Defendant. 
_________________________________/ 
 
 
 
DEFENDANT’S UNOPPOSED MOTION TO CHANGE RESIDENCE 
 
 
The Defendant, David Tyler Hines, through undersigned counsel, moves this 
Court for permission to change his present residence.  In support of the motion, Mr. 
Hines states as follows: 
 
 Mr. Hines desires to relocate his residence, as his lease expires on February 
7, 2021.  He will be moving to a nearby apartment with his wife and stepson. 
Therefore, he requests that the Court permit him to change his address. 
 
Undersigned counsel has spoken with Assistant United States Attorney 
Emily Scruggs who has no objection to this request.1 
 
Undersigned counsel has spoken with United States Probation Officer 
Raymond Gravie, who currently supervises Mr. Hines. He does not object to this 
request. 
                                               
1Pursuant to Federal Rule of Criminal Procedure 49.1(a)(5), only the city and 
state of this address are included in this filing.  However, United States Probation 
Officer Raymond Gravie is aware of the complete address. 
Case 1:21-cr-20011-DPG   Document 36   Entered on FLSD Docket 02/04/2021   Page 1 of 2

 
WHEREFORE, the Defendant requests permission to change his residence. 
 
 
 
 
 
 
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 
 
 
 
 
 
 
 
Tel: (305) 530-7000 
 
 
 
 
 
 
 
Email: Elizabeth_blair @fd.org 
 
 
 
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY certify that on February 4, 2021, 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 36   Entered on FLSD Docket 02/04/2021   Page 2 of 2

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