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Home Court filings United States v. Evan Edwards and Joshua Edwards Report and Recommendation on Restoration Procedures — United States v. Evan Edwards (a/k/a Ian Heringa) and Joshua Edwards (M.D. Fla. No. 6:22-cr-00201)

Court filing

Report and Recommendation on Restoration Procedures — United States v. Evan Edwards (a/k/a Ian Heringa) and Joshua Edwards (M.D. Fla. No. 6:22-cr-00201)

Filed October 3, 2023 in U.S. v. Evan Edwards; one of 3 filings from this case.

No. 6:22-cr-00201-AGM-LHP · Doc. 117 · 2023-10-03 · Docket on CourtListener

Full text

Case 6:22-cr-00201-AGM-LHP      Document 117      Filed 10/03/23    Page 1 of 17 PageID 548




                           UNITED STATES DISTRICT COURT
                              MIDDLE DISTRICT OF FLORIDA
                                     ORLANDO DIVISION

      UNITED STATES OF AMERICA

      VS.                                               CASE NO: 6:22-cr-201-WWB-LHP

      EVAN EDWARDS




                              REPORT AND RECOMMENDATION1
      TO THE UNITED STATES DISTRICT COURT:

            This case comes before the Court following extensive competency

      proceedings under 18 U.S.C. §§ 4241 and 4247. As discussed in more detail below,

      the parties agree that Defendant Evan Edwards is not presently competent to stand

      trial under the standards set forth in 18 U.S.C. § 4241(d) and Dusky v. United States,

      362 U.S. 402 (1960). However, the parties contest whether the Court must now

      commit Evan Edwards to the custody of the Attorney General for restoration

      treatment and evaluation, as required by 18 U.S.C. § 4241(d)(1), or whether the

      Court can skip this step and instead proceed to evaluation under either 18 U.S.C. §§

      4246 or 4248. See Doc. Nos. 108, 116.



            1
                Although the undersigned has the authority to enter an order when the parties do
      not contest the issue of competency, because the parties do contest the course of further
      proceedings in this case, the undersigned has addressed this issue via the present report
      and recommendation. See In re: Authority of United States Magistrate Judges in the Middle
      District of Florida, No. 8:20-mc-100-T-23, Doc. No. 3 § (d)(27) (M.D. Fla. Oct. 29, 2020).
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            For the reasons set forth in this report, I find the procedures of 18 U.S.C. §

      4241(d)(1) to be mandatory, and will therefore respectfully recommend that the

      Court commit Evan Edwards to the custody of the Attorney General, who shall

      hospitalize Evan Edwards for treatment in a suitable facility for a reasonable time,

      not to exceed four months, as is necessary to determine whether there is a

      substantial probability that in the foreseeable future he will attain the capacity to

      permit the proceedings to go forward.

      I.    RELEVANT PROCEDURAL HISTORY

            On December 7, 2022, a grand jury returned an indictment charging Evan

      Edwards with one count of conspiracy to commit bank fraud, one count of bank

      fraud, and two counts of visa fraud, in violation of 18 U.S.C. § 1349, 18 U.S.C. § 1344,

      and 18 U.S.C. § 1546(a), respectively. Doc. No. 1. Evan Edwards was arrested on

      December 14, 2022, and an initial appearance proceeding pursuant to Fed. R. Crim.

      P. 5 was conducted before United States Magistrate Judge David A. Baker that same

      day. Doc. Nos. 9, 10.

            During the course of the Rule 5 proceedings, Magistrate Judge Baker

      determined that there was a question as to Evan Edward’s mental competency to

      proceed. Doc. Nos. 9, 14. Accordingly, Magistrate Judge Baker continued the

      Rule 5 proceedings, provisionally appointed counsel pursuant to the Criminal

      Justice Act, and ordered Evan Edwards temporarily detained and committed to the



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      custody of the United States Marshal for provision of medical care. Doc. Nos. 9,

      17, 21, 25-26. 2

             Magistrate Judge Baker held a status conference with counsel on December

      21, 2022, and on December 27, 2022 Magistrate Judge Embry J. Kidd held a

      continuation of the Rule 5 hearing via the online Zoom platform, and attempted to

      conduct an arraignment. Doc. Nos. 27, 33. Magistrate Judge Kidd was able to

      complete a portion of the Rule 5 proceedings – he advised Evan Edwards of his

      rights, and summarized the charges and the potential penalties – but was unable to

      go forward with any further proceedings or the arraignment.             Doc. No. 33.

      Magistrate Judge Kidd thereafter held status hearings with counsel on December

      28, 2022, and January 4, 2023, and on January 6, 2023, appointed Dr. Ryan C. W.

      Hall, M.D., DFAPA, to examine Evan Edwards pursuant to 18 U.S.C. §§ 4241 and

      4247(b). Doc. Nos. 42, 45, 48, 50.

             On January 16, 2023, Dr. Hall submitted his expert report, in which he opined

      that Evan Edwards was currently incompetent to proceed, but that the question of

      whether Evan Edwards’ competency could be restored was unclear. Doc. No. 58

      (filed under seal). Counsel for Evan Edwards objected to Dr. Hall’s findings, and


             2
               Magistrate Judge Baker initially provisionally appointed the Federal Public
      Defender to represent Evan Edwards, but based on a conflict of interest, authorized the
      Federal Public Defender’s withdrawal, and provisionally appointed Attorney A. Brian
      Phillips under the Criminal Justice Act on December 20, 2022. Doc. Nos. 17, 24-26.
      Attorney Phillips continues to represent Evan Edwards to date.


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      filed a motion for detention hearing. Doc. No. 56. The United States noted its

      agreement with Dr. Hall’s findings, and requested that a hearing be set to address

      competency, with a commitment order under 18 U.S.C. § 4241(d) to follow. Doc.

      No. 57.

            By this point, the case had been reassigned to the undersigned. On February

      24, 2023, following several status conferences with counsel and briefing from both

      sides (Doc. Nos. 65, 78-79; Doc. No. 66 under seal), I denied without prejudice Evan

      Edwards’ motion for a detention hearing, and motion to prohibit his transfer by the

      United States Marshals Service. Doc. No. 85; see also Doc. Nos. 56, 77. 3

            By that same Order, I also found that there was reasonable cause to believe

      that Evan Edwards was presently suffering from a mental disease or defect

      rendering him mentally incompetent to the extent that he was unable to understand

      the nature and consequences of the proceedings against him or to assist properly in

      his defense.   Doc. No. 85, at 5-6; see also 18 U.S.C. § 4241(a).       Accordingly, I

      committed Evan Edwards to the custody of the Attorney General for placement at




            3
              Up until this point in the case, Evan Edwards had remained in the custody of the
      United States Marshals Service and was receiving around-the-clock medical care at
      Orlando Regional Medical Center (“ORMC”). The United States Marshals Service
      ultimately designated Evan Edwards to the Columbia Regional Care Center (the “Care
      Center”) in Columbia, South Carolina, which provides a program for inmates and
      detainees with complex medical issues. Evan Edwards, through counsel, filed a motion
      to prohibit this transfer to the Care Center, which motion the undersigned denied. Doc.
      No. 85.


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      the Federal Medical Center in Butner, North Carolina (“FMC Butner”) for a term

      not to exceed 30 days to conduct a psychiatric or psychological examination, and to

      prepare and submit to the Court and all parties a psychiatric or psychological report

      assessing “whether [Evan Edwards] is suffering from a mental disease or defect

      rendering him mentally incompetent to the extent that he is unable to understand

      the nature and consequences of the proceedings against him or to assist properly in

      his defense.” Doc. No. 85, at 5-6 (quoting 18 U.S.C. §§ 4247(b), (c)). See also 18

      U.S.C. § 4241(b). 4

            On July 7, 2023, Dr. Miriam Kissin, Psy. D., a forensic psychologist employed

      by the Bureau of Prisons, submitted a forensic report regarding Evan Edwards’

      present competency to stand trial. Doc. No. 98 (under seal). 5 Dr. Kissin opined,

      following completion of the 30-day evaluation period set forth in 18 U.S.C. §

      4247(b), that Evan Edwards’ “present competency-related skills are significantly

      compromised by symptoms of a serious mental illness or defect, namely Major

      Neurocognitive Disorder (Dementia) without behavioral disturbance, severe, such

      that he is unable to understand the nature and consequences of the proceedings



            4
             The Bureau of Prisons changed Evan Edwards’ designation to FMC Devens in
      Ayer, Massachusetts, as that facility operated a unit specifically for individuals with
      dementia-related illnesses and could provide the medical care he required.
            5
             Although Dr. Kissin’s report remains under seal, it is necessary to discuss some of
      her conclusions in this report and recommendation, although the undersigned has
      endeavored to keep such discussion to the minimum necessary to render this report.


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      against him or to assist properly in his defense.” Id., at 8. Under a section entitled

      “Prognosis and Recommendations,” Dr. Kissin further opined that:

                   Mr. Edwards’s Major Neurocognitive Disorder (Dementia) has a
            significant negative impact on his ability to function or make rational
            decisions or to effectively aid his defense counsel. As evidenced by
            his presentation over the last several months, Mr. Edwards has
            demonstrated no ability to engage meaningfully with others.
            Typically, there is a one-year window for rehabilitation to ensure some
            functional gains post brain injury. As this time frame has already
            passed, limited if any, improvement in Mr. Edwards's cognitive
            functioning would be expected. Furthermore, his attending medical
            provider has opined that Mr. Edwards has suffered irreversible
            neurological damage. As such, a period of restoration to competency
            pursuant to Title 18, United States Code, Section 424l(d) is not
            indicated for Mr. Edwards as he is not expected to benefit from
            educational interventions in light of his neurological disorder. He
            would be best served within a structured setting where he has access
            to regular support to meet his basic needs.

      Id.

            Upon review of Dr. Kissin’s report, Evan Edwards, through counsel, filed a

      renewed motion for a detention hearing. Doc. No. 99. The parties subsequently

      filed a joint notice (Doc. No. 101; see also Doc. No. 100), stating that neither side

      currently contests the finding of incompetence made within Dr. Kissin’s report.

      Doc. No. 101, at 1. However, the parties further represented that the question of

      what further proceedings were necessary and appropriate remained in dispute.

      Id., at 1-2. The United States also filed a separate response, in which it agreed that

      conditions of pretrial release could now be set. Doc. No. 102.

            On August 3, 2023, the undersigned conducted a status conference with


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      counsel, at the conclusion of which the undersigned scheduled a detention hearing

      for August 31, 2023, and established a briefing schedule for the parties to argue their

      positions as to whether the restoration procedures of 18 U.S.C. § 4241(d) apply, and,

      if not, what further proceedings should occur in this case. Doc. Nos. 104-06. The

      detention hearing was rescheduled for September 12, 2023, and Magistrate Judge

      Kidd conducted the hearing due to the undersigned’s unforeseen absence. Doc.

      Nos. 107, 112. At the conclusion of the hearing, Magistrate Judge Kidd released

      Evan Edwards on various pretrial conditions, including that he be placed in the

      custody of his wife, Mary Jane Edwards, who agreed to act as third-party custodian.

      Doc. No. 114. Evan Edwards remains out on these conditions of release as of the

      date of this report.

            In the meantime, the parties have now submitted their briefing on the

      question of further proceedings, and Evan Edwards has submitted, under seal,

      copies of some of his medical records, which the undersigned has reviewed. Doc.

      Nos. 108, 116; see also Doc. No. 111, under seal. The issue is therefore ripe for

      consideration and this report and recommendation follows.

      II.   ANALYSIS

            18 U.S.C. § 4241(d) provides as follows:

                  (d) Determination and disposition.--If, after the hearing, the
            court finds by a preponderance of the evidence that the defendant is
            presently suffering from a mental disease or defect rendering him
            mentally incompetent to the extent that he is unable to understand the


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            nature and consequences of the proceedings against him or to assist
            properly in his defense, the court shall commit the defendant to the
            custody of the Attorney General. The Attorney General shall
            hospitalize the defendant for treatment in a suitable facility—

                 (1) for such a reasonable period of time, not to exceed four
            months, as is necessary to determine whether there is a substantial
            probability that in the foreseeable future he will attain the capacity to
            permit the proceedings to go forward; and

                   (2) for an additional reasonable period of time until—

                    (A) his mental condition is so improved that trial may proceed,
            if the court finds that there is a substantial probability that within such
            additional period of time he will attain the capacity to permit the
            proceedings to go forward; or

                  (B) the pending charges against him are disposed of according
            to law;

                   whichever is earlier.

                   If, at the end of the time period specified, it is determined that
            the defendant’s mental condition has not so improved as to permit the
            proceedings to go forward, the defendant is subject to the provisions
            of sections 4246 and 4248.

      18 U.S.C. § 4241(d) (emphasis supplied).

            The Eleventh Circuit Court of Appeals has made clear that once a defendant

      is found incompetent to stand trial, the language of § 4241(d) mandates that the

      defendant be hospitalized under the custody of the Attorney General for a careful

      determination of the likelihood of regaining mental capacity to stand trial. United

      States v. Donofrio, 896 F.2d 1301, 1303 (11th Cir. 1990). The Eleventh Circuit further

      held that this hospitalization did not violate due process because the period of


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      commitment is limited by § 4241(d) itself to a “reasonable period,” not to exceed

      four (4) months, and the period may only be extended by a separate finding that the

      defendant would attain competency within the additional time. Id. The Court of

      Appeals further held that the provisions of § 4241(d) are mandatory even if it

      appears that a defendant’s mental condition/competency status is permanent; as

      “[t]he permanency of the condition would then be determined for later

      consideration by the court” following the hospitalization period set forth in §

      4241(d). Id.

            Donofrio remains the binding precedent for this Circuit, and every other

      Circuit to address this issue has reached the same conclusion. See, e.g., United States

      v. Shawar, 865 F.2d 856, 860 (7th Cir. 1989) (“The statute plainly states that ‘the court

      shall commit the defendant to the custody of the Attorney General [who] shall

      hospitalize the defendant for treatment . . . .’ The plain meaning of this phrase is,

      and we hold it to be, that once a defendant is found incompetent to stand trial, a

      district judge has no discretion in whether or not to commit him.” (quoting 18 U.S.C.

      § 4241(d)) (emphasis in original)); United States v. Filippi, 211 F.3d 649, 651 (1st Cir.

      2000) (noting that § 4241(d) “certainly establishes a general rule of some breadth

      and does not appear to call for any case-by-case choice by the district court as to

      whether to incarcerate once the incompetency finding has been made.”); United

      States v. Ferro, 321 F.3d 756, 761 (8th Cir. 2003) (noting that although “[i]t is clear



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    that the statutory scheme detailed by Congress in § 4241(d) provides the district

    court with the discretion to initially determine whether the defendant is competent

    to stand trial . . . . [A]fter determining that a defendant is incompetent . . . a district

    court is required to commit the defendant to the custody of the Attorney General

    for a reasonable period of time to evaluate whether treatment would allow the trial

    to proceed.”); United States v. Magassouba, 544 F.3d 387, 404 (2d Cir. 2008) (“[I]n

    contrast to the discretion afforded district courts in deciding whether to commit a

    defendant for a preliminary competency examination, once a defendant is found

    incompetent, commitment pursuant to 4241(d) is mandatory.” (citations omitted));

    United States v. McKown, 930 F.3d 721, 727 (5th Cir. 2019) (“[U]nlike the court’s

    discretion to confine a defendant before an initial competency hearing, commitment

    is mandatory upon a finding of incapacity.              That is so irrespective of the

    defendant’s initial prognosis.” (footnotes omitted) (citing 18 U.S.C. § 4241(d));

    United States v. Donnelly, 41 F.4th 1102, 1105 (9th Cir. 2022) (“The [Insanity Defense

    Reform Act] thus imposes two mandatory duties following an incompetency

    finding. First, the district court ‘shall commit the defendant to the custody of the

    Attorney General.’ Second, ‘[t]he Attorney General shall hospitalize the defendant

    for treatment in a suitable facility . . . for such a reasonable period of time, not to

    exceed four months.’” (quoting 18 U.S.C. § 4241(d)(1)). See also United States v. Lee,

    No. 1:21-CR-20034, 2022 WL 18275882, at *3 (S.D. Fla. Dec. 27, 2022), report and



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    recommendation adopted, 2023 WL 168755 (S.D. Fla. Jan. 12, 2023) (“Upon a finding of

    incompetence to continue in proceedings against a criminal defendant, a court must

    commit the defendant to the custody of the Attorney General for a period not to

    exceed four months to evaluate whether the defendant may be restored to

    competency.     Such commitment is mandatory.” (citing 18 U.S.C. § 4241(d)(1);

    Donofrio, 896 F.2d at 1303); United States v. Calhoun, No. 2:22-CR-167-ECM, 2023 WL

    2316186, at *1 (M.D. Ala. Mar. 1, 2023), appeal dismissed, No. 23-10773, 2023 WL

    3863505 (11th Cir. June 7, 2023) (“Upon the finding of incompetency, commitment

    to the custody of the Attorney General for a period of restoration is mandatory.”

    (citing 18 U.S.C. § 4241(d)(1); Donofrio, 896 F.2d at 1303).

          In his briefing on the issue, Evan Edwards recognizes this body of authority,

    and does not cite to any decisions suggesting § 4241(d) is not mandatory. Rather,

    Evan Edwards argues that the caselaw is factually distinguishable because here, the

    question of Evan Edwards’ restoration to mental competency is a foregone

    conclusion, and therefore any further treatment would only serve to punish him

    and violate his due process rights. Doc. No. 108. Evan Edwards focuses on his

    extensive medical history, which demonstrates several life-threatening medical

    issues since July 2022, and suggests that Evan Edwards has suffered irreversible

    brain damage and is unable to independently perform basic activities of daily

    living. Id., at 5-7; see also Doc. No. 111, under seal. Evan Edwards particularly



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    focuses on the statements by Dr. Kissin in her BOP report that “limited if any,

    improvement in Mr. Edwards’s cognitive functioning would be expected,” that

    Evan Edwards “has suffered irreversible neurological damage,” and therefore

    hospitalization for restoration proceedings under § 4241(d) “is not indicated.”

    Doc. No. 98, at 8. In short, Evan Edwards contends that “the BOP has already

    resolved this issue” of restoration, therefore any further restoration is “[a] factually

    unnecessary endeavor,” and would render “meaningless the clear and

    unambiguous findings of the government’s report.” Doc. No. 108, at 9.

          While there can be no dispute that Evan Edwards suffers from a myriad of

    serious physical and mental ailments, the undersigned disagrees that complying

    with the clear mandates of § 4241(d) would be a “factually unnecessary endeavor.”

    While Dr. Kissin’s opinions do suggest that restoration will ultimately be

    unsuccessful, she rendered that opinion after only conducting the preliminary 30-

    day evaluation contemplated by 18 U.S.C. § 4241(b), and § 4247(b), and she

    prepared her report in accordance with 18 U.S.C. § 4247(c), which does not request

    a finding as to probability of restoration. See Doc. No. 98, at 1, under seal. In other

    words, Dr. Kissin’s evaluation was focused primarily on whether Evan Edwards is

    currently competent to proceed. See United States v. Brennan, 928 F.3d 210, 217 n.2

    (2d Cir. 2019) (noting that the initial psychiatric evaluation is limited by § 4241(b)

    and § 4247(b) to a period not to exceed 30 days, thus “constraining a medical



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    professional’s ability to evaluate and treat a mentally incompetent defendant.”).

          In contrast, the period of commitment to assess restoration necessarily

    involves a much more detailed evaluation and assessment, focusing on the future.

    It “requires a more ‘careful and accurate diagnosis’ than the ‘brief interviews’ and

    ‘review of medical records’ that tend to characterize the initial competency

    proceeding.” United States v. Strong, 489 F.3d 1055, 1062 (9th Cir. 2007) (citing

    Ferro, 321 F.3d at 762; Filippi, 211 F.3d at 651). See also McKown, 930 F.3d at 728 (“On

    account of ‘the limitations on the federal courts in the field of mental health,’ the

    statute reasonably permits a more thorough evaluation before the district court

    must decide ‘whether to defer trial indefinitely and (quite often) to release the

    defendant back into society.’”) (first quoting Shawar, 865 F.2d at 860-61, then

    quoting Filippi, 211 F.3d at 651). Thus, with all due respect to Dr. Kissin’s opinions,

    whether or not Evan Edwards is capable of restoration to competency is not a

    foregone conclusion.

          In addition, decisional authority from within this Circuit and others shows

    that even where the likelihood of restoration is bleak, § 4241(d) is mandatory and

    cannot be ignored. See Donofrio, 896 F.2d at 1302-03 (finding that following the

    mandates of § 4241(d) did not violate due process even though evidence was

    presented at the initial § 4241(a) proceedings that defendant would never attain the

    capacity to permit a trial to proceed); United States v. Millard-Grasshorn, 603 F.3d 492,



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    494 (8th Cir. 2010) (“When a finding of mental incompetence is made after the

    competency hearing mandated by § 4241(a), the defendant must be committed

    under § 4241(d) for a restoration-of-competency evaluation, even if there is evidence

    that his condition can never improve.” (emphasis in original)); McKown, 930 F.3d at

    728 (finding order committing defendant for four month restoration evaluation

    accords with due process because “even where the medical evidence indicates that

    the defendant’s condition is permanent, temporary hospitalization bears some

    reasonable relation to the purpose for that confinement.”); Brennan, 928 F.3d at 215-

    16 (because the district court found the defendant presently incompetent,

    commitment under § 4241(d) was mandatory and constitutional, even though

    expert who conducted initial competency evaluation opined that defendant’s

    mental capacity was highly unlikely to improve); Shawar, 865 F.2d at 861 (“Our

    reading of 18 U.S.C. § 4241(d) is not only that commitment is mandatory, but also

    that likelihood of recovery is not something to be considered by the district court in

    deciding whether to commit the defendant for the evaluation period”; thus, even

    though experts had already opined that defendant’s mental defect would not

    change, commitment for restoration assessment was still required). See also United

    States v. Cottingham, Case No. 5:19-cr-00010-LCB-JHE-1, Doc. No. 35 (N.D. Ala. Nov.

    5, 2019) (even though Bureau of Prisons’ expert opined in forensic report that

    “considering the typical nature of neurocognitive disorders, it is questionable as to



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    whether the defendant would experience any significant improvement in his

    mental state,” district court committed defendant to custody of Attorney General

    for restoration hospitalization under mandatory provisions of § 4241(d); noting that

    “the process of determining whether a defendant is competent or not is markedly

    different from determining whether an incompetent defendant may be restored to

    competency.”); United States v. Hooks, No. CR 21-054, 2022 WL 1207824, at *5 (E.D.

    La. Mar. 31, 2022), report and recommendation adopted, No. CV 21-MJ-54, 2022 WL

    1202895 (E.D. La. Apr. 22, 2022) (while recognizing a state court finding that the

    defendant was “irrestorably incompetent,” district court had no discretion and

    must commit defendant to the custody of the Attorney General for further

    evaluation under § 4241(d)). Evan Edwards points to no legal authority suggesting

    a contrary conclusion.

          In sum, the binding and persuasive precedent on this issue has uniformly

    held that § 4241(d) is mandatory.     Once a district court finds a defendant be

    presently incompetent, the court has no discretion – the defendant must be

    committed to the custody of the Attorney General for a reasonable period not to

    exceed four months in order to assess whether mental competency can be restored.

    Whether or not the evidence in this case (including Dr. Kissin’s statements during

    the initial evaluation process) suggests that the answer to this question for Evan

    Edwards will ultimately be no, does not change this result.



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    III.   RECOMMENDATION

           Because the parties do not dispute that Evan Edwards is currently

    incompetent to proceed, and for the reasons set forth in this report, I

    RESPECTFULLY RECOMMEND that the Court find that Defendant Evan

    Edwards is presently suffering from a mental disease or defect rendering him

    mentally incompetent to the extent that he is unable to understand the nature and

    consequences of the proceedings against him or to assist properly in this defense.

    See 18 U.S.C. § 4241(d). I FURTHER RECOMMEND that the Court commit Evan

    Edwards to the custody of the Attorney General for hospitalization and treatment

    in a suitable facility for such a reasonable period of time, not to exceed four (4)

    months, as is necessary to determine whether there is a substantial probability that

    in the foreseeable future he will attain the capacity to permit the proceedings to go

    forward. I FURTHER RECOMMEND that the Court permit Evan Edwards to

    self-surrender to the facility so designated by the Attorney General for such

    hospitalization and treatment.


                                  NOTICE TO PARTIES

           A party has fourteen days from the date the Report and Recommendation is

    served to serve and file written objections to the Report and Recommendation’s

    factual findings and legal conclusions. Failure to serve written objections waives

    that party’s right to challenge on appeal any unobjected-to factual finding or legal


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    conclusion the district judge adopts from the Report and Recommendation. 11th

    Cir. R. 3-1.

           Recommended in Orlando, Florida on October 3, 2023.




    Copies furnished to:

    Presiding District Judge
    Counsel of Record




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