United States' Response in Opposition to Motion for Early Termination — United States v. Bridgitte Keim

Record facts

U.S. District Court, Middle District of Florida · No. 8:21-cr-00370 · Doc. 42 · 2025-01-23 · Docket on CourtListener

Summary

The United States' response in opposition to the defendant's pro se motion for early termination of supervised release in United States v. Bridgitte Keim, Case No. 8:21-cr-370-CHE-JSS, in the U.S. District Court for the Middle District of Florida, filed January 23, 2025 as Document 42. The response states that the defendant pleaded guilty on January 5, 2021 to a one-count Criminal Information charging bank fraud under 18 U.S.C. § 1344, and was sentenced on April 8, 2022 to 24 months' imprisonment followed by a three-year term of supervised release. It gives four reasons for denial: the defendant reports being paid in cash and cannot produce paystubs, and she has paid $2,915.59 in restitution with $118,734.97 outstanding. It also states that she has not filed a new financial statement as her probation officer instructed. The government asks the Court to deny the motion.

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
TAMPA DIVISION 
 
 
UNITED STATES OF AMERICA 
 
v. 
CASE NO. 8:21-cr-370-CHE-JSS 
 
BRIDGITTE KEIM 
 
 
UNITED STATES’ RESPONSE IN OPPOSITION TO DEFENDANT’S   
MOTION FOR EARLY TERMINATION OF PROBATION 
 
 
The United States of America, by and through the undersigned Assistant 
United States Attorney, files this response in opposition to the defendant’s pro se 
motion for early termination of probation (Doc. 40).1  For the reasons stated 
below, the defendant’s motion should be denied.  
On January 5, 2021, the defendant entered a guilty plea to a one count 
Criminal Information charging her with bank fraud, in violation of 18 U.S.C. § 
1344. (Doc. 12).  On April 8, 2022, the defendant was sentenced by this Court 
to a term of 24 months’ imprisonment to be followed by a three-year term of 
supervised release. (Doc. 20).  In July of 2023, the defendant commenced her 
three-year term of supervised release.  On January 15, 2025, the defendant 
filed her instant motion, and the Court directed the United States to respond. 
(Docs. 40 and 41).   
 
1 The Court sentenced to a three-year term of supervised release, not probation. (Doc. 26) 
Case 8:21-cr-00370-CEH-T_W     Document 42     Filed 01/23/25     Page 1 of 5 PageID 174

 
2 
Undersigned counsel has communicated with the defendant’s probation 
officer, Brynn Dawsey, to obtain his position and discuss the statements and 
claims made by the defendant in her motion.  After consultations with 
probation officer Dawsey, the United States opposes the defendant’s motion for 
the following reasons: 
1. 
The defendant’s motion is somewhat misleading. Keim states that 
USPO Dawsey was in favor of her filing for early termination. Officer Dawsey 
did not express any opinion about the defendant filing a motion for early 
termination. Rather, Dawsey presented the defendant with her options; one of 
which was to hire counsel to file a motion on her behalf. 
2. 
In response to questions concerning current employment and 
income, the defendant advised probation that she is currently being paid in cash 
by her employer.  The defendant further advised that she cannot produce 
recent paystubs to validate employment and income. This creates a legitimate 
concern that cash payments create a risk of not reporting income for tax 
purposes. 
3. 
The defendant’s motion asserts that she has paid all of her Court 
fees/fines and that her restitution payments are current. This is true. However, 
the defendant has only paid $2,915.59 in restitution and an outstanding balance 
of $118,734.97 remains. The defendant still owes approximately 95% 
Case 8:21-cr-00370-CEH-T_W     Document 42     Filed 01/23/25     Page 2 of 5 PageID 175

 
3 
restitution to the victims of her crimes and should pay more restitution prior to 
granting an early termination of supervised release.   
4. 
Finally, and most troubling, the defendant was instructed by 
officer Dawsey to file a new financial statement. To date, the defendant has 
failed to follow the instruction of her probation officer. Special Condition 
three requires the defendant to provide the probation officer with access to 
any requested financial information. (Doc. 31 at pg. 6).  
Without a new financial statement neither probation or the United States 
can evaluate the defendant’s financial condition, whether changed 
circumstances would allow for raising the mandated monthly restitution 
payment ordered by the Court, and whether her cash employment income is 
being reported to the Internal Revenue Service as required by law. 
 
 
 
 
 
 
 
Case 8:21-cr-00370-CEH-T_W     Document 42     Filed 01/23/25     Page 3 of 5 PageID 176

 
4 
 
WHEREFORE, the United States respectfully requests that this Court 
deny the defendant’s pro se motion for early termination of her term of 
supervised release. 
Respectfully submitted, 
 
ROGER B. HANDBERG 
United States Attorney 
 
 
By: 
/s/ Christopher Poor                      
Christopher Poor 
Assistant United States Attorney 
United States Attorney No. 152 
400 N. Tampa Street, Suite 3200 
Tampa, Florida 33602-4798 
Telephone: (813) 274-6000 
Facsimile: 
(813) 274-6358 
E-mail: Christopher.poor@usdoj.gov 
 
 
 
 
 
 
 
 
 
 
Case 8:21-cr-00370-CEH-T_W     Document 42     Filed 01/23/25     Page 4 of 5 PageID 177

 
 
5 
U.S. v. BRIDGITTE KEIM 
Case No. 8:21-cr-370-CEH-JSS 
 
 
 
CERTIFICATE OF SERVICE 
 
 
I hereby certify that on January 23, 2025, a true and correct copy of the 
foregoing document and the notice of electronic filing were sent by United 
States Mail to the following non-CM/ECF participant(s): 
 
 
 
 
 
Bridgitte Keim 
 
 
 
 
 
105 Glen Ridge Avenue 
 
 
 
 
 
Temple Terrace, FL 33617 
 
 
/s/ Christopher Poor                       
Christopher Poor 
Assistant United States Attorney 
United States Attorney No. 152 
400 N. Tampa Street, Suite 3200 
Tampa, Florida 33602-4798 
Telephone: (813) 274-6000 
Facsimile: 
(813) 274-6358 
E-mail: Christopher.poor@usdoj.gov 
 
 
Case 8:21-cr-00370-CEH-T_W     Document 42     Filed 01/23/25     Page 5 of 5 PageID 178

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