Defendant’s Motion to Enlarge Travel Restrictions — United States v. Wills (Dkt. 23, M.D. Fla.)

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A motion to enlarge travel restrictions filed January 8, 2025 as Document 23 by counsel for defendant Kevin Karl Wills, Jr. in United States v. Wills, Case No. 3:24-cr-166-TJC-LLL, in the U.S. District Court for the Middle District of Florida. It asks the court to let him travel to Rhode Island for an eviction hearing on January 15, 2025. The motion states that Wills is charged by Information with Conspiracy to Defraud the United States, pleaded guilty on November 25, 2024 (accepted December 5, 2024), and is restricted by his bond to the Middle and Southern Districts of Florida, and that he is the landlord of a Providence property in an eviction case for non-payment.

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Case 3:24-cr-00166-TJC-LLL Document 23 Filed 01/08/25 Page 1 of 4 PagelD 66

                 _ UNITED STATES DISTRICT COURT
                   ‘MIDDLE DISTRICT OF FLORIDA
                       JACKSONVILLE DIVISION

UNITED STATES OF AMERICA,

v.                                       CASE NO.: 3:24-cr-166-TJC-LLL

KEVIN KARL WILLS, JR.,

      Defendant.

   DEFENDANT’S MOTION TO ENLARGE TRAVEL RESTRICTIONS

      Defendant, Kevin Karl Wills, Jr., by and through undersigned counsel, hereby

moves this Honorable Court for its Order enlarging Defendant’s travel restrictions

so that he may attend an eviction hearing in Rhode Island on January 15, 2025. In

support thereof, Defendant states:

      1.    Defendant is charged by Information with Conspiracy to Defraud the

United States. (Doc. 1).

      2.    Defendant entered a guilty plea on November 25, 2024 (Doc. 15) and

an Order Setting Conditions of Bond was entered the same day (Doc. 16). A

condition of bond is that Defendant’s travel is restricted to the Middle District and

Southern District of Florida.

      3.    The plea was accepted by the Court on December 5, 2024 (Doc. 21).

      4.    Defendant is a landlord to a property in Providence, Rhode Island and

is required to appear at an eviction hearing for non-payment scheduled for January

Case 3:24-cr-00166-TJC-LLL Document 23 Filed 01/08/25 Page 2 of 4 PagelD 67

15, 2025. Kevin Wills v. Franchesca Rivera, Civil Action File No.: 3CA-2025-0065,
Rhode Island District Court, Noel Judicial Complex. It is Mr. Wills’ intention to use
the proceeds from a sale of this property in order to satisfy his obligations under his
Plea Agreement.
5. Defendant desires to depart from Florida on January 14, 2025, and
return to his residence on January 16, 2025.
6. Defendant proposed the following travel schedule for the Court in the
hope that the Court will approve such travel:
a. Defendant desires to depart from Fort Lauderdale, Florida on
January 14, 2025, and stay at a local hotel in Providence, Rhode
Island.
b. On January 15, 2025, Defendant will attend the eviction hearing
in Rhode Island at the Noel Judicial Complex in Warwick, Rhode
Island.
C. On January 16, 2025, Defendant will return to his residence in

Fort Lauderdale, Florida.

Case 3:24-cr-00166-TJC-LLL Document 23 Filed 01/08/25 Page 3 of 4 PagelD 68

7. Undersigned counsel has conferred with Assistant United States
Attorney Arnold Corsmeier and is authorized to represent that the Government does
not oppose the relief requested herein.

WHEREFORE, Defendant, Kevin Karl Wills, Jr., respectfully requests that
this Honorable Court enter its Order authorizing Defendant to travel to Rhode Island

for the eviction hearing in accordance with the schedule set forth above.

Case 3:24-cr-00166-TJC-LLL Document 23 Filed 01/08/25 Page 4 of 4 PagelD 69

Respectfully submitted,

Ez dct, v wWhe
Elizabeth 1. White, Esquire
Florida Bar No.: 314560
Matthew R. Kachergus, Esquire
Florida Bar No.: 503282
Bryan E. DeMaggio, Esquire
Florida Bar No.: 055712
Camille Sheppard, Esquire
Florida Bar No.: 124518
Hannah B. Dunathan, Esquire
Florida Bar No.: 1058025
Sheppard, White, Kachergus, & DeMaggio, P.A.
215 Washington Street
Jacksonville, Florida 32202
Telephone: (904) 356-9661
Facsimile: (904) 356-9667
Email: sheplaw@sheppardwhite.com
COUNSEL FOR DEFENDANT

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing has been furnished Arnold
B. Corsmeier, Esquire, Assistant United States Attorney,

chip.corsmeier(@usdoj.gov, and Jennifer Michele Harrington, Esquire, Assistant

United States Attorney, Jennifer.harrington2@usdoj.gov, via the CM/ECF system,

ATTORNE

this 8th day of January, 2025.

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