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Home Source documents Defendant Eric Ahiekpor’s Motion for Reconsideration to Travel — United States v. Eric Ahiekpor, No. 2:20-cr-94(3) (Dkt. 196, S.D. Ohio)

Defendant Eric Ahiekpor’s Motion for Reconsideration to Travel — United States v. Eric Ahiekpor, No. 2:20-cr-94(3) (Dkt. 196, S.D. Ohio)

Summary

In this motion filed April 14, 2022 in United States v. Ahiekpor (S.D. Ohio, Case No. 2:20-cr-94(3), Judge Sarah D. Morrison), defense counsel Byron L. Potts asks the court to reconsider and allow Eric Ahiekpor to travel to Miami, FL in April 2022 to accompany the defendant's wife, Akenya McCaleb, for a surgical procedure. An attached letter from McCaleb states that the surgery is April 21, that the doctor requires an adult companion 21 years or older for pre and post op, and that walking or anything physical will not be possible for 5 days. Eric Ahiekpor's own letter to the judge says the surgery is cosmetic and not deemed essential, that the payment is not refundable, and lists earlier trips to St. Louis, DC, NY, New Jersey and Miami without incident. A 2010 nurse aide training certificate is also attached.

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Full text

                                               IN THE UNITED STATES DISTRICT COURT
                                                FOR THE SOUTHERN DISTRICT OF OHIO
                                                         EASTERN DIVISION


                                 United States of America,
                                        Plaintiff,                          Case No. 2:20-cr-94(3)

                                 vs.                                        Judge Sarah D. Morrison


                                 Eric Ahiekpor,
                                        Defendant.




                               DEFENDANT ERIC AHIEKPOR'S MOTION FOR RECONSIDERATION
                                                                TO TRAVEL


                                 Now comes Defendant Eric Ahiekpor, by and through counsel and moves this Court
                          for reconsideration and an order to allow him to travel to Miami,FL on April 18,2022,and
                          return on April 27,2022,to accompany his wife for a surgical procedure. (See Attached
                          Exhibit A,B,and C)
                                                                     Respectftilly submitted,

                                                                    /s/ Bvron L.Potts
                                                                    Byron L. Potts(0040246)
                                                                    Attorney for Defendant
                                                                    761 South High Street
                                                                    Columbus, Ohio 43206
                                                                    614/228-2154
                                                                     byronpotts(§msn.com




BYRON L.POTTS & CO.,LPA
   ATTORNEYS AT LAW
  761 S.HIGH STREET
COLUMBUS.OHIO 43206
     (614)228-2154
    www.blpott8.com
  byrcnpotts@ro8n.com
                                                         CERTIFICATE OF SERVICE


                                 I hereby certify that on April 14,2022,a copy ofthe foregoing was filed
                          electronically. Notice ofthis filing will be sent to Plaintiff by operation ofthe Courtis
                          electronic filing system. Parties may access this filing through the Court's system.
                                 A copy ofthe foregoing was also sent via email to the following this 14th day of
                          April 2022:
                          Melinda Vincent
                          U.S. Probation Officer
                          melinda_vmcent(§ohsp.uscoiuts.gov

                          Peter Glenn-Applegate
                          Assistant United States Attorney
                          peter.glenn-applegate(gusdoj.gov


                                                                       /s/Bvron L.Potts
                                                                       Byron L. Potts(0040246)
                                                                       Attomey for Defendant




JYRON L.POTTS & CO.,LPA
  ATTORNEYS AT LAW
  761 S. HIGH STREET
COLUMBUS,OHIO 43206
    (614)228-2154
   www.blpotts.com
  byionpott^msn.com
The surgery is April 21 and per the doctor rules I must be accompanied by someone 21 years or older. In
my documents I let the doctor know itiy husband Eric will be accompanying me during pre and post op. I
would not be able to walk or do anything physical for 5 days. I have no one else that can be there for me
during that time. I am going under anesthesia and need my husband who Is also certified as a care
provider through his home health business to be there In case anything wrong were to go wrong

I have tried finding someone else to accompany to no success. I respectfully request the court to
reconsider his request to travel with me. He is not only my husband but also my support system In
everything I do. I can be reached at the number below should you have any questions. Thank you.

.Siricerely,



Akenya McCaleb
6142608194




                                                                                         EXHIBIT

                                                                                           A
Dear Judge Sarah Morrison,


I have attached this letter and a letter from my wife Akenya McCaleb respectfully requesting
reconsideration on my request to accompany my wife to Miami for her surgery. I understand this a
cosmetic surgery and therefore It is not deemed as essential. However, her payment is not refundable.
And she has also done her required primary physician visits and blood work.

Per the doctors' instructions my wife needs someone to accompany her to her pre and post operation.
She is not able to do anything while recovering and needs help activities of daily living.
My wife doesn't have anyone to help her besides me. None of family members can request time off
work to accompany her.
Your Honor, as you well know, I have traveled to St. Louis, DC, NY, New Jersey and Miami and back
without any incident. This Will be rhuch like the same. If there are additional information that need to be
presented, kindly let me know.Thank you for your time.

Respectfully,


Eric Ahiekpor.




                                                                                               EXHIBIT
                                                            i



          Certificate ofSuccessful Completion
                                     This is to verify that



                              ERIC AHIEKPOR
                           successfully completed an approved
                Nurse Aide Training and Competency Evaluation Program



                    On this 16th Dav of August. 2010

                                       presented by

                    PREMIER CHOICE HEALTH SERVICES
                                         3651880


In accordance with rule 370I'18'24 Ohio Administrative Code, presentation ofthis Certificate
     is required in orderfor the individual to participate in the written examination and
   peiformonce demonstration components ofthe Competency Evaluation Program (CEP)
   conducted by the Director ofHealth. Both components ofthe CEP must be successfully
            completed within fwentv-four months from the date on this certificate.


                                 Signature ofProgram Coordinator

                                    Validation Code: August 16.2010 22:25              EXHIBIT


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