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Defendant's Unopposed Motion to Amend One Bond Condition — United States v. Julio Enrique Lugo (Dkt. 14)

Summary

In Document 14, filed April 7, 2021 in Case No.: 8:21-mj-01294-AAS-1, Julio Enrique Lugo asks the Middle District of Florida, Tampa Division, to change a single bond condition, without opposition. The motion recounts a Complaint of March 26, 2021 citing 18 U.S.C. § 371 and § 1957, an April 1, 2021 arrest, and a $100,000.00 personal surety bond that bars leaving the Middle District of Florida without permission. It states that recently retained counsel has a primary office in Miami, Florida, and that a prior Southern District of Florida matter requires travel to Fort Lauderdale. It requests permission to travel within the Southern and Middle Districts of Florida while the case is pending.

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“Defendant's Unopposed Motion to Amend One Bond Condition — United States v. Julio Enrique Lugo (Dkt. 14).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flmd-388522-14-0-aee40f9440/, SHA-256 8bac76fd62b114a4b15a82ca5faf29abf5888945ca1b6129c4bb266bbafb9770.

Full text

 Case 8:21-mj-01294-AAS    Document 14     Filed 04/07/21   Page 1 of 3 PageID 55




                    UNITED STATES DISTRICT COURT
                     MIDDLE DISTRICT OF FLORIDA
                           TAMPA DIVISION

UNITED STATES OF AMERICA,

       Plaintiff,                          Case No.: 8:21-mj-01294-AAS-1

vs.

JULIO ENRIQUE LUGO,

       Defendant.
________________________________/

               DEFENDANT’S UNOPPOSED MOTION TO
                 AMEND ONE (1) BOND CONDITION

      Defendant, JULIO ENRIQUE LUGO (“Mr. Lugo”), by and through

undersigned counsel, hereby files this Unopposed Motion to Amend One (1) Bond

Condition, and, as grounds therefore, states as follows:

      1.    On March 26, 2021, Mr. Lugo was charged by Complaint with

conspiracy to defraud the Small Business Administration in violation of 18

U.S.C. § 371 and illegal monetary transactions in violation of 18 U.S.C. § 1957.

(D.E. 1).

      2.    On April 1, 2021, Mr. Lugo was arrested in relation to this matter.

      3.    That same day (April 1, 2021), Judge Wilson granted Mr. Lugo a

personal surety bond in the amount of $100,000.00, (D.E. 8), a condition of which

was that Mr. Lugo “must not, at any time, for any reason whatsoever, leave the
 Case 8:21-mj-01294-AAS     Document 14     Filed 04/07/21   Page 2 of 3 PageID 56




Middle District of Florida without first obtaining the permission of the court,”

(D.E. 10).

      4.     Mr. Lugo recently retained undersigned counsel, whose primary

office is located in Miami, Florida.

      5.     Additionally, Mr. Lugo has a prior matter in the Southern District

of Florida (Case No. 14-cr-60105-JIC), which will require him to travel to Fort

Lauderdale, Florida.

      6.     As such, Mr. Lugo respectfully requests that his bond conditions be

modified, so that he may travel within the Southern and Middle Districts of

Florida during the pendency of this case.

      7.     Undersigned Counsel has conferred with Assistant United States

Attorney Kristen Fiore, who advised the Government has no objection to the

relief requested herein.




                                       2
 Case 8:21-mj-01294-AAS      Document 14      Filed 04/07/21   Page 3 of 3 PageID 57




      WHEREFORE, Defendant, JULIO ENRIQUE LUGO, respectfully

requests this Honorable Court grant this Unopposed Motion to Amend One (1)

Bond Condition, and grant such other relief as is just and proper.


                                              Respectfully submitted,

                                              GRAYROBINSON, P.A.
                                              Attorneys for Defendant
                                              333 S.E. 2nd Avenue, Suite 3200
                                              Miami, Florida 33131
                                              Telephone: (305) 416-6880
                                              Facsimile: (305) 416-6887
                                              brian.bieber@gray-robinson.com

                                              By: s/Brian H. Bieber
                                              BRIAN H. BIEBER
                                              Florida Bar #8140




                         CERTIFICATE OF SERVICE

      I HEREBY CERTIFY that on April 7, 2021, I electronically filed the

foregoing with the Clerk of the Court by using the CM/ECF system, which will

send a notice of electronic filing to all counsel of record.

                                              s/Brian H. Bieber
                                              BRIAN H. BIEBER




                                          3

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