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Unopposed Motion to Travel — United States v. Rosenide Venant (Dkt. 27)

Summary

An Unopposed Motion to Travel filed September 1, 2021 in United States of America v. Rosenide Venant, Case No. 8:21-mj-1295-AAS, in the U.S. District Court for the Middle District of Florida, Tampa Division. The motion states that the defendant is working out a plea agreement to an information, has been on pre-trial release since self-surrender, and traveled to the Fort Lauderdale area after the death of her son on August 24, 2021. It asks the Court to permit the defendant to remain in the Southern District of Florida until as late as September 12, 2021, and to travel there in future with the advance permission of pre-trial services. It states that the United States has no objection, and it bears the /s/ signature of Mark P. Rankin.

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“Unopposed Motion to Travel — United States v. Rosenide Venant (Dkt. 27).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flmd-388524-27-0-39152384a6/, SHA-256 82f90baa74d2599627b8104952e52c701c2a5c847c34328462babf3ac8c7cbf3.

Full text

  Case 8:21-mj-01295-AAS             Document 27       Filed 09/01/21      Page 1 of 2 PageID 80




                             UNITED STATES DISTRICT COURT
                              MIDDLE DISTRICT OF FLORIDA
                                    TAMPA DIVISION


 UNITED STATES OF AMERICA

                        Plaintiff,

 vs.                                                       CASE NO. 8:21-mj-1295-AAS

 ROSENIDE VENANT,

                   Defendant.
 ______________________________________/


                             UNOPPOSED MOTION TO TRAVEL

        COMES NOW the Defendant, Rosenide Venant, and files this Unopposed Motion to

Travel, and states as follows:

        Mrs. Venant is a defendant in this case, which pertains to a non-violent offense (PPP loan

fraud). She has been on pre-trial release since the time of her self-surrender and has followed all

terms of pre-trial release. Mrs. Venant is currently working out a plea agreement to an information

in this matter.

        On August 24, 2021, Mrs. Venant’s 19-year-old son unexpectedly passed away in his

sleep. Mrs. Venant found out about her son’s death on August 25 and immediately traveled to the

Fort Lauderdale area where her son had died while staying with family before starting college.

Mrs. Venant was under intense strain and mourning her son’s death, so she did not give any

thought to the fact that traveling to the Southern District of Florida violated the terms of her pre-

trial release.
  Case 8:21-mj-01295-AAS            Document 27        Filed 09/01/21      Page 2 of 2 PageID 81




       Mrs. Venant has remained in the Southern District of Florida while staying in touch with

pre-trial services. Her son’s funeral is this Friday, September 3. She also wants to stay until as late

as Sunday, September 12, in order to assist in handling family matters.

       For these reasons, Mrs. Venant respectfully requests that the Court grant this motion to

travel, permitting her to remain in the Southern District of Florida until as late as September 12,

2021. She also requests that the Court permit her to travel in the future to the Southern District of

Florida (with the advanced permission of per-trial services) for purposes of dealing with any other

matters related to this family tragedy.

       The United States has no objection to this motion.

                                                       Respectfully submitted,



                                                       /s/ Mark P. Rankin
                                                       Mark P. Rankin
                                                       Florida Bar No. 0177970
                                                       The Law Office of Mark P. Rankin, P.A.
                                                       805 W. Azeele St.
                                                       Tampa, FL 33606
                                                       Telephone No. (727) 365-1751
                                                       Email: mark@rankinlawoffice.com
                                                       Attorney for Rosenide Venant



                                  CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that on this 1st day of September 2021, a true and correct copy of the

foregoing was filed with the Clerk of the Court using the CM/ECF system, which will send a notice

of electronic filing to the AUSA of record and counsel for any co-defendants.



                                                       /s/ Mark P. Rankin
                                                       Mark P. Rankin

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