Unopposed Motion to Set a Different Jury Selection Date — United States v. Bowens (Middle District of Florida)

Summary

An Unopposed Motion to Set a Different Jury Selection Date Other Than December 5, 2025 and Notice of Schedule Conflict, filed November 26, 2025 by the defendant in United States of America v. Bowens, CASE NO.: 6:21-cr-141-RBD-NWH, in the U.S. District Court for the Middle District of Florida, Orlando Division. It states that a November 25, 2025 order set jury selection for December 5, 2025 with the rest of trial starting December 10, 2025, and that defense counsel has a schedule conflict because of airline tickets to travel to the state of Ohio for an "early family Christmas celebration". It asks that jury selection be moved to another date in December 2025. The motion states that the United States Attorney's Office has no objection, and Michael W. Nielsen signs with /s/.

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Full text

Case 6:21-cr-00141-RBD-NWH             Document 188         Filed 11/26/25       Page 1 of 3 PageID 493




                                UNITED STATES DISTRICT COURT
                                 MIDDLE DISTRICT OF FLORIDA
                                     ORLANDO DIVISION

  UNITED STATES OF AMERICA                                CASE NO.: 6:21-cr-141-RBD-NWH


  V.

  EMETT BOWENS,
  ___________________________________/

       UNOPPOSED MOTION TO SET A DIFFERENT JURY SELECTION DATE OTHER

             THAN DECEMBER 5, 2025 AND NOTICE OF SCHEDULE CONFLICT

       Comes now, the defendant, EMETT BOWENS, by and through undersigned counsel, hereby

  moves this Honorable Court to enter an order resetting the jury selection date and alleges:

   1.       That on November 25, 2025, this Honorable Court entered an order setting this case for

            jury selection on December 5, 2025, with the rest of the trial starting on December 10,

            2025. This order is based upon the defendant not signing a waiver of speedy trial through

            January 31, 2026.

   2.       That the defense counsel has a schedule conflict with December 5, 2025 as follows.

            Undersigned counsel has bought and paid for five airline tickets to travel to the state of

            Ohio for an “early family Christmas celebration”. That said, airline tickets were reserved

            and purchased on September 8, 2025. The flight departs from Orlando at 8:45A.M. That

            undersigned counsel would sincerely appreciate it if the jury selection date can be moved

            to another date in December 2025.

   3.       That it would be a huge personal hardship if undersigned counsel has to cancel his trip to

            Ohio in order to pick a jury on December 5, 2025, and would effect not just counsel but
Case 6:21-cr-00141-RBD-NWH            Document 188          Filed 11/26/25    Page 2 of 3 PageID 494




          also his extended family as well.

   4.     That the United States Attorney’s Office has been contacted and has no objection to this

          motion to reset the jury selection date. That is also consistent with the United States

          position to continue the trial until January 2026 trial term.



                                         MEMORANDUM OF LAW

                The Honorable Court has the authority to set trial dates in criminal cases. The

        Honorable Court also has the authority to reset trial dates for good cause. The fact that

        defense counsel has a long-preplanned airline trip to another state on December 5, 2025 is

        good cause to reset the jury selection date. That the defense is not requesting to continue the

        trial all together but to just change the jury selection date.



                WHEREFORE, the defense counsel hereby moves this Honorable Court to enter an

        order as requested above.
Case 6:21-cr-00141-RBD-NWH              Document 188         Filed 11/26/25         Page 3 of 3 PageID 495




                                     CERTIFICATE OF SERVICE

          I HEREBY CERTIFY that on November 26, 2025, 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 the following: United States Attorney, further certify that I mailed the foregoing document

  and the notice of electronic filing by first-class mail to the following: none.



                                                           Respectfully submitted,

                                                           SMITH & EULO LAW FIRM

                                                           By: /s/ Michael W. Nielsen
                                                           Michael W. Nielsen, Esq.
                                                           Florida Bar No. 794392
                                                           Smith & Eulo Law Firm
                                                           720 W State Road 434
                                                           Winter Springs, FL 32708
                                                           mnielsen@smithandeulo.com
                                                           sroofe@smithandeulo.com
                                                           sfetterman@smithandeulo.com
                                                           (407) 327-5865
                                                           Attorney For Defendant


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