Motion for Leave to Amend United States' Witness List — United States v. Emmet Bowens (Document 219)

Summary

A Motion for Leave to Amend United States' Witness List filed January 22, 2026 in United States v. Emmet Bowens, Case No. 6:21-cr-141-RBD-NWH, in the U.S. District Court for the Middle District of Florida, Orlando Division (Document 219). The United States states that it filed its witness list on January 16, 2026 (Doc. 217) and that Wells Fargo has provided records custodian Oscar Rodriguez to testify. It also asks to substitute Barclays Bank employee Phillip Gordon for Mike Coverdale as a records custodian who can authenticate Government Exhibit 10a. The motion states that the defendant declined to meet with stand by counsel, so the United States cannot represent the defendant's position; the signature block names Special Assistant United States Attorney Rachel S. Lyons.

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Case 6:21-cr-00141-RBD-NWH        Document 219       Filed 01/22/26   Page 1 of 3 PageID 686




                         UNITED STATES DISTRICT COURT
                          MIDDLE DISTRICT OF FLORIDA
                              ORLANDO DIVISION

  UNITED STATES OF AMERICA

  v.                                             CASE NO. 6:21-cr-141-RBD-NWH

  EMMET BOWENS

       MOTION FOR LEAVE TO AMEND UNITED STATES’ WITNESS LIST

         The United States respectfully moves for leave of Court to file an amended

  witness list. The United States filed its witness list on January 16, 2026 (Doc. 217), in

  accordance with the Court’s Pretrial Order (Doc. 211). At the time, the United States

  listed custodians of records for several businesses and agencies, but did not yet know

  the name of the specific record custodian that Wells Fargo Bank would provide to

  testify (Doc. 211 at # 15). Today, Wells Fargo provided a records custodian, Oscar

  Rodriguez who will testify on behalf of Wells Fargo Bank. The United States

  respectfully requests leave to file an amended witness list with that name.

         The United States also seeks to substitute Barclays Bank employee Phillip

  Gordon as a substitute records custodian witness for Mike Coverdale (Doc. 211 at

  #8). Mr. Gordon is a custodian of record who is more readily available than Mr.

  Coverdale and can authenticate the same bank records (Government Exhibit 10a)

  that Mr. Coverdale would authenticate.

         For the above reasons, the United States respectfully requests that the Court

  grant leave to file an amended witness list.
Case 6:21-cr-00141-RBD-NWH      Document 219    Filed 01/22/26    Page 2 of 3 PageID 687




        The undersigned attempted to contact Defendant about this motion through

  stand by counsel, however, defendant declined to meet with stand by counsel.

  Therefore, the undersigned cannot represent Defendant’s position on the United

  States’ request.

                                        Respectfully submitted,

                                        GREGORY W. KEHOE
                                        United States Attorney

                                  By:   /s/ Rachel S. Lyons__________________
                                        Rachel S. Lyons
                                        Special Assistant United States Attorney
                                        USAO No. 215
                                        400 W. Washington Street, Suite 3100
                                        Orlando, Florida 32801
                                        Telephone: (407) 648-7500
                                        Facsimile: (407) 648-7643
                                        E-mail: Rachel.Lyons@usdoj.gov




                                           2
Case 6:21-cr-00141-RBD-NWH         Document 219     Filed 01/22/26    Page 3 of 3 PageID 688




  U.S. v. Bowens                                  Case No. 6:21-cr-141-RBD-NWH

                              CERTIFICATE OF SERVICE

         I hereby certify that on January 22, 2026, a true and correct copy of the

  foregoing document and the notice of electronic filing were sent to the defendant by

  email and that copies will also be sent by United States Mail to the following non-

  CM/ECF participant(s):

         Emmet Bowens
         Defendant


         I further certify that on January 22, 2026, 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:

         Michael Nielsen, Esq., Standby Counsel for Emmet Bowens



                                           /s/ Rachel S. Lyons__________________
                                           Rachel S. Lyons
                                           Special Assistant United States Attorney
                                           USAO No. 215
                                           400 W. Washington Street, Suite 3100
                                           Orlando, Florida 32801
                                           Telephone: (407) 648-7500
                                           Facsimile: (407) 648-7643
                                           E-mail: Rachel.Lyons@usdoj.gov


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