Defendant Emmet Bowens' Motion for Approval of Change of Address and Permission to Stay in a Hotel — United States v. Emmet Bowens (Dkt. 63)
Summary
Document 63, filed June 7, 2022 in Case 6:21-cr-00141-RBD-NWH in the U.S. District Court for the Middle District of Florida, Orlando Division, is Emmet Bowens's motion for approval of a change of address and permission to stay in a hotel while between addresses. The motion recounts that he was arrested on December 2, 2021 in Atlanta, Georgia, and that his release conditions include Pretrial Services supervision, GPS monitoring and prior approval for any address change. It notes that the Court denied his requests to remove GPS monitoring (Docs. 15 and 54). Counsel says Mr. Bowens and his family are selling their home and moving to an apartment complex, and asks for permission to stay in a local hotel from June 8, 2022 through July 13, 2022. It states that neither the government nor Pretrial Services opposes the request.
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“Defendant Emmet Bowens' Motion for Approval of Change of Address and Permission to Stay in a Hotel — United States v. Emmet Bowens (Dkt. 63).”
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Case 6:21-cr-00141-RBD-NWH Document 63 Filed 06/07/22 Page 1 of 6 PageID 195
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Case No. 6:21−cr−00141−RBD−EJK
)
EMMET BOWENS, )
)
Defendant. )
)
DEFENDANT EMMET BOWENS’ MOTION SEEKING
APPROVAL OF HIS CHANGE OF ADDRESS AND PERMISSION TO
STAY IN A HOTEL WHILE HE IS TEMPORARILY BETWEEN ADDRESSES
The Defendant, Emmet Bowens (“Mr. Bowens”), by and through the
undersigned counsel, hereby moves for an Order from this Honorable Court
approving his change of address, and granting him permission to stay in a local
hotel while he is temporarily between addresses. In support thereof, Mr. Bowens
states as follows:
1. On November 10, 2021, a federal grand jury in the Middle District of
Florida returned an indictment charging Mr. Bowens with two counts of wire
fraud, in violation of 18 U.S.C. § 1343 (Counts One and Two), and four counts of
money laundering, in violation of 18 U.S.C. § 1957 (Counts Three through Six).
Doc. 1.
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Case 6:21-cr-00141-RBD-NWH Document 63 Filed 06/07/22 Page 2 of 6 PageID 196
2. On December 2, 2021, in Atlanta, Georgia, Mr. Bowens was detained
and eventually arrested in connection with a warrant issued in this case. Docs. 7,
9.
3. On the same date of his arrest, December 2, 2021, Mr. Bowens had a
Rule 5(c)(3) initial appearance before a U.S. Magistrate Judge in the Northern
District of Georgia. Doc. 7. At this hearing, the Magistrate Judge set conditions
of release for Mr. Bowens, including, inter alia, the requirement that he appear in
all proceedings in this case as directed, that he be supervised by Pretrial Services,
that he participate in GPS location monitoring, and that he immediately advise the
Court, defense counsel, and the U.S. Attorney in writing before any change in
address. Id. at 4, 7. The conditions of release also required Mr. Bowens to reside
at the address provided to pretrial services and required him not to change his
address without prior approval from the Court. Id. at 7.
4. On December 16, 2021, Mr. Bowens appeared in the Middle District
of Florida, where this Court held an in-district initial appearance in Mr. Bowens’
case. Doc. 10. At this hearing, Mr. Bowens made an ore tenus motion to modify
his conditions of release, specifically, to remove the condition of GPS monitoring.
Docs. 10, 14. The Court denied Mr. Bowens’ ore tenus motion to modify the
conditions of his release. Doc. 15.
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Case 6:21-cr-00141-RBD-NWH Document 63 Filed 06/07/22 Page 3 of 6 PageID 197
5. On April 21, 2022, Mr. Bowens filed a renewed motion to modify his
conditions of release, specifically to remove the condition of GPS monitoring.
Doc. 40.
6. On May 16, 2022, this Court denied Mr. Bowens’ renewed motion to
modify his conditions of release. Doc. 54.
7. Thus, Mr. Bowens’ conditions of release remain as they were
originally set by the court following his arrest on December 2, 2021.
8. Since his initial appearance before this Court on December 16, 2021,
Mr. Bowens has been living at his residence in Apopka, Florida. Mr. Bowens and
his family are selling their home in Apopka and relocating to an apartment
complex located at 6265 West Sand Lake Road, Orlando, Florida 32819. However,
while he and his family are between addresses, they will be staying at the Hyatt
Regency Orlando, located at 9801 International Drive, Orlando, Florida 32819,
starting on June 8, 2022 and continuing through July 13, 2022. 1
9. Consistent with his current conditions of release, Mr. Bowens,
through the undersigned, has hereby notified the parties and the Court, in writing,
of Mr. Bowens’ upcoming change of address.
1 The undersigned filed this motion immediately upon learning on June 8, 2022, that Mr.
Bowens’ address would be changing, and that Mr. Bowens would need to stay
temporarily at a hotel.
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Case 6:21-cr-00141-RBD-NWH Document 63 Filed 06/07/22 Page 4 of 6 PageID 198
10. Further, Mr. Bowens seeks approval from this Court to change his
address to the aforementioned apartment complex. Lastly, Mr. Bowens requests
permission to stay at the aforementioned local hotel while he is temporarily
between addresses.
11. On June 8, 2022, the undersigned conferred with Assistant United
States Attorney Amanda Daniels and Pretrial Services Officer Charles Sweatt
about the instant motion. The undersigned has been informed that neither the
government, nor Pretrial Services opposes the relief sought herein.
BOWENS| MOTION FOR APPROVAL OF CHANGE OF ADDRESS | PAGE 4 O F 6
Case 6:21-cr-00141-RBD-NWH Document 63 Filed 06/07/22 Page 5 of 6 PageID 199
WHEREFORE, the Defendant, Emmet Bowens, moves this Honorable Court
for an Order granting him approval to change his address to an apartment
complex located at 6265 West Sand Lake Road, Orlando, Florida 32819, and
granting him permission to stay at the Hyatt Regency Orlando, located at 9801
International Drive, Orlando, Florida 32819, starting on June 8, 2022 and
continuing through July 13, 2022, while he is temporarily between addresses.
Respectfully submitted on this 7th day of June, 2022.
s/Andrew C. Searle
ANDREW C. SEARLE, ESQ.
Florida Bar No. 0116461
SEARLE LAW P.A.
200 East Robinson Street, Suite 1150
Orlando, Florida 32801
Telephone: 407-203-3715
Email: andrew@searle-law.com
Attorney for Defendant
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Case 6:21-cr-00141-RBD-NWH Document 63 Filed 06/07/22 Page 6 of 6 PageID 200
CERTIFICATE OF SERVICE
I HEREBY CERTIFY on June 7, 2022, I filed a copy of the foregoing with the Clerk
of the Court via the CM/ECF system. I further certify that all parties to this case are
equipped to receive service of documents via that system.
s/Andrew C. Searle
ANDREW C. SEARLE, ESQ.
Florida Bar No. 0116461
SEARLE LAW P.A.
200 East Robinson Street, Suite 1150
Orlando, Florida 32801
Telephone: 407-203-3715
Email: andrew@searle-law.com
Attorney for Defendant
BOWENS| MOTION FOR APPROVAL OF CHANGE OF ADDRESS | PAGE 6 O F 6
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