Defendant Emmet Bowens' Unopposed Motion to Travel Outside the Middle District of Florida to Attend a Family Funeral — United States v. Emmet Bowens (Dkt. 93)
Summary
Document 93, filed February 21, 2023 in Case 6:21-cr-00141-RBD-EJK in the U.S. District Court for the Middle District of Florida, Orlando Division, is Emmet Bowens's unopposed motion for approval to travel outside the Middle District of Florida to attend his aunt's funeral in Mississippi. He asks to leave on Thursday, February 23, 2023 and return on Monday, February 27, 2023. The motion says his release conditions require pre-approval before leaving the District and that he has complied fully since his arrest. It states that the Pretrial Services Officer said a motion to the Court was needed because he is on location monitoring. Counsel says Assistant United States Attorney Chauncey Bratt does not oppose the request.
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“Defendant Emmet Bowens' Unopposed Motion to Travel Outside the Middle District of Florida to Attend a Family Funeral — United States v. Emmet Bowens (Dkt. 93).”
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Case 6:21-cr-00141-RBD-NWH Document 93 Filed 02/21/23 Page 1 of 5 PageID 275
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’ UNOPPOSED MOTION SEEKING
APPROVAL FROM THE COURT TO TRAVEL OUTSIDE THE MIDDLE
DISTRICT OF FLORIDA TO ATTEND A FAMILY FUNERAL
The Defendant, Emmet Bowens (“Mr. Bowens”), by and through the
undersigned counsel, hereby moves for an Order from this Honorable Court
granting him permission to travel to Mississippi to attend his aunt’s funeral. Mr.
Bowens respectfully requests to be outside the Middle District of Florida to attend
this family funeral, starting on Thursday, February 23, 2023, with a return date of
Monday, February 27, 2023. 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
Case 6:21-cr-00141-RBD-NWH Document 93 Filed 02/21/23 Page 2 of 5 PageID 276
money laundering, in violation of 18 U.S.C. § 1957 (Counts Three through Six).
Doc. 1.
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 U.S. Pretrial
Services, that he participate in location monitoring, and that he remain within the
jurisdiction of the Northern District of Georgia and the Middle District of Florida
“unless pre-approval from . . . Pretrial Services is received.” Id. at 4, 7.
4. On December 16, 2021, Mr. Bowens appeared in the Middle District
of Florida, where this Court held an in-district initial appearance. Doc. 10. Mr.
Bowens’ conditions of release remain as they were originally set by the court in
the Northern District of Georgia. See Docs. 10, 14, 15, 40, 43, 54.
5. Mr. Bowens has fully complied with all conditions of release since his
arrest.
2
Case 6:21-cr-00141-RBD-NWH Document 93 Filed 02/21/23 Page 3 of 5 PageID 277
6. On February 20, 2023, Mr. Bowens informed the undersigned that he
would like to attend his aunt’s funeral in Mississippi. Mr. Bowens plans to travel
to Mississippi on Thursday, February 23, 2023, where he will stay at the
TownePlace Suites, located at 7840 Craft-Goodman Frontage Road, Olive Branch
Mississippi 38654. Mr. Bowens will return to the Middle District of Florida on
Monday, February 27, 2023.
7. As noted above, Mr. Bowens’ pretrial release conditions require him
to seek pre-approval from the U.S. Pretrial Services Office before leaving the
Middle District of Florida.
8. On February 20, 2023, the undersigned emailed Mr. Bowens’ U.S.
Pretrial Services Officer and requested permission for Mr. Bowens to travel out-
of-district to attend the family funeral, as described above.
9. On February 21, 2023, the U.S. Pretrial Services Officer informed the
undersigned that, because Mr. Bowens was on location monitoring, a motion had
to be filed with the Court seeking approval of the requested out-of-district travel.
10. On February 21, 2023, the undersigned conferred with Assistant
United States Attorney Chauncey Bratt who informed the undersigned that the
government does not oppose the relief requested herein.
3
Case 6:21-cr-00141-RBD-NWH Document 93 Filed 02/21/23 Page 4 of 5 PageID 278
WHEREFORE, the Defendant, Emmet Bowens, moves this Honorable Court
for an Order granting him permission/authorization to travel from the Middle
District of Florida to Mississippi (and through those locations directly in between
on the route of travel), starting on Thursday, February 23, 2023, with a return date
of Monday, February 27, 2023.
Respectfully submitted on this 21st day of February, 2023.
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: 407-952-0642
Email: andrew@searle-law.com
Attorney for Defendant
4
Case 6:21-cr-00141-RBD-NWH Document 93 Filed 02/21/23 Page 5 of 5 PageID 279
CERTIFICATE OF SERVICE
I HEREBY CERTIFY on February 21, 2023, 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: 407-952-0642
Email: andrew@searle-law.com
Attorney for Defendant
5
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