Unopposed Motion to Travel — United States v. Edward Moise (Document 6)

Summary

An Unopposed Motion to Travel entered on the docket November 3, 2021 as Document 6 in United States of America v. Edward Moise, Case No. 0:21-cr-60293-WPD, in the U.S. District Court for the Southern District of Florida. The Defendant states that on October 28, 2021 a PSB in the amount of $100,000.00 was posted, and that a condition of the bond requires permission from the Court to travel outside the Southern District of Florida. The motion asks to travel to New Jersey for the Thanksgiving holiday from November 20, 2021 to November 27, 2021. It states that AUSA Stephanie Hauser has advised that she has no objection.

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Case 0:21-cr-60293-WPD Document 6 Entered on FLSD Docket 11/03/2021 Page 1 of 2



                                 UNITED STATES DISTRICT COURT
                                 SOUTHERN DISTRICT OF FLORIDA

                                      Case No. 21CR60293-WPD-1

 UNITED STATES OF AMERICA,

          Plaintiffs,
 vs.

 EDWARD MOISE,

       Defendant.
 ____________________________/

                                UNOPPOSED MOTION TO TRAVEL


          COMES NOW the Defendant, EDWARD MOISE, by and through undersigned counsel and

 files this Unopposed Motion to Travel.

          As grounds for this motion, the Defendant would show the following:

       1. On October 28, 2021, the Defendant posted a PSB in the amount of $100,000.00.

       2. A condition of the Defendant’s bond is that should he wish to travel outside of the Southern

          District of Florida, he must get permission from this Court.

       3. The Defendant wishes to travel for the Thanksgiving holiday to New Jersey from November

          20, 2021, to November 27, 2021.

       4. While in New Jersey the Defendant would be staying at the following address:

                  94 Woodstone Rd
                  Rockaway, NJ 07866

       5. That undersigned counsel contacted AUSA Stephanie Hauser, who has advised that she has

          no objection to the Defendant traveling.
Case 0:21-cr-60293-WPD Document 6 Entered on FLSD Docket 11/03/2021 Page 2 of 2




        WHEREFORE, the Defendant respectfully requests this Honorable Court to grant this motion

 and enter an order allowing the Defendant to travel to New Jersey from November 20, 2021, through

 November 27, 2021.


                                                        /s/ Michael A. Gottlieb
                                                       Michael A. Gottlieb
                                                       Counsel for the Defendant
                                                       1311 SE 2nd Avenue
                                                       Ft. Lauderdale, Florida 33316
                                                       954.462.1005
                                                       mike@mgottlieblaw.com
                                                       Florida Bar No.: 981133




                                   CERTIFICATE OF SERVICE

        I hereby certify that on this 3rd day of November, 2021, this pleading has been electronically

 filed with the Clerk of the Court and all parties of record via CMECF.



                                                       /s/Michael A. Gottlieb
                                                       Michael A. Gottlieb, Esquire


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