veldora arthur second motion to travel

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-20753-CR-SEITZ UNITED STATES OF AMERICA, Plaintiff, vs. VELDORA ARTHUR, Defendant. ____________________________/ MOTION FOR PERMISSION TO TRAVEL COMES NOW the Defendant, VELDORA ARTHUR, by and through her undersigned counsel, and hereby moves this Court for permission to travel outside of this jurisdiction and states the following as grounds in support thereof: 1. That the Defendant is currently released on bond. 2. That the Defendant is scheduled for trial on September 12, 2011. 3. That the Defendant is requesting permission to travel to Niagara Falls, Canada and Atlanta Georgia, Florida with her family from August 7, 2011 through August 21, 2011. 4. The United States Department of Probation has been consulted and does not object to the instant motion to allow the defendant to travel. 5. Thus the undersigned hereby request an order for permission for defendant’s travel to Niagara Falls, Canada and Atlanta, Georgia August 7, 2011 through August 21, 2011. WHEREFORE, the Defendant is requesting permission to travel outside the jurisdiction of Miami-Dade County and travel to both Niagara Falls, Canada and Atlanta, Georgia. Case 1:10-cr-20753-PAS Document 140 Entered on FLSD Docket 07/25/2011 Page 1 of 3

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Page 1: Veldora Arthur Second Motion to Travel

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 10-20753-CR-SEITZ

UNITED STATES OF AMERICA,

Plaintiff,

vs.

VELDORA ARTHUR,

Defendant.

____________________________/

MOTION FOR PERMISSION TO TRAVEL

COMES NOW the Defendant, VELDORA ARTHUR, by and through her

undersigned counsel, and hereby moves this Court for permission to travel outside of this

jurisdiction and states the following as grounds in support thereof:

1. That the Defendant is currently released on bond.

2. That the Defendant is scheduled for trial on September 12, 2011.

3. That the Defendant is requesting permission to travel to Niagara Falls, Canada and

Atlanta Georgia, Florida with her family from August 7, 2011 through August 21,

2011.

4. The United States Department of Probation has been consulted and does not

object to the instant motion to allow the defendant to travel.

5. Thus the undersigned hereby request an order for permission for defendant’s

travel to Niagara Falls, Canada and Atlanta, Georgia August 7, 2011 through

August 21, 2011.

WHEREFORE, the Defendant is requesting permission to travel outside the jurisdiction

of Miami-Dade County and travel to both Niagara Falls, Canada and Atlanta, Georgia.

Case 1:10-cr-20753-PAS Document 140 Entered on FLSD Docket 07/25/2011 Page 1 of 3

Page 2: Veldora Arthur Second Motion to Travel

Respectfully submitted,

/Larry R. Handfield, Esq./__

LARRY R. HANDFIELD, ESQ.

FLORIDA BAR NO.: 330590

4770 Biscayne Blvd., Suite 1250

Miami, Florida 33137

(305) 576-1011 / Tel.

I, HEREBY CERTIFY that a true and correct copy of the foregoing was served by

CM/ECF to: Armando Rosquete, AUSA, U.S. Attorney’s Office, 99 N.E. Fourth Street, Miami,

Florida 33132 on this 25th day of July, 2011.

Respectfully submitted,

/Larry R. Handfield, Esq./__

LARRY R. HANDFIELD, ESQ. Florida Bar No. 330590 4770 Biscayne Boulevard Suite 1250 Miami, Florida 33137 (305) 576-1011

Case 1:10-cr-20753-PAS Document 140 Entered on FLSD Docket 07/25/2011 Page 2 of 3

Page 3: Veldora Arthur Second Motion to Travel

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 10-20753-CR-SEITZ

UNITED STATES OF AMERICA,

Plaintiff,

vs.

VELDORA ARTHUR,

Defendant.

____________________________/

ORDER ON MOTION FOR PERMISSION TO TRAVEL

THIS CAUSE having come on to be heard upon Defendant Motion for Permission to

Travel and the Court having heard argument of counsel or being otherwise fully advised in the

premises, it is hereby:

ORDERED AND ADJUDGED that:

1. Defendant’s Motion for Permission to Travel to Niagara Falls, Canada and Atlanta

Georgia from August 7, 2011 through August 21, 2011 is hereby_______________.

DONE AND ORDERED in Open Court in Miami-Dade County, Florida on this

______ day of ___________________, 2011.

__________________________________ PATRICIA A. SEITZ U.S. District Court Judge

cc: Larry R. Handfield, Esq.

Armando Rosquete, Esq., AUSA Federal Department of Probation

Case 1:10-cr-20753-PAS Document 140 Entered on FLSD Docket 07/25/2011 Page 3 of 3