Case 1:03-cr-20117-FAM Document 31 Entered on FLSD Docket 12/19/2005 Page 1 of 4

IN THE UNITED STATES DISTRICT COUR T

FOR THE SOUTHERN DISTRICT OF FLORI D
(Miami Division ) 2 . ,, L-), Y 1 o [., , ,, : C 2
CASE NUMBER 03-20117 CR MOR E
UNITED STATES OF AMERICA,
Plaintiff,
V.
EDWARD M. CHISM,

Defendant .

MOTION OF EDWARD CHISM

FOR LEAVE TO RELOCATE HIS
PERMANENT RESIDENCE TO PANAMA
Edward Chism, by and through his undersigned counsel, hereby moves this
Honorable Court for leave to relocate his permanent residence to Panama and as
grounds therefore states :
1 . Mr. Chism lived most of his adult life in Panama City in the Republic of
Panama .
2 . Mr. Chism worked for nearly 30 years in Panama with the U .S .
Government and held various senior management positions including Chief U .S.
Probation Officer with the U .S . Courts .

1
DAVID M . GARVIN, P.A .
1200 BRICKELL AVENUE, SUITE 1480 MIAMI , FLORIDA 33131 TELEPHONE ( 305) 371-8101

Case 1:03-cr-20117-FAM Document 31 Entered on FLSD Docket 12/19/2005 Page 2 of 4

3 . Mr. Chism's wife, Teresita Chism, was born in Panama .

4. Mr. and Mrs . Chism were married in Panama in 1975 . Their only child
is married and lives in Panama.
5 . Mr. and Mrs . Chism have two grandchildren that live in Panama .
6 . Mr . and Mrs . Chism have no family for support in the United States .
7 . Mr. Chism moved to Miami to start his own business, American
Financial Group . This business no longer exists .
8 . Mr. Chism has no employment prospects in South Florida but has family
and friends in Panama and employment opportunities .
9 . Mr . Chism has no home in the United States . Mr. Chism currently
resides in an extended stay motel .
10 . Mrs. Chism has moved to Panama to be with her 83-year-old mother
who is not well and to be close to her son and grandchildren .
11 . Mr. Chism is presently on supervised release arising from his income tax
offense . He has completed approximately one year of the three years of supervised
release contained in his sentence .
12 . If permitted to relocate to Panama, Mr . Chism will contact his probation
officer as instructed .
13 . This motion has been discussed with Assistant United States Attorne y
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DAVID M . GARVIN, PA .
1200 BRICKELL AVENUE, SUITE 1480 MIAMI, FLORIDA 33131 TELEPHONE (305) 371-8101

Case 1:03-cr-20117-FAM Document 31 Entered on FLSD Docket 12/19/2005 Page 3 of 4

David Buckner and he has stated that the United States has no objection .
14 . Probation Officer Jeffrey Feldman has informed the undersigned that
Mr. Chism has paid his fine in full and is in complete compliance with the
requirements of his supervised release .
15 . The interest of justice would be best served by the granting of this
motion .
WHEREFORE, Edward Chism moves this Honorable Court for leave to
relocate his permanent residence to Panama .
Respectfully submitted ,
DAVID M . GARVIN, P .A.
Counsel for Edward Chism
1200 Brickell Avenue
Suite 148 0
Miami , Flo as 3313 1
Tel: (305 371-810 1
Fax: (30 ) 3 ;71-8,

BY:
DAVID M. GAR
Florida Bar No . 3

3
DAVID M . GARVIN, P.A .
1200 BRICKELL AVENUE, SUITE 1480' MIAMI, FLORIDA 33131 TELEPHONE (305) 371-8101

Case 1:03-cr-20117-FAM Document 31 Entered on FLSD Docket 12/19/2005 Page 4 of 4

CERTIFICATE OF COMPLIANC E
I HEREBY CERTIFY that I spoke with Assistant United States Attorney
David Buckner and he stated that he had no objectiqQto the filing of this motion .

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was
furnished by U .S . Mail this J day of December, 2005, to :
David Buckner, AUSA
99 N.E. 4`h Street
4th Floo r
Miami, Florida 33 1

4
DAVID M. GARVIN, P.A .
1200 BRICKELL AVENUE, SUITE 1480 MIAMI, FLORIDA 33131 TELEPHONE (305) 371-8101