Case 2:16-cr-00132-JFC Document 49 Filed 02/24/17 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA )

) Case No.: 2:15-cr-00212-JFC
)
v. ) Case No.: 2:16-cr-00132-JFC
)
ABIGALE LEE MILLER )

MOTION FOR PERMISSION TO TRAVEL INTERNATIONALLY

Defendant, Abigale Lee Miller (Ms. Miller), by and through counsel, files this Motion

for Permission to Travel Internationally, stating as follows:

1. On June 27, 2016, Ms. Miller pleaded guilty to one (1) count of concealment of

assets in a bankruptcy proceeding in violation of 18 U.S.C. 152(1), and to one (1) count of

failing to file a report under 31 U.S.C. 5316 in violation of 31 U.S.C. 5324(c)(1).

2. Subsequent to pleading guilty, the Court released Ms. Miller on an unsecured

appearance bond while awaiting sentencing.

3. The conditions of the bond require Ms. Miller to seek and obtain Court approval

for any international travel.

4. The first portion of Ms. Millers sentencing hearing occurred on January 20,

2017, at which Ms. Miller was present.

5. The second portion of Ms. Millers sentencing hearing was scheduled to occur on

February 24, 2017.

6. However, on February 22, 2017, the Government filed a motion to continue the

second portion of the sentencing hearing.

7. Ms. Miller consented to the Governments motion to continue, and the Court

granted the Governments motion.

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8. The second portion of the sentencing hearing has not yet been rescheduled.

9. At the time the Governments motion to continue the sentencing hearing was filed

on February 22, 2017, Ms. Miller was in transit from London, England to Pittsburgh,

Pennsylvania in order to attend the sentencing hearing.

10. The Court previously granted Ms. Miller permission to travel to London, England.

11. In so doing, the Court required Ms. Miller to file all future motions to travel more

than two weeks prior to the date of travel.

12. Today, February 24, 2017, Ms. Miller was presented with business opportunities

in Cancun (Yucatan Peninsula), Mexico in the form of a dance convention and a speaking

engagement.

13. The business opportunities would require Ms. Miller to travel to Cancun from

March 3 to March 7, 2017.

14. The organizer of the dance convention and the speaking engagement did not

previously offer these opportunities to Ms. Miller because, until two (2) days ago, the sentencing

hearing was scheduled to occur today.

15. Accordingly, through no fault of her own, Ms. Miller is unable to comply with the

Courts requirement that all future motions to travel be filed more than two weeks prior to the

date of travel.

16. Ms. Miller seeks permission to travel to Cancun on the aforementioned dates to

pursue the aforementioned business opportunities.

17. To the extent the Court allows Ms. Miller to travel to Cancun, she also seeks

permission to travel to Merida (Yucatan), Mexico the day before, on March 2, 2017, to finalize a

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prior business opportunity Ms. Miller had pursued (Ms. Miller was previously in Yucatan with

the Courts permission).

18. Pursuant to Court approval, Ms. Miller will travel as follows:

a. Merida, Mexico March 2, 2017; and,

b. Cancun, Mexico March 3 7, 2017.

19. Pursuant to Court approval, Ms. Miller will return to Los Angeles, California,

where she lives and works, on March 7, 2017.

20. If permitted to travel, Ms. Miller will provide the Government, in advance, the

details of her business trip.

21. The Government has no objection to this Motion.

WHEREFORE, Defendant, Abigale Lee Miller, respectfully requests that this Honorable

Court grant her Motion for Permission to Travel Internationally, and enter the proposed Order

attached hereto.

Date: February 24, 2017 Respectfully submitted,

CLARK HILL, PLC

By: /s/ Brandon J. Verdream

Robert J. Ridge, Esquire
PA I.D. No.: 58651
E-mail: rridge@clarkhill.com
Brandon J. Verdream, Esquire
PA I.D. No.: 204162
E-mail: bverdream@clarkhill.com

Firm I.D. No.: 282

One Oxford Centre
301 Grant Street, 14th Floor
Pittsburgh, PA 15219
Telephone: (412) 394-7711
Fax: (412) 394-2555
Attorneys for Defendant, Abigale Lee Miller

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foregoing Motion for

Permission to Travel Internationally and proposed Order have been served on all counsel of

record this 24th day of February, 2017, via this Courts CM/ECF e-filing notification system.

/s/ Brandon J. Verdream

Brandon J. Verdream, Esquire
PA I.D. No.: 204162
E-mail: bverdream@clarkhill.com

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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA )

) Case No.: 2:15-cr-00212-JFC
)
v. ) Case No.: 2:16-cr-00132-JFC
)
ABIGALE LEE MILLER )

ORDER

AND NOW, upon consideration of Defendant Abigale Lee Millers Motion for

Permission to Travel Internationally, it is hereby ORDERED, ADJUDGED and DECREED that

said Motion is GRANTED. It is further hereby ORDERED that Defendant Abigale Lee Miller is

permitted to travel to the following locations on the following dates for business opportunities, as

set forth in said Motion:

a. Merida, Mexico March 2, 2017;

b. Cancun, Mexico March 3-7, 2017.

Date: ___________________, 2017 BY THE COURT:

__________________________________
Joy Flowers Conti
Chief U.S. District Judge
cc: All counsel of record (via CM/ECF)

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