Case 2:15-cr-00212-JFC Document 80 Filed 02/10/17 Page 1 of 5

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 October 13, 2015, the Government filed an Indictment against Ms. Miller at

Case No. 2:15-cr-212 (No. 212).

2. In the Indictment, the Government alleged that Ms. Miller committed various

criminal acts during the pendency of a prior bankruptcy proceeding. (No. 212, Docs. 1-2.)

3. On June 20, 2016, the Government filed an Information against Ms. Miller at

Case No. 2:16-cr-132 (No. 132).

4. In the Information, the Government alleged that Ms. Miller failed to file a report

required under 31 U.S.C. 5316 in violation of 31 U.S.C. 5324(c)(1), stemming from an

overseas trip to Australia in 2014. (No. 132, Docs. 1-2.)

5. 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). (No. 212,

Doc. 44; No. 132, Doc. 7.)

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

appearance bond while awaiting sentencing.

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

for any international travel.

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

2017, at which Ms. Miller was present.

9. The second portion of Ms. Millers sentencing hearing is scheduled to occur on

February 24, 2017.

10. Ms. Miller currently lives and works in Los Angeles, California.

11. Ms. Miller respectfully requests that the Court permit her to travel to London and

Newcastle, England, for business opportunities prior to the second portion of the sentencing

hearing.

12. Pursuant to Court approval, Ms. Miller will travel to the aforementioned locations

as follows:

a. London, England February 16-20, 2017; and,

b. Newcastle, England February 21, 2017.

13. Pursuant to Court approval, Ms. Miller will return to Pittsburgh, Pennsylvania on

February 22, 2017.

14. If permitted to travel to England, Ms. Miller will provide the Government, in

advance, the details of her business trip.

15. Since the filing of the Indictment at No. 212, Ms. Miller, with Court permission,

has traveled extensively, including internationally.

16. Specifically, with Court permission, Ms. Miller traveled to Norway, Scotland,

England, Gibraltar, Spain, and Mexico (No. 212, Docs. 33, 55.)

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17. The trip to Mexico occurred after Ms. Miller pleaded guilty to the aforementioned

charges.

18. Although not a condition of her bond, Ms. Miller has sought Court approval and

consent from the Government for domestic travel.

19. Ms. Miller has complied with the conditions of her release pending sentencing.

20. Ms. Miller has appeared before the Court when required.

21. Ms. Miller is not a flight risk.

22. There is no risk of Ms. Miller intentionally not returning for the second portion of

the sentencing hearing on February 24, 2017.

23. Ms. Millers livelihood depends, in part, on her ability to travel for business

opportunities, including internationally.

24. Accordingly, Ms. Miller respectfully requests that this Court grant her permission

to travel to the aforementioned locations on the aforementioned dates.

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 10, 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

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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 10th 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. London, England February 16-20, 2017; and,

b. Newcastle, England February 21, 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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