UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO, 20-TP-20045-BB

UNITED STATES OF AMERICA

vs.

ERIC SEIDEN,

Defendant.

___________________________________/

GOVERNMENT’S RESPONSE 

IN OPPOSITION TO DEFENDANT’S MOTION TO TRAVEL

The United States, by and through the undersigned Assistant United States Attorney, 

respectfully submits this response in opposition to the Movant’s, Eric Seiden, motion to travel (the 

“Motion”) (DE 10). Claiming that the United States Probation Office (“Probation”) has 

arbitrarily denied his request to travel, the Movant asks the Court to override Probation’s decision. 

As discussed more fully below, the Court should deny the Motion because the denial of the 

Movant’s request was not arbitrary but based upon the fact that he did not comply with the

conditions of his supervised release. In support thereof, the United States states as follows:

1. In December of last year, the Movant submitted a request to Probation, seeking to 

travel to Orlando to visit his mother approximately once per month. 

2. On January 11, 2021, Probation sent the request to the probation office in the 

Middle District of Florida, so that they could inspect the Movant’s mother’s home to determine if 

it was suitable considering his sex offender status. The Middle District of Florida denied the 

request because the residence did not meet the requisite requirements. Specifically, her residence 

is near schools and daycares and is also equipped with a computer that has access to the internet. 

Probation asked the Movant to provide an alternative location to reside at while he visited his 

Case 1:20-tp-20045-BB Document 14 Entered on FLSD Docket 03/03/2021 Page 1 of 3
2

mother.

3. In mid-February of 2021, Probation received the Movant’s request for the approval 

of an alternate location, which was the Hampton Inn. Because of the Movant’s underlying 

offense, which involves driving from Miami to Orlando to have sex with a minor in a hotel, 

Probation did not believe that the new proposed location was suitable. Additionally, shortly 

before receiving the request for approval of the alternative location, the Movant, on February 10, 

2020, had self-reported that he used his computer to send personal emails, which was not 

authorized by the Court. In addition, on February 11, 2021, Probation discovered that the Movant 

had obtained secondary employment without notifying Probation and obtaining the requisite 

approval. 

4. Probation advised the Movant that his conduct did not comply with the terms of his 

supervised release and, based on that conduct, denied his request to travel. Accordingly, based 

on the Movant’s failure to abide by the conditions of his supervised release and to provide a

suitable location to reside at while he visits his mother, the United States believes that the Movant

should not be allowed to travel at this time and opposes the Motion.

Case 1:20-tp-20045-BB Document 14 Entered on FLSD Docket 03/03/2021 Page 2 of 3
3

III. Conclusion

Based on the foregoing, the United States respectfully requests that the Court deny the 

Movant’s Motion.

Respectfully submitted,

 ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

By: /s/ Quinshawna S. Landon

QUINSHAWNA S. LANDON

ASSISTANT U.S. ATTORNEY

Florida Bar No. 99835

99 NE 4th Street, 4th Floor

Miami, Florida 33132-2111

Tel. No. (305) 961-9362

E-mail: Quinshawna.Landon@usdoj.gov 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on March 3, 2021, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF.

/s/ Quinshawna S. Landon

QUINSHAWNA S. LANDON

ASSISTANT U.S. ATTORNEY

Case 1:20-tp-20045-BB Document 14 Entered on FLSD Docket 03/03/2021 Page 3 of 3