UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-03308-MJ-TORRES

UNITED STATES OF AMERICA, 

v. 

ACISCLO VALLADARES URRUELA, 

Defendant.

___________________________________/

DEFENDANT ACISCLO VALLADARES URRUELA’S UNOPPOSED

MOTION TO PERMIT TRAVEL

Defendant Acisclo Valladares Urruela respectfully requests the entry of an order permitting 

him to take a personal trip outside of the Southern District of Florida from April 8, 2022 through 

April 11, 2022. The grounds for this request are set forth below. 

1. Mr. Valladares made his initial appearance on October 20, 2020. Mr. Valladares 

was released on bond. One of the conditions of bond is that Mr. Valladares may enter airports 

located in the Southern District of Florida for the sole purpose of accompany his children either 

(1) before they board any flight from this District (2) after they de-board any flight into this 

District, if there is no other adult relative accompany them. 

2. Mr. Valladares respectfully requests permission to travel to Washington, DC for a 

personal trip from April 8, 2022 through April 11, 2022. 

3. Mr. Valladares will be away only to travel to Washington, DC, participate in 

personal events, and return home. 

4. Because he does not have a U.S. driver’s license or other ID document acceptable 

for domestic air travel, Mr. Valladares will need his Guatemalan passport to make this trip. He 

has, however, surrendered that passport as a condition of his bond. Accordingly Mr. Valladares

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Gelber Schachter & Greenberg, P.A.

One southeast third avenue ▪ Suite 2600▪ Miami, Florida 33131 ▪ www.gsgpa.com

has consulted with his Pretrial Services Officer, Jorge Ferdinandy, regarding the logistics for these 

trips if this motion is granted. Mr. Ferdinandy has advised that Mr. Valladares would need to obtain 

his passport from Pretrial Services the day before departing for Washington, DC and return it 

within 24 hours of getting back home. Mr. Valladares would of course agree to this condition and 

would comply with any other conditions or requests from Pretrial Services. 

5. Undersigned counsel has conferred with Mr. Ferdinandy and with Assistant United 

States Attorney Walter Norkin. Neither the United States nor Pretrial Service oppose this motion. 

Mr. Valladares will not let the travel interfere with any court dates or obligations and will alter his 

travel schedule if necessary to attend any proceedings. 

6. A proposed order is attached as Exhibit A.

WHEREFORE, Defendant Acisclo Valladares Urruela respectfully requests the entry of 

an order permitting him to make the trip as stated herein.

Dated: April 4, 2022 Respectfully Submitted,

/s/Gerald E. Greenberg

GERALD E. GREENBERG

Florida Bar No. 440094

ggreenberg@gsgpa.com

DAN GELBER

Florida Bar No. 512877

dan@gsgpa.com

NATALIA B. MCGINN

Florida Bar No. 1011385

nmcginn@gsgpa.com

GELBER SCHACHTER & GREENBERG, P.A.

SunTrust International Center 

One Southeast Third Avenue, Suite 2600

Miami, Florida 33131 

Telephone: (305) 728-0950

E-service: efilings@gsgpa.com

Counsel for Defendant Acisclo Valladares Urruela

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