Snipes wants to travel to London & Thailand
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Snipes wants to travel to London & Thailand
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
OCALA DIVISION
)
UNITED STATES, )
)
Plaintiff, )
) Case No. 5:06-cr-00022-WTH-GRJ
v. )
)
WESLEY SNIPES, )
)
Defendant. )
)
SNIPES’ MOTION FOR LIMITED TRAVEL
FOR WORK OBLIGATIONS
Comes now the Defendant, Wesley Trent Snipes (hereinafter “Snipes”), by and
through his counsel of record, Daniel R. Meachum & Associates, LLC., by Daniel R. Meachum, who respectfully moves the Court for permission to travel outside the continental United States to fulfill contractual obligations on two films, as more fully set forth below.
1.
The Order Setting Conditions of Release entered in this case on December 8, 2006, restricts Mr. Snipes’ travel to the continental United States. (Doc 60.)
2.
The Order Setting Conditions of Release allowed Mr. Snipes to return to Namibia, to complete the shooting of a film he was working on at that time. When discussing this request, the Government agreed that Mr. Snipes posed no risk of flight, is not a risk to himself or the community, and has strong family ties in the United States.
3.
On August 6, 2007, the Court granted Snipes’ Unopposed Motion to Amend Conditions of Release (Doc. 181), which authorized Mr. Snipes to film Art of War in Vancouver, Canada.
4.
On December 19, 2007, the Court granted Snipes’ Motion for Limited Holiday Travel to be with his family (Doc 329), authorizing him to travel to South Korea for Christmas and New Year’s Eve.
5.
On March 12, 2008, the Court granted Mr. Snipes’ Unopposed Amended Motion to Travel and Conditions of Release, (Doc. 430) authorizing him to travel outside the country for the limited purpose of post-production of The Art of War II, for which he was under contract.
6.
By Order entered May 22, 2008 (Doc. 475 ) this Court continued Mr. Snipes’ bail pending appeal. On June 19, 2008, the government filed a notice of appeal from that bail order.
7.
At this time, Mr. Snipes is herein respectfully requesting leave to travel to London, England and Bangkok, Thailand for the limited purpose of fulfilling other contractual obligations relating to two additional films- Gallowalker and Chasing the Dragon.
8.
Mr. Snipes’ employment obligations require him to be onsite for approximately three days for post-production editing on the film Gallowalker. Post-production editing of the film is scheduled to begin on July 14, 2008.
9.
The post-production editing is central to the completion of the film. Mr. Snipes is under contract for this post-production work, and his failure to take part in this post-production work may be deemed a breach of his contract with adverse effects for the completion of the film and for his future livelihood as an actor.
10.
In addition to the Gallowalker contractual obligations, Mr. Snipes seeks leave to travel to Bangkok, Thailand to film Chasing the Dragon, on which Mr. Snipes is under contract to perform as an actor.
11.
The filming of Chasing the Dragon is scheduled to begin on September 8, 2008 in Bangkok and is expected to last approximately eight weeks.
12.
The appeal and cross-appeal in this case will not be completed in the ordinary course before the end of the shooting schedule for Chasing the Dragon and the completion of the post-production work in Gallowalker.
13.
These requests are similar to those previously granted by this Honorable Court. Mr. Snipes has conscientiously complied with the Order Setting Conditions of Release living up to the trust the Court has shown in him. He has never presented and does not currently present a risk of flight.
14.
Further, the circumstances of the work, surrounded by a cast of other actors and film and production professionals as well as Mr. Snipes’ contractual obligations to complete these films provide additional assurances that he does not present a risk of flight; were he to abscond under these circumstances, it would destroy his ability to earn a living for the rest if his life. Mr. Snipes will of course voluntarily return after his work on this film, as he has done each time he has been granted permission by this Court.
15.
It is essential that Mr. Snipes complete these two projects to satisfy his civil tax liabilities and provide for his family.
16.
If the Court requires additional specificity or confirmation of the travel arrangements or contractual details relating to these films, counsel will provide it at the Court’s request.
WHEREFORE, for the reasons set forth above and any others this Court may find appropriate, Snipes respectfully requests that the Court return his passport and allow him to travel to London for the period beginning July 13, 2008 through July 17, 2008 and further travel subsequently to Bangkok on September 8, 2008, to return upon completion of filming.
Respectfully submitted on June 25, 2008.
/s/ Daniel R. Meachum
Daniel R. Meachum
MIDDLE DISTRICT OF FLORIDA
OCALA DIVISION
)
UNITED STATES, )
)
Plaintiff, )
) Case No. 5:06-cr-00022-WTH-GRJ
v. )
)
WESLEY SNIPES, )
)
Defendant. )
)
SNIPES’ MOTION FOR LIMITED TRAVEL
FOR WORK OBLIGATIONS
Comes now the Defendant, Wesley Trent Snipes (hereinafter “Snipes”), by and
through his counsel of record, Daniel R. Meachum & Associates, LLC., by Daniel R. Meachum, who respectfully moves the Court for permission to travel outside the continental United States to fulfill contractual obligations on two films, as more fully set forth below.
1.
The Order Setting Conditions of Release entered in this case on December 8, 2006, restricts Mr. Snipes’ travel to the continental United States. (Doc 60.)
2.
The Order Setting Conditions of Release allowed Mr. Snipes to return to Namibia, to complete the shooting of a film he was working on at that time. When discussing this request, the Government agreed that Mr. Snipes posed no risk of flight, is not a risk to himself or the community, and has strong family ties in the United States.
3.
On August 6, 2007, the Court granted Snipes’ Unopposed Motion to Amend Conditions of Release (Doc. 181), which authorized Mr. Snipes to film Art of War in Vancouver, Canada.
4.
On December 19, 2007, the Court granted Snipes’ Motion for Limited Holiday Travel to be with his family (Doc 329), authorizing him to travel to South Korea for Christmas and New Year’s Eve.
5.
On March 12, 2008, the Court granted Mr. Snipes’ Unopposed Amended Motion to Travel and Conditions of Release, (Doc. 430) authorizing him to travel outside the country for the limited purpose of post-production of The Art of War II, for which he was under contract.
6.
By Order entered May 22, 2008 (Doc. 475 ) this Court continued Mr. Snipes’ bail pending appeal. On June 19, 2008, the government filed a notice of appeal from that bail order.
7.
At this time, Mr. Snipes is herein respectfully requesting leave to travel to London, England and Bangkok, Thailand for the limited purpose of fulfilling other contractual obligations relating to two additional films- Gallowalker and Chasing the Dragon.
8.
Mr. Snipes’ employment obligations require him to be onsite for approximately three days for post-production editing on the film Gallowalker. Post-production editing of the film is scheduled to begin on July 14, 2008.
9.
The post-production editing is central to the completion of the film. Mr. Snipes is under contract for this post-production work, and his failure to take part in this post-production work may be deemed a breach of his contract with adverse effects for the completion of the film and for his future livelihood as an actor.
10.
In addition to the Gallowalker contractual obligations, Mr. Snipes seeks leave to travel to Bangkok, Thailand to film Chasing the Dragon, on which Mr. Snipes is under contract to perform as an actor.
11.
The filming of Chasing the Dragon is scheduled to begin on September 8, 2008 in Bangkok and is expected to last approximately eight weeks.
12.
The appeal and cross-appeal in this case will not be completed in the ordinary course before the end of the shooting schedule for Chasing the Dragon and the completion of the post-production work in Gallowalker.
13.
These requests are similar to those previously granted by this Honorable Court. Mr. Snipes has conscientiously complied with the Order Setting Conditions of Release living up to the trust the Court has shown in him. He has never presented and does not currently present a risk of flight.
14.
Further, the circumstances of the work, surrounded by a cast of other actors and film and production professionals as well as Mr. Snipes’ contractual obligations to complete these films provide additional assurances that he does not present a risk of flight; were he to abscond under these circumstances, it would destroy his ability to earn a living for the rest if his life. Mr. Snipes will of course voluntarily return after his work on this film, as he has done each time he has been granted permission by this Court.
15.
It is essential that Mr. Snipes complete these two projects to satisfy his civil tax liabilities and provide for his family.
16.
If the Court requires additional specificity or confirmation of the travel arrangements or contractual details relating to these films, counsel will provide it at the Court’s request.
WHEREFORE, for the reasons set forth above and any others this Court may find appropriate, Snipes respectfully requests that the Court return his passport and allow him to travel to London for the period beginning July 13, 2008 through July 17, 2008 and further travel subsequently to Bangkok on September 8, 2008, to return upon completion of filming.
Respectfully submitted on June 25, 2008.
/s/ Daniel R. Meachum
Daniel R. Meachum
Demo.
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Re: Snipes wants to travel to London & Thailand
At least he's not asking the U.S. Marshals to carry his luggage for him.
Dan Evans
Foreman of the Unified Citizens' Grand Jury for Pennsylvania
(And author of the Tax Protester FAQ: evans-legal.com/dan/tpfaq.html)
"Nothing is more terrible than ignorance in action." Johann Wolfgang von Goethe.
Foreman of the Unified Citizens' Grand Jury for Pennsylvania
(And author of the Tax Protester FAQ: evans-legal.com/dan/tpfaq.html)
"Nothing is more terrible than ignorance in action." Johann Wolfgang von Goethe.
Re: Snipes wants to travel to London & Thailand
When the judge renders his or her decision, I hope they consider this very important question:
Does the world need another two Wesley Snipes films?
Well? Does it?
Sorry, that was 3 questions, I was a little worked up just then. Think of the children!
Does the world need another two Wesley Snipes films?
Well? Does it?
Sorry, that was 3 questions, I was a little worked up just then. Think of the children!
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Re: Snipes wants to travel to London & Thailand
He should be required to post a bond equal to double the amount of his outstanding tax liability. Hell, he can stay over there then as far as I'm concerned.
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Re: Snipes wants to travel to London & Thailand
I like the way you think!Joey Smith wrote:He should be required to post a bond equal to double the amount of his outstanding tax liability. Hell, he can stay over there then as far as I'm concerned.
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Re: Snipes wants to travel to London & Thailand
Let that be a lesson for us all, don't schedule any projects if you're planning to commit a crime.
Three cheers for the Lesser Evil!
10 . . . . . . . . . . . . . . . 2
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Re: Snipes wants to travel to London & Thailand
London might be out of the question.
They just refused a visa to convicted felon Martha Stewart.
However, there's a possible trade. Based on recent visa refusals, we could trade Snipes for Boy George.
They just refused a visa to convicted felon Martha Stewart.
However, there's a possible trade. Based on recent visa refusals, we could trade Snipes for Boy George.
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Re: Snipes wants to travel to London & Thailand
Martha's got a felony conviction. Snipes only has misdemeanors.
Demo.
Re: Snipes wants to travel to London & Thailand
The world doesn’t really need another two Wesley Snipes films. But you need to consider Snipes’ ability to pay his back taxes. I say let him make the films so the IRS can levy the proceeds. That’s the biggest value I see in two more Wesley Snipes films.Leftcoaster wrote:When the judge renders his or her decision, I hope they consider this very important question:
Does the world need another two Wesley Snipes films?
Well? Does it?
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Re: Snipes wants to travel to London & Thailand
Snipes has already been paid on one of the films.
Demo.
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Re: Snipes wants to travel to London & Thailand
I hope I'm not out of line with this question, but has he paid the federal income tax on his income from that film yet (or at least made some estimated payments)? I mean, would it be possible for him to at least pay the tax on that before the judge lets him go overseas while he appeals his convictions?Demosthenes wrote:Snipes has already been paid on one of the films.
Sorry; that was insensitive of me.
"My greatest fear is that the audience will beat me to the punch line." -- David Mamet
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Re: Snipes wants to travel to London & Thailand
As of the date of sentencing, he still hadn't file any tax returns since 1999. He did bring two checks with him totaling $5 million in an attempt to get a more lenient sentence, but that amount would have been to cover part of the taxes due for the years in question at the trial.
Demo.
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Re: Snipes wants to travel to London & Thailand
The gov's response:
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
OCALA DIVISION
UNITED STATES OF AMERICA
v. CASE NO. 5:06-cr-22(S1)-Oc-10GRJ
WESLEY TRENT SNIPES
UNITED STATES’ RESPONSE IN OPPOSITION TO
DEFENDANT SNIPES’ MOTION FOR INTERNATIONAL TRAVEL
The United States of America, by and through the undersigned attorneys for the
United States, opposes defendant Snipes’ Motion for Limited Travel for Work
Obligations (Doc. 486).
In his motion, defendant Snipes makes two separate requests for international
travel. First, defendant Snipes requests to be allowed to travel to London, England from
July 13, 2008 through July 17, 2008 for post-production editing of the film “Gallowalker.”
Id. at 3. Second, defendant Snipes requests to be allowed to travel to Bangkok,
Thailand for the filming of “Chasing the Dragon.” Id. According to the defendant, this
new project is “scheduled to begin on September 8, 2008 . . . and is expected to last
approximately eight weeks.” Id. The defendant offers to return at an unspecified date
“upon completion of filming.” Id. at 4.
The defendant argues that he is not a risk of flight based on his previous history
of returning from international travel while on bond in this case. However, the
defendant’s previous international travel was prior to sentencing. The defendant now
has been sentenced to three years’ imprisonment. Thus, the defendant’s motivation to
return to the United States has changed drastically. See United States v. Bland, No.
CR05-5785 RBL, 2007 WL 563322 (W.D. Wash. Feb. 20, 2007). Accordingly, the
defendant now poses a risk of flight that he did not previously, and his motion should be
denied.
Alternatively, even if the Court finds that the defendant is not a flight risk despite
his impending incarceration, and is inclined to permit him some international travel while
his appeal is pending, the Court should grant such travel sparingly. It would be one
thing to allow the defendant to travel across the Atlantic for a brief and defined period of
time to finish a project that is nearly complete; it would be another to allow the
defendant to spend two months (likely more) beginning a new project half-way around
the world with an open-ended return date. Such a travel request is too lengthy and too
vague. Undoubtedly, it will be followed by additional requests for international travel for
follow-up work. Allowing lengthy or frequent international travel could delay the appeal
in this case as Snipes’ attorneys will almost certainly seek one or more extensions of
the briefing schedule based, in part, on their inability to consult with their jet-setting
client.
In any event, if the Court permits any international travel, the Court should
increase the amount of the defendant’s bond.
WHEREFORE, the United States respectfully requests that the Court deny
defendant Snipes’ motion. Alternatively, if the Court permits the defendant to travel
internationally, the Court should deny his request to travel to Bangkok and should
increase the amount of his bond.
Respectfully submitted,
ROBERT E. O’NEILL
United States Attorney
Demo.
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Re: Snipes wants to travel to London & Thailand
The judge lets Snipes travel.
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
OCALA DIVISION
UNITED STATES OF AMERICA
v. WESLEY TRENT SNIPES
______________________________/
O R D E R
Upon due consideration, Defendant Snipes’ Motion For Limited Travel For Work
Obligations (Doc. 486) to which the Government has filed a response in opposition (Doc.
489) is GRANTED. Defendant Snipes’ Motion For Leave to File a Reply to the
Government’s Opposition to Snipes’ Motion For Limited Travel For Work Obligations (Doc.
490) is DENIED AS MOOT.
The Defendant’s existing conditions of release (Doc. 60) require, among other things,
that he will be supervised in the Central District of California and shall report as directed
by the Pretrial Services Office. Within ten (10) days from the date of this Order, the Pretrial
Services Officer is requested to furnish to the Court (by filing a copy in this action) of any
and all reporting instructions to which the Defendant is presently subject, and to make a
report concerning the Defendant’s record of compliance with those instructions. This Order
will be subject to reconsideration after receipt of the report from the Pretrial Services
Officer.
IT IS SO ORDERED.
DONE and ORDERED at Ocala, Florida this 2nd day of July, 2008.
Demo.
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Re: Snipes wants to travel to London & Thailand
I think a few US marshalls are going to get a free vacation.
Three cheers for the Lesser Evil!
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. . . . . . Dr Pepper
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Re: Snipes wants to travel to London & Thailand
Judge: Snipes can travel abroad for movies
OCALA, Fla. (AP) — Wesley Snipes will be allowed to leave the United States to work on two movies while his lawyers appeal his tax convictions.
Federal judge William Terrell Hodges on Wednesday approved the actor's motion to travel to London and Bangkok, Thailand. Snipes will be in England about three days this month for post-production editing of Gallowwalker, and in Thailand for eight weeks to film Chasing the Dragon.
A jury convicted the action star in February of three counts of willfully failing to file his income taxes. The 45-year-old Snipes, star of the Blade trilogy, White Men Can't Jump and Jungle Fever among other films, has appealed the convictions and his three-year prison sentence to the 11th Circuit Court in Atlanta.
Prosecutors asked Hodges to deny Snipes' request to travel abroad, saying he was a flight risk.
OCALA, Fla. (AP) — Wesley Snipes will be allowed to leave the United States to work on two movies while his lawyers appeal his tax convictions.
Federal judge William Terrell Hodges on Wednesday approved the actor's motion to travel to London and Bangkok, Thailand. Snipes will be in England about three days this month for post-production editing of Gallowwalker, and in Thailand for eight weeks to film Chasing the Dragon.
A jury convicted the action star in February of three counts of willfully failing to file his income taxes. The 45-year-old Snipes, star of the Blade trilogy, White Men Can't Jump and Jungle Fever among other films, has appealed the convictions and his three-year prison sentence to the 11th Circuit Court in Atlanta.
Prosecutors asked Hodges to deny Snipes' request to travel abroad, saying he was a flight risk.
Whenever you hear a man speak of his love for his Country, it is a sign he expects to be paid for it. – H. L. Mencken
Death and Taxes. Ya Think?
Death and Taxes. Ya Think?
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Re: Snipes wants to travel to London & Thailand
Zha zhing, convicted man.
10 quatloos says he runs to a country that we have no extradition treaty with.
10 quatloos says he runs to a country that we have no extradition treaty with.
The laissez-faire argument relies on the same tacit appeal to perfection as does communism. - George Soros
Re: Snipes wants to travel to London & Thailand
Like the one that's less than 150 miles from Bangkok? The thought had crossed my mind too, but on the other hand, I'd just do the three years in lieu of having to live in Cambodia the rest of my life.Doktor Avalanche wrote:Zha zhing, convicted man.
10 quatloos says he runs to a country that we have no extradition treaty with.
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Re: Snipes wants to travel to London & Thailand
Also, as noted in the court filing if Snipes flees then his very lucrative career is over. Then again, if he has a few million in cash stashed around, who needs a lucrative career?RyanMcC wrote:Like the one that's less than 150 miles from Bangkok? The thought had crossed my mind too, but on the other hand, I'd just do the three years in lieu of having to live in Cambodia the rest of my life.Doktor Avalanche wrote:Zha zhing, convicted man.
10 quatloos says he runs to a country that we have no extradition treaty with.
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Re: Snipes wants to travel to London & Thailand
Well you'll work harder with a gun in your backRyanMcC wrote:Like the one that's less than 150 miles from Bangkok? The thought had crossed my mind too, but on the other hand, I'd just do the three years in lieu of having to live in Cambodia the rest of my life.Doktor Avalanche wrote:Zha zhing, convicted man.
10 quatloos says he runs to a country that we have no extradition treaty with.
For a bowl of rice a day...
Three cheers for the Lesser Evil!
10 . . . . . . . . . . . . . . . 2
. . . . . . Dr Pepper
. . . . . . . . . . . . . . .. . . 4
10 . . . . . . . . . . . . . . . 2
. . . . . . Dr Pepper
. . . . . . . . . . . . . . .. . . 4