Motion to continue Defendant's Unopposed Motion — USA v. Sanders et al. (Dkt. 60)

Record facts

U.S. District Court records for the Western District of Missouri and Western District of Washington · No. 4:24-cr-00029-BP · Doc. 60 · 2024-03-04 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
 
 
UNITED STATES OF AMERICA 
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Plaintiff, 
 
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v. 
 
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Case No. 4:24-cr-00029-BP 
 
ROXANNE NAZIR 
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Defendant. 
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DEFENDANT’S UNOPPOSED MOTION  
TO RESCHEDULE THE ARRAIGNMENT 
 
COMES NOW undersigned counsel, Matthew T. Merryman, on behalf of the Defendant 
Roxanne Nazir (“Defendant”), and requests this Court to reschedule the Arraignment scheduled 
on March 7, 2024 at 1:30 PM. 
SUGGESTIONS IN SUPPORT 
1. 
On February 6, 2024, Roxanne Nazir was named along with ten co-defendants in 
a thirteen count Indictment alleging conspiracy to commit wire fraud. 
2. 
On February 26, 2024, the Court ordered Ms. Nazir to appear at her arraignment 
of the Indictment on March 7, 2024 at 1:30 PM. 
3. 
On February 27, 2024, Counsel was ordered to represent Ms. Nazir pursuant to 
the Criminal Justice Act. 
4. 
 Counsel has discovered a scheduling conflict that exists on March 7, 2024 which 
will prevent counsel from appearing at 1:30 PM. 
Case 4:24-cr-00029-BP     Document 60     Filed 03/04/24     Page 1 of 3

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5. 
Counsel is scheduled to appear at a Termination of Parental Rights (“TPR) 
hearing on March 7, 2024 at 2:00 PM before the Honorable Alisha O’Hara in Division III of the 
Clay County Circuit Court in In Re Anderson 23CY-JU00115. 
6. 
Counsel does not believe he can make both the TPR hearing and Ms. Nazir’s 
arraignment. 
7. 
Counsel is requesting that the arraignment be rescheduled for Wednesday March 
6, 2024 or Friday March 8, 2024. 
8. 
On March 4, 2024, Counsel conferred with AUSA Paul Becker and the United 
States of America does not oppose this request for a continuance. 
9. 
This Unopposed Motion to Reschedule the Arraignment is made in good faith and 
not to burden or unduly delay the Court or United States of America. 
WHEREFORE, Counsel for Defendant respectfully requests that this Court reschedule 
the arraignment to Wednesday March 6, 2024 or Friday March 8, 2024.. 
Dated: 
March 4, 2024 
 
 
THE BATES & MERRYMAN LAW FIRM LLC 
/s/ Matthew T. Merryman  
 
Matthew T. Merryman 
The Bates & Merryman Law Firm LLC 
P.O. Box 10282 
Kansas City, MO 64111 
816-223-4482 
mmerryman@bmmblaw.com  
Case 4:24-cr-00029-BP     Document 60     Filed 03/04/24     Page 2 of 3

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CERTIFICATE OF SERVICE 
I hereby certify that on March 4, 2024, a copy of the foregoing Defendant’s Unopposed 
Motion to Reschedule the Arraignment, was filed electronically. Notice of this filing will be sent 
to all parties by operation of the Court’s electronic filing system. Parties may access the filing 
through the Court’s Electronic Case Filing System. 
/s/Matthew T. Merryman 
 
Matthew T. Merryman 
 
Case 4:24-cr-00029-BP     Document 60     Filed 03/04/24     Page 3 of 3

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