Motion to modify conditions of release — USA v. Sanders et al. (Dkt. 86)

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. 86 · 2024-03-14 · Docket on CourtListener

Full text

Defendant’s Motion to Modify Release Conditions page 1 
 
IN THE UNITED STATES DISTRICT COURT FOR THE  
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
 
UNITED STATES OF AMERICA, 
 
 
                   Plaintiff, 
 
v. 
DENISE SANDERS, 
 
 
                   Defendant. 
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Case No. 4:24-cr-00029-BP-3 
 
DEFENDANT’S MOTION TO MODIFY RELEASE CONDITIONS  
WITH DECLARATION OF COUNSEL 
 
Denise Sanders, through undersigned counsel, Paul Hood, respectfully moves the Court 
for an Order modifying pretrial release conditions to permit the Defendant to travel to the 
Western District of Missouri with the prior approval of her Pretrial Services Officer.  The 
Government does not oppose this request.  The United States Pretrial Services Office also does 
not oppose this request.  Ms. Sanders resides in Texas and is supervised there.  She is currently 
permitted to travel to the Western District of Missouri for Court or attorney meetings only.   
Ms. Sanders was arraigned on February 29, 2024.  ECF Doc. 46.  She has no prior 
criminal history.  ECF Doc. 41 at 4.  The Government did not seek detention.  Ms. Sander was 
continued on pretrial release with conditions that had been previously ordered by the United 
States District Court for the District of Texas.  Those conditions limit Ms. Sanders’s travel to the 
“Western & Northern District of Texas and directly to and from the Western District of Missouri 
for Court or consultation with counsel.”  ECF Doc. 28 at 2 (condition 7f).  
Case 4:24-cr-00029-BP     Document 86     Filed 03/14/24     Page 1 of 4

Defendant’s Motion to Modify Release Conditions page 2 
 
Ms. Sanders respectfully moves this Court to modify the previously cited travel 
restriction by adding these words to the end of the condition, “or as otherwise pre-approved by 
Pretrial Services.”  If modified as requested, the full condition from 7f would read as follows: 
Abide by the following restrictions on personal association, 
residence, or travel: Western & Northern District of Texas and 
directly to and from the Western District of Missouri for Court or 
consultation with your counsel or as otherwise pre-approved by 
Pretrial Services.  
 
Ms. Sanders has significant connections to Kansas City and the Kansas City-area, 
including family who live here.  The requested modification would allow Ms. Sanders to travel 
to Kansas City and the Kansas City-area so long as the Pretrial Services Office approved of the 
travel in advance.  This request arose because Ms. Sanders will soon need to travel to Kansas 
City for a funeral.  In consultation with the US Pretrial Services, the relief requested by this 
motion is tailored not just to that anticipated trip but to address travel needs more generally based 
on Ms. Sanders connections to this area.  This request is supported by the following declaration 
of counsel: 
DECLARATION 
  I, Paul Hood, declare under of penalty of perjury that the following is true to the best of 
knowledge and belief: 
1. I am the attorney for Denise Sanders in this matter.   
2. On March 13, 2024, she contacted me regarding a request to travel to Kansas City, 
Missouri. 
3. Ms. Sanders’s husband has a serious medical condition and is near the end of his life. 
4. Her husband was recently removed from a ventilator and is not expected to live much 
longer.   
Case 4:24-cr-00029-BP     Document 86     Filed 03/14/24     Page 2 of 4

Defendant’s Motion to Modify Release Conditions page 3 
 
5. His funeral will be in Kansas City. 
6. Ms. Sanders had also contacted Wayne Webb, her Supervising Pretrial Services 
Officer in Texas, regarding the situation. 
7. On March 14, 2024, I conferred with Tanis Humig with United States Pretrial 
Services in Kansas City, MO. 
8. The Pretrial Services Office in Kansas City does not object to this motion. 
9. The Pretrial Services Office in Texas also does not object to this motion. 
10. On March 14, 2024, I also conferred with Assistant United States Attorney Paul 
Becker regarding this motion, including a description of the relief requested and the 
supporting rationale. 
11. The Government does not oppose this motion.     
12. Ms. Sanders is sixty years old and has no criminal history. 
CONCLUSION 
Release conditions are to be no more restrictive than is necessary to meet two goals: 
safety and the appearance of the accused at court dates.  18 U.S.C. § 3142(c)(1)(B).  Both of 
those goals can be met while allowing Ms. Sanders to travel to the Western District of Missouri 
for Court, attorney meetings, and for other purposes with the pre-approval of United States 
Pretrial Services.  For the reasons stated, the requested relief should be granted.          
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
s/ Paul Hood  
 
 
             
 
 
 
 
 
PAUL HOOD, MO 55215 
 
 
 
 
 
104 W. 9th Street, Suite 404 
 
 
 
 
 
Kansas City, MO 64105 
 
 
 
 
 
Phone: 541-513-7545 
 
 
 
 
 
Fax: 844-284-3964  
 
 
 
 
 
paul@paulhoodlaw.com 
 
 
 
 
 
Attorney for Denise Sanders 
Case 4:24-cr-00029-BP     Document 86     Filed 03/14/24     Page 3 of 4

Defendant’s Motion to Modify Release Conditions page 4 
 
Certificate of Service 
 
 
The undersigned certifies that the foregoing motion was electronically filed on 
March 14, 2024 and that service was accomplished through Notice of Electronic Filing to 
counsel for the Government and counsel for co-defendants. 
 
 
 
 
 
 
 
/s/ Paul Hood  
 
 
             
 
 
 
 
 
Paul Hood 
 
 
 
 
 
 
 
Case 4:24-cr-00029-BP     Document 86     Filed 03/14/24     Page 4 of 4

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