Motion to modify conditions of release — USA v. Sanders et al. (Dkt. 88)

Summary

A motion to modify conditions of pre-trial release, Document 88 filed March 16, 2024 in United States v. Daisha Sanders, No. 4:24-cr-00029-BP, in the U.S. District Court for the Western District of Missouri. Defendant Daisha Sanders, through counsel Katrina Y. Robertson, states that the Northern District of Texas set conditions of release on February 23, 2024 in Case 3:24-mj-00190-RB, restricting travel to the Western and Northern Districts of Texas and directly to and from the Western District of Missouri for court or consultation with counsel. The motion asks the court to add the language "or as otherwise pre-approved by Pretrial Services". It states that defense counsel believes the pre-trial office does not oppose the modification, and it is signed /s/ Katrina Y. Robertson.

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IN THE UNITED STATES DISTRICT COURT  
FOR THE WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA,  
 
) 
 
 
 
 
 
 
 
) 
 
 
 
Plaintiff,  
 
 
) 
 
 
 
 
 
 
 
) 
v. 
 
 
 
 
 
)   Case No. 24-CR-00029-01-BP 
 
 
 
 
 
 
 
) 
DAISHA SANDERS,  
 
 
 
) 
 
 
 
 
 
 
 
) 
 
 
 
Defendant.  
 
 
) 
 
MOTION TO MODIFY CONDITIONS OF PRE-TRIAL RELEASE   
 
Defendant, Daisha Sanders, by and through counsel, Katrina Y. Robertson, and 
hereby moves this Court for an Order modifying the conditions of her pre-trial release.  In 
support, Defendant states the following: 
1.      On February 23, 2024, the United States District Court for the Northern 
District of Texas set conditions of release. (Case 3:24-mj-00190-RB). (Doc. 26)   
2.      Pursuant to that Order, Ms. Sanders must 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 counsel. 
3.      Defendant requests this Court to modify this provision in light of family 
circumstances and potential travel for a funeral.    
4.      Ms. Sanders asks this Court to modify the provision to include the additional 
language: or as otherwise pre-approved by Pretrial Services.  
5.      Since her release, Ms. Sanders has abided the conditions set by the Court and 
remained in contact with her supervising officer.  
6.       Defendant submits that she will absolutely comply with any other conditions 
which this Court shall impose.       
7       Defense counsel believes that the pre-trial office does not oppose such 
modification.  
 
8.      This modification of her pre-trial release condition is minimal, would still serve 
to protect the community and provide monitoring until the conclusion of this case.    
 
WHEREFORE, Ms. Sanders requests that this Honorable Court grant this Motion 
Case 4:24-cr-00029-BP     Document 88     Filed 03/16/24     Page 1 of 2

 
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and grant the relief requested herein, and for such other relief the Court deems just and 
proper. 
 
 
 
 
 
 
Respectfully Submitted, 
 
 
 
 
 
 
KATRINA Y. ROBERTSON, LLC 
 
 
      /s/ Katrina Y. Robertson                                     
 
 
 
 
 
 
Katrina Y. Robertson,   MBN 61289 
The Cable Building 
1321 Burlington Street 
Suite 600 
North Kansas City, MO 64116 
Office: (816) 885-4974  
Facsimile: (816) 817-4964  
 
ATTORNEY FOR DEFENDANT 
 
 
CERTIFICATE OF SERVICE  
 
 
 
The undersigned hereby certifies that a copy of the foregoing was delivered on March 
16, 2024 to the CM-ECF system of the United States District Court for the Western District 
of Missouri for electronic delivery to all counsel of record.    
 
 
 
 
_/s/ Katrina Y. Robertson ______________ 
 
 
 
 
 
 
Katrina Y. Robertson MBN 61289 
 
Case 4:24-cr-00029-BP     Document 88     Filed 03/16/24     Page 2 of 2

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