Motion to modify conditions of release — USA v. Sanders et al. (Dkt. 90)

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. 90 · 2024-03-28 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA,  
) 
 
 
 
 
 
 
) 
 
 
 
Plaintiff, 
 
) 
 
 
 
 
 
 
) 
vs.  
 
 
 
 
 
) 
Case No. 4:24-cr-00029-BP-2 
 
 
 
 
 
 
) 
JOEL WRIGHT, 
 
 
 
) 
 
 
 
 
 
 
) 
 
 
 
Defendant, 
 
) 
 
DEFENDANT’S MOTION TO MODIFY CONDITIONS OF RELEASE 
 
COMES NOW the Defendant, Joel Wright, by and through his counsel, Jeffrey Gedbaw, 
and moves this 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 his Pretrial Services 
Officer.  Mr. Wright resides in Texas and is supervised there.  He is only currently permitted to 
travel to the Western District of Missouri for Court or attorney meetings.  In support of this 
motion, Mr. Wright states the following: 
 
1. 
The Defendant was arraigned on February 29, 2024 (Doc. 46).  He has no prior 
criminal history, and the Government did not seek detention.  Mr. Wright’s current conditions of 
release were previously ordered by the United States District Court for the Northern District of 
Texas.  The current conditions limit Mr. Wright’s travel to the “Western and Northern District of 
Texas and directly to and from the Western District of Missouri for Court or consultation of 
counsel.” 
 
2.   
Mr. Wright is asking this Court to modify that previously imposed condition so 
that he can attend the funeral of a family member that is scheduled for Friday, March 29, 2024.  
Specifically, the deceased individual is his stepfather, Earl Cornelius. 
Case 4:24-cr-00029-BP     Document 90     Filed 03/28/24     Page 1 of 3

 
3.   
Mr. Wrigth respectfully moves this Court to modify the previously cited travel 
restrictions 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 of 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. 
 
 
4. 
Based on an email exchange with Mr. Wright’s Pretrial Services Officer in the 
Western District of Missouri, they do not have any objection to this modified language.  
Furthermore, it should be noted that Defendants Daisha Sanders has filed a virtually identical 
motion (Doc. 88), which was granted by the Court (Doc. 89).  Additionally, Defendant Denise 
Sanders filed a virtually identical motion (Doc. 86), which was also granted by the Court (Doc. 
87). 
 
5.   
Counsel for Mr. Wright has consulted with Assistant United States Attorney Paul 
Becker regarding this matter, and Mr. Becker has informed counsel that he has no objection to 
this request. 
 
6. 
Due to the fact that Mr. Wright is charged with a non-violent offense; has no 
criminal history; neither the Pretrial Services Office in Texas or the Pretrial Services Office in 
the Western District of Missouri objects to this request; and identical requests have already been 
granted for two of the other co-defendants in this case, counsel for Mr. Wright requests that this 
Court enter an Order modifying the conditions of release as set forth in paragraph 3, above. 
 
WHEREFORE, for the reasons set forth above, it is requested that this Court modify the 
conditions of the defendant’s bond and grant him authorization to travel to the Kansas City, 
Missouri area, subject to pre-approval of his Pretrial Services Officer. 
 
Case 4:24-cr-00029-BP     Document 90     Filed 03/28/24     Page 2 of 3

 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
/s/ Jeffrey Gedbaw 
 
 
 
 
 
 
 
 
______________________________ 
 
 
 
 
 
 
 
 
Jeffrey Gedbaw, MO Bar No. 56318 
 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
 
618 SE 4th St., Suite 204 
 
 
 
 
 
 
 
 
Lee’s Summit, MO 64063 
 
 
 
 
 
 
 
 
Phone:  
(816) 379-5329 
 
 
 
 
 
 
 
 
Fax: 
 
(816) 272-5967 
 
 
 
 
 
 
 
 
jgedbaw@gedbawlawfirm.com 
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on March 28, 2024, a true copy of the foregoing was served 
on all parties by electronic filing through the ECF system. 
 
 
 
 
 
 
 
 
 
 
/s/ Jeffrey Gedbaw 
 
 
 
 
 
 
 
 
_____________________________ 
 
 
 
 
 
 
 
 
Jeffrey Gedbaw 
 
 
 
 
 
 
  
Case 4:24-cr-00029-BP     Document 90     Filed 03/28/24     Page 3 of 3

File and source

File

gov.uscourts.mowd.174450.90.0.pdf

Size

124,026 bytes

SHA-256

be158ee57912d3304d2783e2372dc18051b8e3422f3a3d6cb679fb267e8cfca6

Our copy

gov.uscourts.mowd.174450.90.0.pdf

Original

PACER (login required)