MOTION for extension of time to file objections to Presentence Investigation Report… — USA v. Sanders et al (Dkt. 217)

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. 217 · 2025-01-31 · Docket on CourtListener

Summary

A motion to extend the deadline to file objections to the presentence investigation report, filed January 31, 2025 as Document 217 in United States of America v. Sanders et al, No. 4:24-cr-00029-BP, in the U.S. District Court for the Western District of Missouri. It is filed for defendant Kiandra Crowe by Assistant Federal Public Defender Robert Kuchar and asks that the deadline be extended until February 18, 2025. The supporting suggestions state that a February 6, 2024 indictment charged the defendant under 18 U.S.C. § 1349 in Count 1 and 18 U.S.C. § 1343 in Count 7, and that the defendant pleaded guilty to count 1 on November 20, 2024. They state that the objection deadline was January 29, 2025 and that counsel needs more time to review the presentence report with the defendant.

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Full text

IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA,  
) 
) 
Plaintiff, 
 
) 
) 
v. 
 
 
 
 
 
) 
Case No. 24-00029-06-CR-BP 
 
 
 
 
 
 
 
) 
KIANDRA CROWE, 
 
) 
) 
Defendant. 
 
) 
MOTION TO EXTEND DEADLINE TO FILE PSI OBJECTIONS 
 
 
COMES NOW the defendant, Kiandra Crowe, through his counsel, Robert Kuchar, 
Assistant Federal Public Defender for the Western District of Missouri and moves this Court to 
extend the deadline for filing Objections to the PSI until February 18, 2025. 
 
SUGGESTIONS IN SUPPORT 
1. 
On February 6, 2024, an indictment was filed charging defendant with violations 
of 18 U.S.C. § 1349 (Conspiracy to Commit Wire Fraud) in Count 1; and 18 U.S.C. § 1343 (Wire 
Fraud) in Count 7 of the indictment. 
2. 
On February 22, 2024, the defendant appeared before the Honorable W. Brian 
Gaddy, United States Magistrate Judge, for an initial appearance and bond hearing, and the office 
of the Federal Public Defender was appointed to represent the defendant. 
3. 
On February 29, 2024, the defendant appeared before the Honorable Lajuana M. 
Coumts, United States Magistrate Judge, for an arraignment 
4. 
On November 20, 2024, defendant plead guilty to count 1 of the indictment. 
5. 
The preliminary PSI was completed and the deadline to make objections is on 
January 29, 2025. 
6. 
Additional time is needed for the undersigned counsel to meet with the defendant 
Case 4:24-cr-00029-BP     Document 217     Filed 01/31/25     Page 1 of 2

2 
 
and review the presentence report with him. 
WHEREFORE, the defendant, Kiandra Crowe, respectfully requests this Court extend the 
deadline for filing Objections to the PSI until February 18, 2025. 
 
 
 
 
 
 
Respectfully submitted, 
 
/s/ Robert Kuchar 
 
 
 
 
 
 
 
 
 
 
ROBERT KUCHAR 
Assistant Federal Public Defender 
1000 Walnut, Suite 600 
Kansas City, MO 64106 
(816) 471-8282 
 
 
 
 
 
 
 
 
 
CERTIFICATE OF SERVICE 
 
In accordance with Rule 49(a), (b) and (d), Fed. R. Crim. P., and Rule 5(b), Fed. R. Civ. 
P., it is hereby CERTIFIED that the foregoing motion was electronically filed and emailed to all 
interested parties on this 31st day of January 2025. 
/s/ Robert Kuchar           
                
 
 
 
ROBERT KUCHAR 
Case 4:24-cr-00029-BP     Document 217     Filed 01/31/25     Page 2 of 2

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