Second MOTION for extension of time to file objections to Presentence Investigation… — USA v. Sanders et al (Dkt. 222)

Summary

Defendant Daisha Sanders's second unopposed motion for extension of time to file objections to the preliminary presentence investigation report in United States of America v. Daisha Sanders, Case No. 24-00029-01/11-CR-W-BP, in the U.S. District Court for the Western District of Missouri, filed February 14, 2025 as Document 222. It states that the report was distributed on January 17, 2025, that objections were due January 31, 2025, and that the government has since responded with its objection and additional information affecting the guideline range. Counsel Katrina Y. Robertson states that Probation Officer Jeremy Thomas has no objection and that no response has come from Assistant U.S. Attorney Paul Becker. The motion cites Local Rule 99.8.L and asks to extend the deadline to February 28, 2024.

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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. 24-00029-01/11-CR-W-BP  
 
 
 
 
  
 
) 
DAISHA SANDERS, 
 
 
) 
 
 
 
 
 
 
) 
 
 
 
Defendant.   
) 
 
 DEFENDANT’S SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME  
TO FILE OBJECTIONS TO THE PRELIMINARY SENTENCE REPORT 
 
 
Defendant, Daisha Sanders, by and through counsel, moves the Court for an Order 
of extension of time in which to file objections to the preliminary Presentence Investigation 
Report. In support, Defendant states:   
1.   
On January 17, 2025 the United States Probation Office prepared and 
distributed Defendant’s preliminary presentence investigation report.   
2. 
On January 31, 2025, Defendant’s written objections were due.   
3.    
Since the filing of Defendant’s motion for an extension, the Government has 
responded with its objection and additional information.      
4.    
Counsel is currently attending a CLE out of state and has not had an 
opportunity to review the information with her client.  Further research is necessary 
concerning the Government’s position which impacts Defendant’s guideline range.        
5.    
Defense counsel has discussed this request with Assistant United States 
Attorney Paul Becker.   Counsel has not received a response.  
6. 
The United States Probation Officer, Jeremy Thomas, indicates that he has 
no objection.   
Case 4:24-cr-00029-BP     Document 222     Filed 02/14/25     Page 1 of 2

7.    
Local Rule 99.8.L provides for a modification of the time limits set forth in 
the rule upon a showing of good cause.   
8.    
Defendant respectfully suggests that good cause exists for such an extension 
of time.  
WHEREFORE, Defendant requests an Order of the Court extending the time for 
any defense objections to the preliminary presentence investigation report to February 28, 
2024.   
 
 
 
 
 
 
 
Respectfully submitted,  
 
 
 
 
 
 
 
KATRINA Y. ROBERTSON, LLC  
 
 
 
 
 
 
 
 
 
       /s/ Katrina Y. Robertson_______ 
Katrina Y. Robertson, MBN 61289 
The Cable Building 
1321 Burlington, Suite 600 
North Kansas City, Missouri 64116 
Office: 816-885-4974 
Facsimile: 816-817-4964 
krobertson@kyrobertsonlaw.com 
 
Attorney for Daisha Sanders  
CERTIFICATE OF SERVICE 
 
The undersigned hereby certifies that a copy of the foregoing was delivered on 
February 14, 2025 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 222     Filed 02/14/25     Page 2 of 2

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