Motion to modify conditions of release Defendant's Unopposed Motion — USA v. Sanders et al. (Dkt. 230)

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. 230 · 2025-02-25 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
 
 
UNITED STATES OF AMERICA 
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Plaintiff, 
 
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v. 
 
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Case No. 4:24-cr-00029-BP 
 
ROXANNE NAZIR 
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Defendant. 
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DEFENDANT’S UNOPPOSED MOTION  
TO MODIFY CONDITIONS OF RELEASE 
 
COMES NOW undersigned counsel, Matthew T. Merryman, on behalf of the Defendant 
Roxanne Nazir (“Defendant”), and requests this Court to modify the conditions of release to 
allow the Defendant to apply for an automotive loan. 
SUGGESTIONS IN SUPPORT 
1. 
On February 6, 2024, Roxanne Nazir was named along with ten co-defendants in 
a thirteen count Indictment alleging conspiracy to commit wire fraud. 
2. 
On Feburary 26, 2025, the Court set Conditions of Release, which ordered 
Defendant to not incur new debit or open new lines of credit without court approval. (Dkt. No. 
22).  
3. 
On October 3, 2024, the Defendant changed her plea to guilty on Count VI of the 
Indictment. 
4. 
The Defendant’s sentencing is scheduled for April 3, 2025. 
5. 
The Defendant has been experiencing problems with her automobile and needs to 
purchase a new vehicle. 
Case 4:24-cr-00029-BP     Document 230     Filed 02/25/25     Page 1 of 3

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6. 
The Defendant needs an automotive loan in order to purchase a new vehicle and 
respectfully requests this Court to modify the conditions of release to allow the Defendant to 
obtain a loan in order to purchase a new vehicle. 
7. 
On February 25, 2025, Counsel conferred with AUSA Paul Becker and the United 
States of America does not oppose this request for a modification of the conditions of release. 
8. 
This Unopposed Motion to Modify Conditions of Release is made in good faith 
and not to burden or unduly delay the Court or United States of America. 
WHEREFORE, Counsel for Defendant respectfully requests that this Court modify 
conditions of release as outlined above in order to allow the Defendant to obtain an automotive 
loan in order to purchase a new vehicle. 
Dated: 
February 25, 2025 
 
 
THE BATES & MERRYMAN LAW FIRM LLC 
/s/ Matthew T. Merryman  
 
Matthew T. Merryman 
The Bates & Merryman Law Firm LLC 
P.O. Box 10282 
Kansas City, MO 64111 
816-223-4482 
mmerryman@bmmblaw.com  
Case 4:24-cr-00029-BP     Document 230     Filed 02/25/25     Page 2 of 3

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CERTIFICATE OF SERVICE 
I hereby certify that on February 25, 2025, a copy of the foregoing Defendant’s 
Unopposed Motion to Modify Conditions of Release, was filed electronically. Notice of this 
filing will be sent to all parties by operation of the Court’s electronic filing system. Parties may 
access the filing through the Court’s Electronic Case Filing System. 
/s/Matthew T. Merryman 
 
Matthew T. Merryman 
 
Case 4:24-cr-00029-BP     Document 230     Filed 02/25/25     Page 3 of 3

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