Court filing
Motion to continue Sentencing Hearing — USA v. Sanders et al. (Dkt. 232)
Filed February 28, 2025 in Sanders; one of 83 filings from this case.
Record facts
| Court | U.S. District Court records for the Western District of Missouri and Western District of Washington |
|---|---|
| Filed | 2025-02-28 |
U.S. District Court records for the Western District of Missouri and Western District of Washington · No. 4:24-cr-00029-BP · Doc. 232 · 2025-02-28 · Docket on CourtListener
Full text
DEFENDANT’S REQUEST TO CONTINUE SENTENCING– Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION UNITED STATES OF AMERICA, § Plaintiff, § § VS. § NO. 24-00029-04-CR-W-BP § RASHONDA GOLDEN, § Defendant. § § DEFENDANT’S REQUEST TO CONTINUE SENTENCING COMES NOW the Defendant, Rashonda Golden, by and through her counsel, and hereby requests that the Court continue sentencing in the case for approximately 60 days to a date and time to be agreed by the parties. Sentencing is presently scheduled for March 6, 2025, at 11:00 a.m. In support thereof, Defendant states as follows: 1. The Defendant, Rashonda Golden, was arrested on the instant case and granted pretrial release pending disposition. Ms. Golden thereafter pled guilty to one count of Conspiracy to Commit Wire Fraud carrying a sentencing range of 0 to 20 years. Ms. Golden pled with a written plea agreement and there are no objections to the PSR. 2. The Defendant previously lived in the Pacific Northwest. Due to a relationship unexpectedly ending, the Defendant was recently forced to relocate to the Los Angeles, California area where she has started a new job and cares for her preteen son as a single mother. 3. The Defendant is having difficulty at the current time in securing care for her son while she attends sentencing here in Kansas City and, moreover, the Defendant is currently without sufficient funds to finance travel and lodging to and from Kansas City, Missouri due to the expense of her relocation and starting a new job. Case 4:24-cr-00029-BP Document 232 Filed 02/28/25 Page 1 of 2 DEFENDANT’S REQUEST TO CONTINUE SENTENCING– Page 2 4. The government has been made aware of Defendant’s request and has no objection. 5. The Defendant is anxious to get the case concluded but is not presently situated to get herself back to the Kansas City area for sentencing next week. The Defendant is not seeking to be obstreperous and remains transparent in her challenges leading to this formal request for a brief extension of sentencing. Based upon the foregoing, Ms. Golden requests that this Honorable Court continue her sentencing date consistent with the suggestions contained in this motion and for any other relief deemed proper by the Court. Respectfully submitted, /S/ DAVID A. KELLY David A. Kelly (MO #45983) Kelly, Reed & Jansen 114 Southwest Third Street Lee’s Summit, MO 64063 (816) 347-1818 FAX (816) 347-1854 dave@mokanlegal.com ATTORNEY FOR DEFENDANT CERTIFICATE REGARDING SERVICE I hereby certify that it is my belief and understanding that counsel for plaintiff as well as all counsel for all co-defendants are participants in the Court’s CM/ECF program and that separate service of the foregoing document is not required beyond the Notification of Electronic Filing to be forwarded upon the filing of the foregoing document. Copies of each document have been provided to opposing counsel via email as well. /s/ David A. Kelly David A. Kelly, Attorney for Defendant Case 4:24-cr-00029-BP Document 232 Filed 02/28/25 Page 2 of 2
File and source
- File
- gov.uscourts.mowd.174450.232.0.pdf
- Size
- 171,800 bytes
- SHA-256
- f044971aa0391b3d2918e4fd837e4b361bbfce114c3814b3f7cdfd02a57c90df
- Original
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