Motion for order Return of Passport Post-Sentencing — USA v. Sanders et al. (Dkt. 298)

Summary

Defendant Rashonda Golden's request for return of passport in United States of America v. Rashonda Golden, No. 24-00029-04-CR-W-BP, in the U.S. District Court for the Western District of Missouri, Western Division, filed August 13, 2025 as Document 298. The motion states that Golden was recently sentenced to probation and that Pretrial Services has advised the passport will be sent to the Dept. of State if not ordered returned within the next week. It states that Golden has no current international travel plans but lives and works in California, where a passport is needed for many transactions. It asks the Court to allow Pretrial Services to return the passport and is signed by David A. Kelly of Kelly & Jansen, LLC.

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DEFENDANT’S MOTION FOR ORDER – 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 FOR RETURN OF PASSPORT 
 
COMES NOW the Defendant, Rashonda Golden, by and through her counsel, and hereby 
requests an order of this Court for the return of Defendant’s passport.  Pretrial Services has 
advised Defendant’s passport will be sent to the Dept. of State if not ordered back to the 
Defendant in the next week.  The Defendant was recently sentenced to probation.  The 
Defendant does not know of any reason why she cannot be possessed of her passport at this time.  
The Defendant has no international travel plans currently but the Defendant lives and works in 
California and a passport is a necessary document for many transactions in California.   
WHEREFORE, the Defendant Rashonda Golden prays for an order of this Honorable 
Court allowing Pretrial Services to return the Defendant’s passport and for any and all other 
relief this Court deems just and proper upon these premises.   
 
 
 
 
 
 
 
Case 4:24-cr-00029-BP     Document 298     Filed 08/13/25     Page 1 of 2

DEFENDANT’S MOTION FOR ORDER – Page 2 
 
Respectfully submitted, 
 
/S/ DAVID A. KELLY 
 
David A. Kelly (MO #45983) 
Kelly & Jansen, LLC 
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 298     Filed 08/13/25     Page 2 of 2

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