Whether a constructive variance or improper venue can serve as grounds for overturning a federal criminal conviction for wire fraud and money laundering conspiracy

No question identified. : 2. On April 21, 2024, Ms. Saunders was convicted in the United States District Court for the Western District of Tennessee on one count of Conspiracy to Commit Wire Fraud under 18 U.S.C. §1349, and one (1) count of Conspiracy to Commit Money Laundering under 18 U.S.C. §1956(h). 3. On appeal, in addition to arguing that the evidence was insufficient to support her convictions, Ms. Saunders also argued that the proof at trial constituted a constructive variance or amendment from the indictment, and that venue was improper in the United States District Court for the Western District of Tennessee. 4. Ms. Saunders’ deadline for an Application for Writ of Certiorari is currently June 9, 2025. 5. Good cause exists for an extension. Since the Sixth Circuit Court of Appeals ruling, counsel has been handling an unusually heavy caseload consisting of both criminal and civil cases in the State of Tennessee, and Federal Court along with several appeals to the United States Court of Appeals for the Sixth Circuit all appointed under the Criminal Justice Act. Sufficient ground exists, and Ms. Saunders respectfully requests this Court grant her a 60day extension of the deadline to file a Petition for Writ of Certiorari to the Sixth Circuit Court of Appeals to up to and including August 8, 2025. Respectfully submitted this 29" day of May 2025 /s/ Mark E. Brown Mark E. Brown (BPR #021851) MENEFEE & BROWN, P.C. 2633 Kingston Pike, Ste. 100 Knoxville, Tennessee 37919 Phone: (865) 357-9800 Fax: (865) 357-9810 e-mail: Attorney for the Petitioner CERTIFICATE OF SERVICE I hereby certify that on this 29" day of May 2025, a true and exact copy of this document has been served via this Court’s electronic filing system. Service is made on all parties appearing on this Court’s electronic service certificate. All parties in interest may access this pleading via ECF. Service is also made on the OFFICE OF THE SOLICITOR GENERAL OF THE UNITED STATES, UNITED STATES DEPARMENT OF JUSTICE, ROOM 5616, 950 PENNSYLVANIA. AVENUE, N.W., WASHINGTON, D.C. 20530-0001, by placing the same in the United States Mail, first class postage prepaid. /s/ Mark E. Brown Mark E. Brown