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P. v. Ladd
This is the fifth appeal in a series involving two separate criminal convictions. While on probation in both cases, defendant Kathleen Margaret Ladd requested the trial court by motion to determine her ability to pay certain fines and fees that had previously been imposed. The trial court deferred that determination, the subject of another appeal, but then 13 months later concluded that Ladds probation supervision fees should be reduced and found that she had the ability to pay $25 per month on each case. After that order, the subject of another appeal that is still pending,[1] Ladd sought to suspend her obligation to pay monthly fees until such time as she could become gainfully employed and thereby earn sufficient discretionary income to pay the fees. The trial court denied that request, and, without notice and over objection, granted the Peoples oral request at the hearing to extend Ladds term of probation by two years, ostensibly because at the ordered rate of payment, she would still owe fines and fees one year laterthe end of her initially imposed three-year probation term. In the instant appeal, Ladd challenges the order extending her probation term. Concluding that the court did not comply with applicable statutory requirements concerning the modification of probation, Court reverse.

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