MOTION FOR PREPARATION OF PRE-PLEA REPORT AS TO CRIMINAL HISTORY; DECLARATION; PROPOSED ORDER

PEGGY A. LEEN, Magistrate Judge.

TO THE CLERK OF THE ABOVE-ENTITLED COURT, AND TO THE UNITED STATES ATTORNEY FOR THE DISTRICT OF NEVADA, ATTN: ASSISTANT UNITED STATES ATTORNEY SUSAN CUSHMAN:

Defendant Isaias Ruiz-Rodriguez, through counsel, hereby moves the Court for an order for the preparation of a pre-plea report limited to the issue of criminal history. This motion is based on the attached declaration of counsel, and it is believed that the Government does not oppose this motion.

DECLARATION OF MICHAEL IAN GAREY

I, Michael Ian Garey do hereby declare and state:

1. I am an attorney duly licensed in the State of California, and have been approved to appear as defense counsel for Defendant Isaias Ruiz-Rodriguez, pro hac vice in this matter;

2. Preliminary discussions re possible resolution of this matter have begun, and an assessment of the Defendant's criminal history would be of assistance in confirming that he is "safety valve" eligible, pursuant to the provisions of U.S.S.G. section 5C1.2 and 18 U.S.C. 3553(f);

3. I have spoken to A.U.S.A. Susan Cushman, and believe that this motion is unopposed.

I declare under penalty of perjury that the forgoing is true and correct to the best of my knowledge. Executed at Santa Ana, California this 16th day of May, 2018.

ORDER

It is hereby ordered that the Probation Department shall prepare a pre-plea report in this matter, limited to the issue of criminal history.