UNOPPOSED MOTION FOR PREPAREATION OF PRE-PLEA PRESENTENCE REPORT (PSR)

RICHARD F. BOULWARE, II, District Judge.

Defendant Samuel Donesing requests the Court enter an order directing the United States Department of Probation to prepare a Pre-Plea Presentence Investigation Report (PSR) to determine the defendant's Criminal History.

On DATE, Mr. Doensing was charged in a X count indictment with X and Y. The parties are attempting to negotiate this case. The parties believe that they may be able to resolve this case short of trial. Based on defense counsel's review of Mr. Donesing's criminal record, there appear to be a number of issues with respect to how his prior convictions will be counted. To satisfy Mr. Donesing's concerns and to assure that he has the information he needs to make a truly knowing and intelligent decision, as to whether to accept or reject a plea offer, he has requested that a Pre-Plea Presentence Investigation Report be completed so that he understands how Probation will calculate his Criminal History Points and corresponding category. Defense counsel has spoken with AUSA Linda Mott and she does not oppose this motion.

Conclusion

Mr. Donesing respectfully requests the Court order the United States Department of Probation to prepare a Pre-Plea Presentence Investigation Report to determine his Criminal History Points and corresponding Criminal History Category.

[PROPOSED] ORDER

IT IS HEREBY ORDERED, based on the foregoing motion, and good cause appearing, that the United States Department of Probation for the District of Nevada shall prepare a Pre-Plea Presentence Investigation Report (PSR) with respect to Defendant Samuel Lane Donesing's Criminal History Points and Criminal History Category.