Filed: Nov. 30, 2017
Latest Update: Nov. 30, 2017
Summary: PEGGY A. LEEN , Magistrate Judge . UNOPPOSED MOTION FOR PRE PLEA PRESENTENCE INVESTIGATION REPORT COMES NOW, JESS R. MARCHESE, ESQ., and hereby moves for or Order directing Probation to perform a pre-plea PSR for the Defendant in this case. This Motion is made and based upon the attached Points and Authorities, Declaration of Counsel, and any argument entertained at the hearing on this matter. POINTS AND AUTHORITIES Recently, the undersigned received a written plea offer from the Unite
Summary: PEGGY A. LEEN , Magistrate Judge . UNOPPOSED MOTION FOR PRE PLEA PRESENTENCE INVESTIGATION REPORT COMES NOW, JESS R. MARCHESE, ESQ., and hereby moves for or Order directing Probation to perform a pre-plea PSR for the Defendant in this case. This Motion is made and based upon the attached Points and Authorities, Declaration of Counsel, and any argument entertained at the hearing on this matter. POINTS AND AUTHORITIES Recently, the undersigned received a written plea offer from the United..
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PEGGY A. LEEN, Magistrate Judge.
UNOPPOSED MOTION FOR PRE PLEA PRESENTENCE INVESTIGATION REPORT
COMES NOW, JESS R. MARCHESE, ESQ., and hereby moves for or Order directing Probation to perform a pre-plea PSR for the Defendant in this case. This Motion is made and based upon the attached Points and Authorities, Declaration of Counsel, and any argument entertained at the hearing on this matter.
POINTS AND AUTHORITIES
Recently, the undersigned received a written plea offer from the United States of America. In order to properly counsel the defendant in reference to this plea, counsel would request that this Court order a Pre-Plea Presentence Investigation Report for Mr. Rodriguez-Perez.
Specifically, counsel is concerned that due to previous traffic arrests that Mr. Rodriguez-Perez may have criminal history points that might cause him to be ineligible for the safety valve and/or have an increased criminal history category. Out of an abundance of caution, counsel would like the report done.
In addition, the undersigned has spoken with counsel for the United States of America and he does not oppose this request.
IT IS SO ORDERED.
