Filed: Jan. 30, 2015
Latest Update: Jan. 30, 2015
Summary: UNOPPOSED MOTION FOR THE PREPARATION OF PRE-PLEA PRESENTENCE REPORT (PSR) AND ORDER GLORIA M. NAVARRO, Chief District Judge. COMES NOW the defendant, Derrick Anthony Woodfin, by and through his counsel of record, Rachel Korenblat, Assistant Federal Public Defender, and files this Motion for the Preparation of Pre-Plea Presentence Report (PSR). This pleading is based upon the attached Memorandum of Points and Authorities and all of the papers and pleadings on file herein. POINTS AND AUTHORI
Summary: UNOPPOSED MOTION FOR THE PREPARATION OF PRE-PLEA PRESENTENCE REPORT (PSR) AND ORDER GLORIA M. NAVARRO, Chief District Judge. COMES NOW the defendant, Derrick Anthony Woodfin, by and through his counsel of record, Rachel Korenblat, Assistant Federal Public Defender, and files this Motion for the Preparation of Pre-Plea Presentence Report (PSR). This pleading is based upon the attached Memorandum of Points and Authorities and all of the papers and pleadings on file herein. POINTS AND AUTHORIT..
More
UNOPPOSED MOTION FOR THE PREPARATION OF PRE-PLEA PRESENTENCE REPORT (PSR)
AND ORDER
GLORIA M. NAVARRO, Chief District Judge.
COMES NOW the defendant, Derrick Anthony Woodfin, by and through his counsel of record, Rachel Korenblat, Assistant Federal Public Defender, and files this Motion for the Preparation of Pre-Plea Presentence Report (PSR). This pleading is based upon the attached Memorandum of Points and Authorities and all of the papers and pleadings on file herein.
POINTS AND AUTHORITIES
On December 31, 2014, Derrick Woodfin was charged in a Criminal Indictment with violation of 49 U.S.C. § 46504, Interference with Flight Crew. On January 6, 2015, Mr. Woodfin made his initial appearance and entered his plea of not guilty to the charge in the indictment.
The parties are in the process of attempting to negotiate this case. Based on the undersigned's review of Mr. Woodfin's criminal record there is a concern that he may qualify as a career offender, which would cause him to face a significant amount of custodial time. Undersigned counsel has communicated with Assistant United States Attorney, Alexandra Michael, and she does not oppose this request for a pre-plea presentence investigation.
To satisfy Mr. Woodfin's concerns and to assure that he has the information he needs to make a truly knowing and intelligent decision about how to proceed with his case, he has requested that a Pre-Plea Presentence Investigation Report be completed to determine if his prior convictions will trigger the sentencing enhancements pursuant to the the career offender provisions in the Sentencing Guidelines.
CONCLUSION
Therefore, Mr. Woodfin respectfully request that this Honorable Court enter an Order directing that the United States Department of Probation prepare a Pre-Plea Presentence Investigation Report to determine Mr. Woodfin's criminal history.
ORDER
IT IS HEREBY ORDERED that the United States Probation Office shall prepare and provide to the Court by March 31, 2015, a Pre-Plea Presentence Investigation Report calculating Derrick Anthony Woodfin's criminal history.
