Filed: Oct. 22, 2019
Latest Update: Oct. 22, 2019
Summary: UNOPPOSED MOTION FOR ORDER DIRECTING DEPARTMENT OF PROBATION TO PREPARE A PLEA-PLEA PSR (CRIMINAL HISTORY ONLY) DANIEL J. ALBREGTS , Magistrate Judge . Certification: This motion is timely filed. Comes now the defendant, Gustavo Arechiga, by and through his counsel of record, William Brown, of BROWN MISHLER, PLLC, and hereby moves this court for an order requesting the department of probation to prepare a pre-plea PSR (criminal history only). This request is based on the Points and Authori
Summary: UNOPPOSED MOTION FOR ORDER DIRECTING DEPARTMENT OF PROBATION TO PREPARE A PLEA-PLEA PSR (CRIMINAL HISTORY ONLY) DANIEL J. ALBREGTS , Magistrate Judge . Certification: This motion is timely filed. Comes now the defendant, Gustavo Arechiga, by and through his counsel of record, William Brown, of BROWN MISHLER, PLLC, and hereby moves this court for an order requesting the department of probation to prepare a pre-plea PSR (criminal history only). This request is based on the Points and Authorit..
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UNOPPOSED MOTION FOR ORDER DIRECTING DEPARTMENT OF PROBATION TO PREPARE A PLEA-PLEA PSR (CRIMINAL HISTORY ONLY)
DANIEL J. ALBREGTS, Magistrate Judge.
Certification: This motion is timely filed.
Comes now the defendant, Gustavo Arechiga, by and through his counsel of record, William Brown, of BROWN MISHLER, PLLC, and hereby moves this court for an order requesting the department of probation to prepare a pre-plea PSR (criminal history only). This request is based on the Points and Authorities attached hereto.
MEMORANDUM OF POINTS AND AUTHORITIES
Counsel has discussed the case with his client, Gustavo Arechiga, and the different ways in which his criminal history may impact the sentence, if any, he may ultimately receive. Given the potential for Armed Career Criminal designation, counsel respectfully requests an order from this Court requesting the United States Probation Office (USPO) to prepare a "pre-plea1 PSR," detailing Arechiga's prior convictions. Counsel does not seek preparation of a complete PSR, but rather what typically appears as "Part B" (Defendant's Criminal History).
Counsel has communicated with USPO Officer Wendy Beckner, met with Beckner in person to review the criminal history information currently in the USPO's possession, and discussed with Beckner the circumstances involved in this case necessitating the USPO's pre-plea involvement. The government does not oppose preparation of a pre-plea PSR.
