Opinion
2:12-cr-315-JCM-VCF
01-07-2013
UNITED STATES OF AMERICA, Plaintiff, v. MELESIO ARRELLANO-GARCIA, Defendant.
RENE L. VALLADARES Federal Public Defender RAQUEL LAZO Assistant Federal Public Defender
RENE L. VALLADARES
Federal Public Defender
State Bar No. 11479
RAQUEL LAZO
Assistant Federal Public Defender
411 E. Bonneville Avenue, Suite 250
Las Vegas, Nevada 89101
(702) 388-6577
(Fax) 388-6261
Attorneys for ARRELLANO-GARCIA
MOTION TO CONDUCT A PRE-PLEA
INVESTIGATION REPORT AND
PROPOSED ORDER
(First Request)
COMES NOW, appointed counsel, Raquel Lazo, Assistant Federal Public Defender, hereby moves this Court to request a Pre-Plea Pre-Sentence Investigation Report be prepared by the Probation department.
1. There is some uncertainty regarding Mr. Arrellano-Garcia's Criminal History Category. The disposition of many convictions remains unclear. Undersigned counsel has requested documents pertaining to these prior convictions but no responses have been received. This has made it difficult to narrow down the Criminal History Category.
2. Mr. Arrellano-Garcia is requesting a pre-plea presentence report in order to have a better idea of his Criminal History Category score. He believes that this will help him decide as to whether he will proceed with a plea agreement or without the benefit of an agreement.
3. Defense counsel recognizes that the Department of Probation is extremely busy. Therefore, should this court grant Mr. Arrellano-Garcia's request, he is willing to provide them with as much time as necessary to complete the presentence report. Indeed, a stipulation to continue the trial in this matter for another ninety (90) days is being filed contemporaneously with this motion.
RENE L. VALLADARES
Federal Public Defender
By: _____________
RAQUEL LAZO
Assistant Federal Public Defender
UNITED STATES OF AMERICA, Plaintiff, v. MELESIO ARRELLANO-GARCIA, Defendant.
2:12-cr-315-JCM-VCF
ORDER
No opposition having been filed and good cause appearing,
IT IS HEREBY ORDERED that the Probation Department will prepare a Pre-Plea Investigation Report on Defendant MELESIO ARRELLANO-GARCIA.
____________________
CAM FERENBACH
UNITED STATES MAGISTRATE JUDGE
CERTIFICATE OF ELECTRONIC SERVICE
The undersigned hereby certifies that she is an employee of the Law Offices of the Federal Public Defender for the District of Nevada and is a person of such age and discretion as to be competent to serve papers.
That on December 13, 2012, she served an electronic copy of the above and foregoing MOTION TO CONDUCT A PRE-PLEA INVESTIGATION REPORT AND PROPOSED ORDER by electronic service (ECF) to the person named below:
DANIEL BOGDEN
United States Attorney
333 Las Vegas Blvd. So., 5th Floor
Las Vegas, Nevada 89101
ROBERT BORK
Assistant United States Attorney
333 Las Vegas Blvd. So. 5th Floor
Las Vegas, NV 89101
Maribel Bran
Employee of the Federal Public Defender