Opinion
Case No. 2:12-CR-00132-MMD-RJJ
03-05-2013
UNITED STATES OF AMERICA, Plaintiff, v. WILLIAM BONAPARTE, Defendant.
THOMAS F. PITARO, ESQ. Attorney for Defendant WILLIAM BONAPARTE
THOMAS F. PITARO, ESQ.
Attorney for Defendant
WILLIAM BONAPARTE
DEFENDANT'S MOTION TO
CONDUCT A PRE-PLEA PRE-
SENTENCING INVESTIGATION
REPORT AND PROPOSED ORDER
COMES NOW the defendant, WILLIAM BONAPARTE, by and through his attorney of record, THOMAS F. PITARO, ESQ., and hereby moves this Court request a Pre-Plea Presentence Investigation Report be prepared by the Probation department.
1. The defendant is charged in a 10 count Indictment stemming from several alleged armed robberies. The defendant is unsure of his prior convictions and believes that his criminal history could be anywhere from a level 1 to a level 3. The disparity in a potential sentence between these criminal history levels is substantial, and what possible sentence the defendant will face will highly effect negotiations and the ability to work out a potential guilty plea.
2. Undersigned counsel therefore respectfully requests an order that the Department of Probation conduct a pre-plea pre-sentence investigation report to determine the Defendant's criminal history category as soon as possible.
3. Undersigned counsel has spoken to the prosecutor, Assistant United States Attorney Cristina Silva regarding this request and she has no opposition.
________________________
THOMAS F. PITARO, ESQ.
Nevada Bar No. 001332
1212 S. Casino Center Blvd.
Las Vegas, Nevada 89104
Attorney for Defendant
WILLIAM BONAPARTE
UNITED STATES OF AMERICA, Plaintiff,
v.
WILLIAM BONAPARTE, Defendant.
Case No. 2:12-CR-00132-MMD- CWH
ORDER
IT IS HEREBY ORDERED that the Probation Department will prepare a Pre-Plea Presentence Investigation Report on Defendant William Bonaparte.
________________________
C.W. Hoffman Jr.
United States Magistrate Judge