Opinion
2:12-CR-488-LDG-VCF
04-29-2013
United States of America, Plaintiff, v. Katherine Kaplan, Defendant.
DANIEL G. BOGDEN United States Attorney DANIEL R. SCHIESS Assistant United States Attorney
DANIEL G. BOGDEN
United States Attorney
DANIEL R. SCHIESS
Assistant United States Attorney
333 Las Vegas Boulevard, Suite 5000
Las Vegas, Nevada 89101
(702)388-6336
Attorneys for Plaintiff
United States of America
MOTION FOR DOWNWARD
DEPARTURE
The United States, by and through Daniel G. Bogden, United States Attorney, and Daniel R. Schiess, Assistant United States Attorney, moves for the court to grant the defendant a two-level downward departure for having provided substantial assistance. The defendant met with the FBI four times and provided information about the fraudulent scheme in which she was involved and is the basis of her conviction. The defendant's information was consistent with other information possessed by the FBI. The information may help the FBI advance the investigation of this matter.
DANIEL G. BOGDEN
United States Attorney
____________
DANIEL R. SCHIESS
Assistant United States Attorney
Certificate of Service
I certify that a copy of the foregoing motion was served on defense counsel of record through the court's electronic filing system.
____________
Daniel R. Schiess
ORDER
IT IS SO ORDERED.
____________
Lloyd D. George
Sr. U.S. District Judge