Opinion
CASE NO.: 2:12-cr-00360-JCM-VCF
02-22-2013
UNITED STATES OF AMERICA Plaintiff, v. ROBERT PEREZ, et al., Defendant.
PHIL BROWN, ESQ. Nevada Bar No. 6240 BROWN LAW OFFICES Attorney for Defendant Joanna Perez
PHIL BROWN, ESQ.
Nevada Bar No. 6240
BROWN LAW OFFICES
Attorney for Defendant Joanna Perez
DEFENDANT JOANNA PEREZ'S
UNOPPOSED MOTION TO CONDUCT
A PRE-PLEA PRESENTENCING
INVESTIGATION REPORT AND
PROPOSED ORDER
Comes now, appointed counsel Phil Brown Esq., and hereby moves this Court request a Pre-Plea Pre-Sentence Investigation Report be prepared by the Probation department.
1) It appears that defendant has no criminal history and may be eligible for a sentence outside the applicable United States Sentencing Guideline (U.S.S.G.) range pursuant to U.S.S.G. § 5C1.2, 18 U.S.C § 3553(f) and U.S.S.G. § 2D1.1(b)(6). Whether the defendant is eligible for the Safety Valve will drastically impact her sentencing exposure, negotiations, and client's decision as to how she should proceed. A pre-plea presentence report will promote judicial economy and aid in the manner in which this case is ultimately resolved.
2) Undersigned counsel therefore respectfully requests an order that the Department of Probation conduct a pre-plea presentence investigation report as soon as possible.
3) Undersigned counsel has spoken to the prosecutor, Assistant United States Attorney Robert Knief regarding this request and he has no opposition.
_____________
PHIL BROWN, ESQ.
200 HOOVER AVE, UNIT #130
LAS VEGAS, NEVADA 89101
ATTORNEY FOR THE DEFENDANT
SCOTT WEST
PHIL BROWN, ESQ.
Nevada Bar No. 6240
BROWN LAW OFFICES
200 Hoover Ave., Unit 130
Las Vegas, NV 89101
Telephone (702) 405-0505
Facsimile (866) 215-8145
Thelasvegasdefender@gmail.com
Attorney for Defendant - Joanna Perez
UNITED STATES OF AMERICA Plaintiff,
vs. ROBERT PEREZ, et. al., Defendant.
CASE NO.: 2:12-CR-360
ORDER GRANTING DEFENDANT
JOANNA PEREZ'S MOTION FOR
PRE-PLEA PRESENTENCE REPORT
IT IS HEREBY ORDERED that the Probation Department will prepare a Pre-Sentence Investigation Report on Defendant Joanna Perez.
_____________
U.S. DISTRICT JUDGE
MAGISTRATE
CERTIFICATE OF SERVICE
The undersigned hereby certifies that he is an employee of Brown Law Offices, Chartered, and is a person of such age and discretion as to be competent to serve papers.
That on February 5, 2013, he served an electronic copy of the above and foregoing UNOPPOSED MOTION TO CONDUCT A PRE-PLEA PRESENTENCING INVESTIGATION REPORT by electronic service (ECF) to the person named below:
DANIEL BOGDON
United States Attorney
ROBERT KNIEF
Assistant United States Attorney
333 Las Vegas Blvd. So., 5th Floor
Las Vegas, NV 89101
Philip H. Brown
Employee of Brown Law Offices, Chartered