Opinion
2:20-CR-00124-JCM-BNW
01-26-2023
UNITED STATES OF AMERICA, Plaintiff, v. BRANDSON CABRAL, Defendant.
MONTI JORDANA LEVY, ESQ. Nevada Bar No. 8158 WRIGHT MARSH & LEVY Attorneys for Defendant Brandson Cabral
MONTI JORDANA LEVY, ESQ. Nevada Bar No. 8158 WRIGHT MARSH & LEVY Attorneys for Defendant Brandson Cabral
UNOPPOSED MOTION FOR PRE-PLEA PRESENTENCE REPORT
BRANDSON CABRAL, by and through his attorney, MONTI JORDANA LEVY, of WRIGHT MARSH & LEVY, respectfully moves this Honorable Court to order the Department of Probation to prepare a pre-plea presentence report to assist the parties in negotiating the instant case.
Defense counsel has met and conferred with the Government prior to filing this motion. The assigned AUSA has indicated that the Government will not oppose the instant motion.
MEMORANDUM OF POINTS AND AUTHORITIES
Defendant Brandson Cabral is charged by Indictment with one count of Felon in Possession of Firearm. The Government and Mr. Cabral's counsel have been discussing potential negotiations in this matter; however, there are some areas of confusion regarding his prior criminal history and the calculations of credit between state and federal offenses. Counsel believes that once a true calculation of Mr. Cabral's criminal history and an accurate determination of when his sentences had been completed is prepared that the parties will be able to meaningfully discuss resolving the case.
To ensure that Mr. Cabral has all of the information he needs to make a knowing and intelligent decision as to whether to enter into plea negotiations with the Government, he respectfully requests that a Pre-plea Presentence Investigation Report be prepared.
Mr. Cabral's counsel has spoken with the assigned AUSA, Edward Veronda, who stated that he does not oppose this request.
ORDER
IT IS HEREBY ORDERED that the United States Probation office prepare a Pre-Plea Presentence Investigation Report with respect to Defendant Brandson Cabral's criminal history points and corresponding criminal history.