Opinion
2:08-cr-00342-MCE
09-01-2011
Jill M. Thomas ASSISTANT UNITED STATES ATTORNEY ATTORNEY FOR THE PLAINTIFF James R. Gremer Attorney for Defendant CALVIN TRUONG
JAMES R. GREINER, ESQ.
CALIFORNIA STATE BAR NUMBER 123357
LAW OFFICES OF JAMES R. GREINER
ATTORNEY FOR DEFENDANT
CALVIN TRUONG
STIPULATION AND AGREEMENT
BY THE PARTIES THAT PROBATION
DO A PRE-PLEA INVESTIGATION
REPORT INCLUDING A
DETERMINATION OF THE
DEFENDANT'S CRIMINAL HISTORY
Plaintiff United States of America, by its counsel, Assistant United States Attorneys, Ms. Jill M. Thomas, and defendant CALVIN TRUONG, by his attorney James R. Greiner, hereby jointly request and stipulate that this Court may sign the Proposed Order, Ordering Probation to prepare a full and complete pre-plea investigation including, but not limited to, a criminal History background investigation to determine the defendant's criminal history level.
Respectfully submitted,
BENJAMIN B. WAGNER
UNITED STATES ATTORNEY
Jill M. Thomas by in person authorization
Jill M. Thomas
ASSISTANT UNITED STATES ATTORNEY
ATTORNEY FOR THE PLAINTIFF
James R. Gremer
Attorney for Defendant CALVIN TRUONG
ORDER
Based upon the representations of counsel, the record in this case, and the agreements and stipulations between counsel in the case, and that
The parties agree and stipulate that this Court may make the requested Order:
It is hereby Ordered that the Probation Department prepare a full and complete pre-plea investigation including, but not limited to, a criminal History background investigation to determine the defendant's criminal history level.
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE