Opinion
Case No.: 2:13-cr-00085-APG-PAL
05-15-2013
UNITED STATES OF AMERICA, Plaintiff, v. ALBERT LAFARGA-CRUZ, Defendant.
RENE L. VALLADARES Federal Public Defender MONIQUE KIRTLEY Assistant Federal Public Defender Attorneys for Albert Lafarga-Cruz
RENE L. VALLADARES
Federal Public Defender
MONIQUE KIRTLEY
Assistant Federal Public Defender
Attorneys for Albert Lafarga-Cruz
MOTION TO REQUEST PRE-TRIAL
SERVICES INTERVIEW ALBERT
LAFARGA-CRUZ WITH PROPOSED
ORDER
(Expedited Treatment Requested)
COMES NOW the defendant, Albert Lafarga-Cruz, by and through his counsel of record, Rene L. Valladares, Federal Public Defender, and Monique Kirtley, Assistant Federal Public Defender, counsel for defendant and files this Motion to Request Pre-trial Services to Interview Mr. Lafarga-Cruz for the following reasons.
RENE L. VALLADARES
Federal Public Defender
______________________
MONIQUE KIRTLEY
Assistant Federal Public Defender
MOTION TO REQUEST PRE-TRIAL SERVICES INTERVIEW
ALBERT LAFARGA CRUZ
On April 27, 2013, the defendant, Albert Lafarga-Cruz ("Lafarga"), made an initial appearance before Magistrate Judge Cam Ferenbach. Mr. Lafarga was detained as a flight risk and a danger to the community. It appears from the Order that the Court did not have any verifiable information regarding Mr. Lafarga as he had not interviewed with Pre-trial Services. The undersigned counsel filed a Motion to Re-Open Bail. A hearing on the Motion is scheduled for May 21, 2013 at 10:00 a.m. Prior to the hearing, Mr. Lafarga would like the opportunity to be interviewed by Pre-trial Services. In order to have Mr. Lafarga interviewed, the undersigned respectfully requests that this Court order Pre-trial Services to interview him prior to the 10:00 a.m., on May 21, 2013. Undersigned counsel is including a proposed order that would accomplish what is being requested in this motion.
Respectfully submitted,
RENE L. VALLADARES
Federal Public Defender
______________________
MONIQUE KIRTLEY
Assistant Federal Public Defender
Counsel for Albert Lafarga-Cruz
UNITED STATES OF AMERICA, Plaintiff,
vs. ALBERT LAFARGA CRUZ, Defendant.
Case No.: 2:13-cr-00085-APG-PAL
ORDER
The reasons being sound and in the best interests of justice and judicial economy being served.
IT IS ORDERED that Pre-trial Services if time and resources are available conduct a pre-trial interview on May 21, 2013 prior to 10:00 a.m. and make the report available to the parties and the court on or before May 20, 2013 as quickly as possible.
______________________
UNITED STATES MAGISTRATE JUDGE
CERTIFICATE OF ELECTRONIC SERVICE
The undersigned hereby certifies that she is an employee of the Law Offices of the Federal Public Defender for the District of Nevada and is a person of such age and discretion as to be competent to serve papers.
That on May 14, 2013, she served an electronic copy of the above and foregoing MOTION TO REQUEST PRE-TRIAL SERVICES INTERVIEW ALBERT LAFARGA CRUZ WITH PROPOSED ORDER, (Expedited Treatment Requested), by electronic service (ECF) to the person named below:
DANIEL G. BOGDEN
United States Attorney
SUSAN CUSHMAN
Assistant United States Attorney
333 Las Vegas Blvd. So., 5th Floor
Las Vegas, Nevada 89101
______________________
Employee of the Federal Public Defender