Opinion
CASE NO. 2:11-cr-00379-GMN-CWH
03-12-2013
UNITED STATES OF AMERICA, Plaintiff, v. DAVID TORRADO, Defendant.
CRAIG W. DRUMMOND, ESQ.
CRAIG W. DRUMMOND, ESQ.
DEFENDANT'S MOTION FOR A
PRE-PLEA PRESENTENCE
INVESTIGATION REPORT
COMES NOW, the Defendant by and through his appointed attorney of record, Craig W. Drummond, Esq., and moves this Honorable Court to direct that a Pre-Plea Presentence Investigation Report be prepared in this matter by the U.S. Probation Office.
This request is made for the following reasons:
1. The Defendant does have a prior criminal history and as such, he may be subject to substantially different sentencing ranges based on his criminal history and other factors surrounding the offenses and plea.
2. Defendant's decision regarding to plead or proceed to trial in this matter may be significantly affected by his exposure in this regard.
3. This request is made so that Defendant may have the advice and assistance of effective counsel reviewing his actual sentencing exposure based on his verified criminal history.
4. The preparation and review of the report in this matter will promote judicial economy and aid in the matter which this case may be ultimately resolved.
WHEREFORE, the Defendant requests this Honorable Court Order that the U.S. Probation Office prepare a Pre-Plea Presentence Investigation Report in this matter as soon as possible.
Respectfully Submitted,
CRAIG W. DRUMMOND, ESQ.
Nevada Bar No. 011109
228 South Fourth St., First Floor
Las Vegas, NV 89101
T: (702)366-9966
F: (702) 508-9440
craig@urummondfirm.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 11 day of March, 2013, the undersigned served the foregoing Defendant's Motion for Pre-Plea Presentence Investigation Report on all counsel herein by causing a true copy thereof to be filed with the Clerk of Court using the CM/ECF system, which was served via electronic transmission by the Clerk of Court pursuant to local order
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Employee of CRAIG W. DRUMMOND, P.C.
IT IS SO ORDERED.
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UNITED STATES MAGISTRATE JUDGE