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The United States of America v. German Alvarez-Ortega

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


September 12, 2012

THE UNITED STATES OF AMERICA,
PLAINTIFF,
v.
GERMAN ALVAREZ-ORTEGA, ET AL DEFENDANTS.

The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge

STIPULATION AND [PROPOSED] ORDER TO PROBATION TO PREPARE ) REPORT REGARDING THE CRIMINAL HISTORY OF ALVAREZ-ORTEGA

Judge: Hon. Garland E. Burrell

Several issues concerning the criminal history of German Alvarez-Ortega, such as eligibility for the USSG section 5C1.2 "safety valve," cannot be determined with the information presently known by the prosecution and the defense. The information is needed before the parties can continue meaningful negotiations.

It is hereby requested by the parties, Daniel McConkie, Assistant United States Attorney,

and Michael Long, attorney for German Alvarez-Ortega, that the court order the United States

Probation Office to prepare a report concerning the criminal history of Mr. Alvarez-Ortega.

Dated: September 12, 2012 Respectfully submitted, /s/ Michael D. Long__________ MICHAEL D. LONG Attorney for Michael Long Dated: September 12, 2012 BENJAMIN WAGNER United States Attorney /s/ Daniel McConkie____ DANIEL McCONKIE Assistant U.S. Attorney MICHAEL D. LONG (CA State Bar #149475) 901 H Street, Suite 301 Sacramento, CA 95814 (916) 447-1920 Mike.Long.Law@msn.com

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

No. CR-S-11-365 GEB

THE UNITED STATES OF AMERICA, Plaintiff, GERMAN ALVAREZ-ORTEGA, ) et al ) Defendants.

(Proposed) ORDER

Judge: Hon. Garland E. Burrell

The United State Probation Office is requested to prepare a report concerning the criminal history of defendant German Alvarez-Ortega.

20120912

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