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United States of America v. Ricardo Venegas

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


October 23, 2012

UNITED STATES OF AMERICA, PLAINTIFF,
v.
RICARDO VENEGAS, DEFENDANT.

The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.

JOHN R. MANNING (SBN 220874) LAW OFFICE OF JOHN R. MANNING 1111 "H" Street, Suite 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 jmanninglaw@yahoo.com Attorney for Defendant RICARDO VENEGAS

JOINT REQUEST AND [PROPOSED] ORDER FOR A FULL PRE-PLEA REPORT REGARDING MR. VENEGAS.

The Parties, Jill Thomas Esq., Assistant United States Attorney, and counsel for defendant Ricardo Venegas, John R. Manning, Esq., jointly request the Court order the United States Probation Department to draft a "full" or "complete" pre-plea presentence report. This Court previously authorized United States Probation to prepare a pre-plea report for the sole purpose of calculating Mr. Venegas' criminal history. The Parties believe that due to the complex nature of the facts and circumstances surrounding this matter (including information raised in the pre-plea criminal history report), a "full" or "complete" pre-plea report will be beneficial, if not instrumental, in resolving this matter.

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

UNITED STATES OF AMERICA, Plaintiff, v. RICARDO VENEGAS, Defendant.

CR NO. S-08-441 GEB

PROBATION IS REQUESTED TO PREPARE A "FULL" PRE-PLEA REPORT

The United States Probation Department is requested to draft a "full" pre-plea report, provided that this request is consistent with other functions of the Department.

GARLAND E. BURRELL, JR. Senior United States District Judge

20121023

© 1992-2012 VersusLaw Inc.



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