IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
February 8, 2013
UNITED STATES OF AMERICA,
GREGORIO ZAPIEN-MENDOZA, ET. AL.,
The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge
STIPULATION AND [PROPOSED] ORDER FOR PRE-PLEA CRIMINAL HISTORY EVALUATION FOR DEFENDANT ZAPIEN-MENDOZA
The government and defendant GREGORIO ZAPIEN-MENDOZA (hereafter "defendant"), through undersigned counsel, stipulate that it would be appropriate for the United States Probation Office to prepare a criminal history evaluation, and determine the criminal history category, for defendant prior to a change of plea. As such, the parties request that this Court make such an order. The criminal history for defendant is ambiguous and his criminal history cannot be determined with sufficient confidence to adequately advise the defendant of the consequences of a change of plea. Moreover, an accurate calculation of the defendant's criminal history category would significantly aid in the settlement of this matter.
The government has authorized the defense counsel for defendant to sign this stipulation on his behalf.
DATED: February 7, 2013 BENJAMIN WAGNER United States Attorney by /s/ Scott N. Cameron, for Daniel McConkie Assistant U.S. Attorney DATED: February 7, 2013 by /s/ Scott N. Cameron Scott N. Cameron Counsel for Gregorio Zapien-Mendoza
For the reasons stated in the above stipulation of counsel, the United States Probation Department is ordered to conduct a criminal history evaluation, and to determine the criminal history category, for defendant GREGORIO ZAPIEN-MENDOZA.
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