Free Letter - District Court of Delaware - Delaware

Case 1:05-cr-00031-GMS

FEDERAL PUBLIC DEFENDER
District of Delaware 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 FAX (302) 573-6041

Document 11

Filed 08/05/2005

Page 1 of 2

Penny Marshall Federal Public Defender

Christopher S. Koyste Assistant Federal Public Defender Eleni Kousoulis Assistant Federal Public Defender Jonathan Pignoli Research and Writing Specialist

August 5, 2005

Honorable Gregory M. Sleet United States District Court J. Caleb Boggs Federal Building 844 King Street, Fourth Floor Wilmington, DE 19801 Re: United States v. Jose Luis Vasquez-Juarez Criminal Action No. 05-31-GMS

Dear Judge Sleet. This letter is an unopposed request to set an expedited hearing date in the above entitled matter. It is also requested that the Court set the date for a guilty plea with sentencing to follow. On June 7, 2005, an initial appearance was held in Delaware District Court on an April 14th indictment charging Mr. Vasquez-Juarez with illegal re-entry after deportation. The defense accepted the government's plea agreement to plead to the indicted charge. Since the parties recognized that the guideline range was likely to be relatively low, probation was asked to complete an expedited presentence report in anticipation of sentencing. The pre-sentencing report, which has now been completed, list a guideline range of 1 to 7 months. Mr. Vasquez-Juarez was incarcerated in February 2005 on a separate state charge, however, he was given probation in that case. Therefore, Mr. Vasquez-Juarez has served significant prison time for which no sentence of incarceration has applied.

Case 1:05-cr-00031-GMS

Document 11

Filed 08/05/2005

Page 2 of 2

It is therefore requested that a guilty plea-sentence date be set as soon as feasible for the Court.

Respectfully submitted, /s/ Penny Marshall Federal Public Defender

PM/rsb

cc:

Beth Moscow Schnoll, Assistant United States Attorney Nancy Klingler, U.S. Probation/Pretrial Services