Free Motion to Reduce Sentence - District Court of Arizona - Arizona

1 2 3 4 Attorney for Defendant Manuel de Jesus Rosales Corrales 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE DISTRICT OF ARIZONA 7 UNITED STATES OF AMERICA, 8 Plaintiff, 9 v. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Comes now Defendant Manuel De Jesus Rosales Corrales, through undersigned counsel, Nicholas Alcock, and respectfully requests the Court to consider the following downward departure request pursuant to Federal Sentencing Guideline Section 5G1.3. In the instant case, Mr. Rosales Corrales has been detained in Arizona State Custody since June of 2004. He subsequently plead guilty in Maricopa County Superior Court to Illegally Conducting a Enterprise and was sentenced to 2 years and 6 months in the Arizona Department of Corrections. The basis for the plea of guilty involved the fact that on May 15, 2004, the Defendant delivered a vehicle to a smuggler for the purpose of transporting illegal aliens.
Case 2:04-cr-01070-DGC Document 75 Filed 03/13/2006 Page 1 of 2

ALCOCK & ASSOCIATES, P.C. Nicholas M. Alcock (Bar No. 018965) 2 N. Central Ave., 26th floor Phoenix, Arizona 85004 Telephone: (602) 404-6000

REQUEST FOR DOWNWARD DEPARTURE Case No: 04-CR01070-006-PHX-DGC ASSIGNED TO THE HONORABLE JUDGE DAVID G. CAMPELL

MANUEL DE JESUS ROSALES CORRALES, Defendant.

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On August 26, of 2005, the Defendant was moved to CCA Florence and was charged Federally with Conspiracy to Transport Illegal Aliens. This charge was based on relevant conduct to the Arizona case of Illegally Conducting an Enterprise. As such and pursuant to 5G1.3(c), the Defense respectfully requests that the Court run the undischarged term of imprisonment concurrently to the instant offense. Defense believes that the sentence imposed by the Maricopa County Superior Court is adequate to obtain a reasonable punishment for the instant offense. This is supported by the Defendant's significant health issues. Specifically, Defendant suffers from severe memory loss, headaches, depression and anxiety stemming from a major concussive head injury. Further, Mr. Rosales Corrales has fully accepted responsibility and has avowed to all parties that he will never return to the United States. RESPECTFULLY SUBMITTED this 13th day of March, 2006. /s/ Nicholas M. Alcock Nicholas M. Alcock, Esq. Attorney for Defendant Certificate of Service I hereby certify that on March 13, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Emory T. Hurley /s/ Nicholas M. Alcock

Case 2:04-cr-01070-DGC

Document 75

Filed 03/13/2006

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