Free Objection to Presentence Investigation Report - District Court of Arizona - Arizona

1 UNITED STATES OF AMERICA vs. JOSE MANUEL MEDINA PINEDA CASE NO. CR 03-1097-PHX-ROS 2 OBJECTIONS TO PRESENTENCE REPORT 3 4 5 6 7 8 9 10

RESPECTFULLY SUBMITTED this 15th day of August, 2005. PHILIP A. SEPLOW, ESQ.

By:

S/Philip A. Seplow Philip A. Seplow, Esq. Attorney for Defendant

CERTIFICATE OF SERVICE

X I hereby certify that on , I electronically transmitted the 11 attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the 12 following CM/ECF registrants:
13 Lisa Jennis-Settel, Esq. ASSISTANT UNITED STATES ATTORNEY 14 Baltazar Iniguez, Esq. 15 Attorney for Gerardo Eufemio Cardenas-Osorio 16 Michael S. Reeves, Esq. Attorney for Daniel Samaniego-Cachon 17 Robert James McWhirter, Esq. 18 Attorney for Francis Luna-Lara 19

X I hereby certify that on , I served the attached document by 20 First Class Mail on the following, who are not registered participants of the CM/ECF System: 21 Jeannie Moreno 22 UNITED STATES PROBATION OFFICER Sandra Day O'Connor U.S. Courthouse - SPC 7 23 401 West Washington - Suite 160 Phoenix, AZ 85003 24
25 26 27 28

S/ Philip A. Seplow

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Case 2:03-cr-01097-ROS

Document 97

Filed 08/15/2005

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IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) Plaintiff, ) ) vs. ) ) Jose Manuel Medina-Pineda, ) ) Defendant. ) __________________________ ) Case No. CR 03-1097-PHX-ROS

8 United States of America, 9 10 11 12 13 14

OBJECTIONS TO PRESENTENCE REPORT

COMES NOW the Defendant, Jose Manuel Medina-Pineda, by

15 and through undersigned counsel, and gives notice that he has no 16 formal objections to the Presentence Report. 17

The initial guideline imprisonmnent range, as reflected However, after

18 by the Report in paragraph 67 is 41-51 months.

19 factoring in all the agreed-upon enhancements, the imprisonment 20 range due to the impact of the Plea Agreement is now 70-87 months. 21 It is requested that Mr. Jose Manuel-Medina Pineda (true name 22 Victor Manuel Velasquez) be sentenced at the low end of the 23 guideline range.

He has already been in official pretrial During that time period he has

24 detention at CCA for 690 days. 25 been a model detainee.

He has been respectful to both his

26 attorney and to the Court, and would like to return to Mexico 27 after being released from prison so he can continue in his efforts 28 to support his family.

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Case 2:03-cr-01097-ROS

Document 97

Filed 08/15/2005

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