May 14, 2013
UNITED STATES OF AMERICA,
ALBERT LAFARGA-CRUZ, (EXPEDITED TREATMENT REQUESTED) DEFENDANT.
MOTION TO REQUEST PRE-TRIAL SERVICES INTERVIEW ALBERT LAFARGA-CRUZ WITH PROPOSED ORDER
COMES NOW the defendant, Albert Lafarga-Cruz, by and through his counsel of record, Rene L. Valladares, Federal Public Defender, and Monique Kirtley, Assistant Federal Public Defender, counsel for defendant and files this Motion to Request Pre-trial Services to Interview Mr. Lafarga-Cruz for the following reasons.
RENE L. VALLADARES Federal Public Defender /s/ Monique Kirtley MONIQUE KIRTLEY Assistant Federal Public Defender
On April 27, 2013, the defendant, Albert Lafarga-Cruz ("Lafarga"), made an initial appearance before Magistrate Judge Cam Ferenbach. Mr. Lafarga was detained as a flight risk and a danger to the community. It appears from the Order that the Court did not have any verifiable information regarding Mr. Lafarga as he had not interviewed with Pre-trial Services. The undersigned counsel filed a Motion to Re-Open Bail. A hearing on the Motion is scheduled for May 21, 2013 at 10:00 a.m. Prior to the hearing, Mr. Lafarga would like the opportunity to be interviewed by Pre-trial Services. In order to have Mr. Lafarga interviewed, the undersigned respectfully requests that this Court order Pre-trial Services to interview him prior to the 10:00 a.m., on May 21, 2013. Undersigned counsel is including a proposed order that would accomplish what is being requested in this motion.
DATED this 14th day of May, 2013.
Respectfully submitted, RENE L. VALLADARES Federal Public Defender /s/ Monique Kirtley __________________________ MONIQUE KIRTLEY Assistant Federal Public Defender Counsel for Albert Lafarga-Cruz
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
Case No.: 2:13-cr-00085-APG-PAL
UNITED STATES OF AMERICA, Plaintiff, v. ALBERT LAFARGA CRUZ, Defendant.
The reasons being sound and in the best interests of justice and judicial economy being served. if time and resources are available
IT IS ORDERED that Pre-trial Services conduct a pre-trial interview on May 21, and the court on or before May 20, 2013.
2013 prior to 10:00 a.m. and make the report available to the parties as quickly as possible.
DATED this day May 15th of , 2013.
UNITED STATES MAGISTRATE JUDGE
CERTIFICATE OF ELECTRONIC SERVICE
The undersigned hereby certifies that she is an employee of the Law Offices of the Federal Public Defender for the District of Nevada and is a person of such age and discretion as to be competent to serve papers.
That on May 14, 2013, she served an electronic copy of the above and foregoing MOTION TO REQUEST PRE-TRIAL SERVICES INTERVIEW ALBERT LAFARGA CRUZ WITH PROPOSED ORDER, (Expedited Treatment Requested), by electronic service (ECF) to the person named below:
DANIEL G. BOGDEN United States Attorney SUSAN CUSHMAN Assistant United States Attorney 333 Las Vegas Blvd. So., 5th Floor Las Vegas, Nevada 89101 /s/ Blanca Lenzi Employee of the Federal Public Defender
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