Unopposed Motion to Conduct a Pre-Plea Presentencing Investigation Report — United States v. Harrison-Pierre

Summary

This is an unopposed motion and proposed order in the District of Nevada, Case No. 2:26-cr-0106-GMN-MDC, United States of America against Yves Garry Harrison-Pierre. Appointed counsel David T. Brown asks the Court to order that the Probation Department prepare a pre-plea presentence investigation report as soon as possible. The motion says the calculation of the defendant's criminal history will drastically impact sentencing exposure, negotiations and the client's decision on how to proceed. It also says counsel spoke to Assistant United States Attorney Kimberly Frayn, who has no opposition. It is dated July 20, 2026, with the /s/ signature of David Brown.

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 Case 2:26-cr-00106-GMN-MDC              Document 15      Filed 07/20/26      Page 1 of 4



 1   MOT
     DAVID T. BROWN, ESQ.
 2   Nevada Bar No. 006914
     BROWN, BROWN & PREMSRIRUT
 3   520 S. Fourth Street, 2nd. Fl.
     Las Vegas, Nevada 89101
 4   ph: (702) 384-5563
     email: dbrown@brownlawlv.com
 5   Attorney for Defendant Yves Harrison-Pierre
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                                    UNITED STATES DISTRICT COURT
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                                        DISTRICT OF NEVADA
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     UNITED STATES OF AMERICA,           )
 9                                       )          CASE NO.: 2:26-cr-0106-GMN-MDC
                 Plaintiff,              )
10                                       )
     vs.                                 )
11                                       )
     YVES GARRY HARRISON-PIERRE,         )          YVES HARRISON PIERRE’S UNOPPOSED
12                                       )          MOTION TO CONDUCT A PRE-PLEA
                 Defendant.              )          PRESENTENCING INVESTIGATION
13                                       )          REPORT AND PROPOSED ORDER
     ____________________________________)
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            COMES NOW, appointed counsel David T. Brown, Esq., of BROWN, BROWN &
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     PREMSRIRUT, and hereby moves this Court in request of a Pre-Plea Pre-Sentence Investigation
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     Report be prepared by the Probation Department.
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            1) The calculation of Defendant Yves Harrison Pierre’s criminal history will drastically
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     impact his sentencing exposure, negotiations, and client’s decision as to how he should proceed.
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     A pre-plea presentence report will promote judicial economy and aid in the manner in which this
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     case is ultimately resolved.
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 Case 2:26-cr-00106-GMN-MDC             Document 15        Filed 07/20/26     Page 2 of 4



 1          2) Undersigned counsel therefore respectfully requests an Order that the Department of
 2   Probation conduct a pre-plan presentence investigation report as soon as possible.
 3          3) Undersigned counsel has spoken to the prosecutor, Assistant United States Attorney
 4   Kimberly Frayn regarding this request and she has no opposition.
 5          DATED this 20th day of July, 2026.
 6                                                BROWN, BROWN & PREMSRIRUT
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                                                  /s/ David Brown
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 9                                                DAVID T. BROWN, ESQ.
                                                  Nevada Bar No. 006914
10                                                520 S. Fourth St.
                                                  Las Vegas, Nevada 89101
11                                                Attorney for Defendant Yves Harrison-Pierre
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Case 2:26-cr-00106-GMN-MDC   Document 15   Filed 07/20/26   Page 3 of 4
 Case 2:26-cr-00106-GMN-MDC             Document 15        Filed 07/20/26      Page 4 of 4



 1                                   CERTIFICATE OF SERVICE
 2          I hereby certify that on this 20th day of July 2026, I served a copy of the foregoing
 3   UNOPPOSED MOTION TO CONDUCT A PRE-PLEA PRESENTENCING INVESTIGATION
 4   REPORT AND PROPOSED ORDER upon the following via the CM/ECF system as follows
 5
 6   Todd Blanche
     United States Attorney's Office
 7   400 South Virginia Street, Suite 900
     Reno, NV 89501
 8   (775) 784-5438
     Attorney for Plaintiff United States of America
 9
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     Sigal Chattah
11   DOJ-USAO
     501 Las Vegas Blvd. South, Suite 1100
12   Las Vegas, NV 89143
     702-388-6566
13   sigal.chattah@usdoj.gov
     Attorney for Plaintiff United States of America
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15   Kimberly M. Frayn
     U.S. Attorney's Office
16   501 Las Vegas Blvd. South, Suite 1100
     Las Vegas, NV 89101
17   702-388-6336
     kimberly.frayn@usdoj.gov
18   Attorney for Plaintiff United States of America

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20                                 /s/ Alexis Budner
                                   _____________________________
21                                 An Employee of Brown, Brown, & Premsrirut
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                                                       4


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