Appendix E -12 Defendant's Motion to Preclude Interview of Defendant for Pre-sentence Report

• Library: How to Try a Murder Case: Pretrial and Trial Guidelines for Prosecution and Defense (ABA) (2011 Ed.)

APPENDIX E-12 Defendant's Motion to Preclude Interview of Defendant for Pre-Sentence Report

Defendant, by undersigned counsel, respectfully requests that this Honorable Court order the Division of Parole and Probation that it shall not attempt to interview Defendant or in any way elicit a statement from him in conjunction with the preparation of the Pre-Sentence Investigation Report, and in support thereof states the following:

I. The Defendant is charged with first-degree murder and related offenses in the above-captioned matter.
II. The State has filed a Notice of Intention to Seek a Sentence of Death.
III. Annotated Code of Maryland, Correctional Services, Section 6-112(c) (1999), provides that a pre-sentence investigation report shall be completed by the Division of Parole and Probation in any case in which the death penalty is sought pursuant to Article 27, Section 412. See Md. Corr. Serv. Code Ann. § 6-112(c) (1999); Md. Ann. Code

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