How have the courts treated a defendant's criminal history score for prior criminal convictions?

Defendant also discussed nine prior convictions before 1986, in the most general and even obtuse manner. At the sentencing hearing, defense counsel only noted that defendant could not recall "each and every" offense. Defendant asked the court to consider the difficulty in verifying the prior arrests and convictions in determining their reliability. In his written objections, defendant did not deduct these points from the criminal history score. His failure to do so suggests that he did not object to their inclusion, or, at least, that he was not asking the court to resolve a factual issue. If he wanted to have a factual issue resolved he should have made that known in a manner that alerted the district court to his desire. At the sentencing hearing, defendant conceded that there was not "any value in having to prove up those records." No objection was made. See United States v. Rewald, 889 F.2d 836, 869 (9th Cir.1989).

III. Notice of Intent to Depart.