A guilty plea entered four days before trial on a fully prepared case, without evidence of prior plea negotiations, is not entered at the 'first reasonable opportunity' under s 9AA(4) of the Sentencing Act 1995 (WA) and does not warrant the maximum 25% discount. A 10% discount is appropriate in such circumstances. Separate aggravated burglaries committed on consecutive days at different locations against the same victim are not a continuing episode of offending for the purposes of the one transaction rule.
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