UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
:
v. : CRIMINAL NO. 90-0070-03
: (formerly, Judge Pratt)
xxxxxxxxxxxx :
________________________________:
MOTION TO TERMINATE SUPERVISED RELEASE AND
SUPPORTING MEMORANDUM
xxxxxxxxxxx, through undersigned counsel, respectfully requests that this Court terminate her supervised release pursuant to Rule 32.1(b) of the Federal Rules of Criminal Procedure and 18 U.S.C. § 3583(e). In support of this Motion, Ms. xxxx shows the court:
1. The statute governing early termination of supervised release, 18 U.S.C. § 3583(e), provides that the court may terminate a term of supervised release "and discharge the defendant released at any time after the expiration of one year of supervised release, ... if it is satisfied that such action is warranted by the conduct of the defendant released and in the interest of justice."
2. On May 2, 1995, Ms. xxxx began a five-year term of supervised release under the supervision of the United States District Court for the District of Columbia, after having served a 5 year sentence of incarceration.
3. It appears that since May 2, 1995, Ms. xxxx has fulfilled all the conditions of her supervised release. She presently works three jobs: (1) shift supervisor at Au Bon Pain, where she has worked for over two years; (2) a parking lot attendant for DBY Parking, at 740 3rd Street, NW, where she has worked part-time for a year; and (3) Young's Cleaning Service, where she has worked nights, for a year. Ms. xxxx has a checking and a savings account. She has undergone the required drug tests, all which indicate negative results. She has maintained her own apartment at 1008 Monroe Street, NW, for over two years. She continues to submit her monthly reports in a timely manner.
4. Counsel, on behalf of Ms. xxxx, has contacted her supervising U.S. Probation Officer, Ms. Delores Richardson, and advised her of the filing this motion. Counsel is serving Ms. Richardson with a courtesy copy of the motion by facsimile.
5. Ms. xxxx has proven that she meets the criteria for early termination of supervised based on her good conduct under 18 U.S.C. § 3583(e).
WHEREFORE, it is respectfully requested that, in the interests of justice, the Court grant Ms. xxxx's motion for early termination of her supervised release pursuant to
18 U.S.C. § 3583(e), and pursuant to Rule 32.1(b)
Respectfully submitted,
A.J. KRAMER FEDERAL PUBLIC DEFENDER
Reita Pendry
Assistant Federal Public Defender
625 Indiana Avenue, N.W., Suite 550
Washington, D.C. 20004
(202) 208-7500
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Motion To Terminate Supervised Release And Supporting Memorandum has been served upon the Office of the United States Attorney, 555 4th Street, NW, Washington, DC, 20001 by mail and by leaving a copy in the box designated for that Office in the Clerk's Office of the United States District Court for the District of Columbia, and by facsimile and by hand-delivery upon United States Probation Officer Delores Richardson, this 16th day of December 1998.
_______________________
Reita Pendry
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
:
v. : CRIMINAL NO. 90-0070-03
: (formerly Judge Pratt)
DEBORAH M. xxxx :
________________________________:
ORDER
Upon consideration of Defendant xxxxxxx. xxxx's Motion To Terminate Release, and it appearing to the Court that good cause exists for the termination, it is this ____ day of December, 1998, hereby
ORDERED that the Motion is granted.
_____________________________
Judge, United States District Court
Copies To:
Office of the United States Attorney
555 Fourth St., N.W.
Washington, D.C. 20001
(202) 514-7064
Reita Pendry, Esq.
Assistant Federal Public Defender
625 Indiana Ave., N.W. Suite 550
Washington, DC 20004
(202)208-7500
Delores Richardson
U.S. Probation Officer
United States District Court
for the District of Columbia
333 Constitution Ave, NW
Washington, DC 20001
(202)565-1340
xxxxxxxxxx. xxxx
xxxxxxxxxxxxx, NW, #xxx
Washington, DC 20010