Free Motion for Early Termination of Probation - District Court of Connecticut - Connecticut

Case 3:02-cr-00024-SRU

Document 77

Filed 02/14/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. SAMUEL WILSON : : : CRIMINAL NO. 3:00CR24(SRU) February 13, 2006

MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE Pursuant to Rule 32(c), Fed. R. Crim. P., and 18 U.S.C. § 3564(c), the defendant, Samuel Wilson, hereby moves for early termination of probation. In support of this motion, Mr. Wilson states: 1. On February 5, 2000, an indictment was returned that charged that Samuel Wilson with violations of 21 U.S.C. §§ 846, 841(a) and 841(b)(1)(c). 2. On February 6, 2000, Mr. Wilson appeared for presentment and arraignment and he was released pending trial on a $50,000 non-surety bond. 3. On August 29, 2002, Mr. Wilson pled guilty to Count One of the indictment, which charged conspiracy to possess with intent to distribute and distribution of cocaine in violation of 18 U.S.C. §§ 841(a)(1)(c) and 846, and he was permitted to remain at liberty pending sentencing. 4. On November 18, 2002, this Court sentenced Mr. Wilson to probation for a term of five years, with six months home confinement, 360 hours community service, a fine of $3,000, and a special assessment of $100. Mr. Wilson had been on release, subject to supervision by pretrial services, for over two and a half years prior to sentencing.. 5. Mr. Wilson paid the special assessment on the day he was sentenced. After completing the required period of home confinement, Mr. Wilson fully paid the fine and completed the required community service. In all aspects, Mr. Wilson has been in full compliance with the terms of probation. 6. Mr. Wilson is a first offender who has fulfilled the Court's requirements while released on bond before sentencing and since he was sentenced while on probation, and there is no further need to subject him to the supervision by the U.S. Probation Office or to burden that office with the supervision of this law-abiding citizen.

Case 3:02-cr-00024-SRU

Document 77

Filed 02/14/2006

Page 2 of 2

-27. Mr. Wilson previously moved, in 2004, for early termination of probation, and the Court denied that motion without prejudice to re-filing after Mr. Wilson had completed three years of probation, which he has now done. WHEREFORE, the defendant moves this Court to terminate the term of probation in the interest of justice and upon the good conduct of the defendant. Respectfully submitted, THE DEFENDANT, SAMUEL WILSON THOMAS G. DENNIS FEDERAL DEFENDER

Dated: February 13, 2006

/s/ Paul F. Thomas Asst. Federal Defender 2 Whitney Ave., Suite 300 New Haven, CT 06510 Bar No. ct01724 (203) 498-4200 Email: [email protected] CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE has been mailed to James J. Finnerty, Esq., Assistant United States Attorney, United States Courthouse, 915 Lafayette Boulevard, Bridgeport, CT 06604, and to Jane Cafone, United States Probation Officer, 915 Lafayette Boulevard, Bridgeport, CT 06604, on this 13th day of February 2006.

/s/ Paul F. Thomas