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

Case 3:02-cr-00221-AWT

Document 3

Filed 11/03/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. WILLIAM VELAZQUEZ : : : CRIMINAL NO. 3:02CR221(AWT) November 3, 2004

MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE The defendant, William Velazquez, respectfully moves the Court to terminate his term of supervised release and discharge him f rom further supervision. In support of this motion, the defendant represents as follows. (1) On October 5, 2001 the defendant was sentenced in the Eastern District of New York,

Korman, J. to a term of imprisonment of 18 months, to be followed by three years of supervised release, upon his conviction for importing "ecstasy" into the United States, in violation of 21 U.S.C. § 952(a) and 960(b)(3). (2) Defendant was discharged from custody and commenced serving his term of supervised

release on or about March 29, 2002. Jurisdiction was transferred to the District of Connecticut on June 3, 2002. (3) Title 18, U.S.C. § 3583(e)(l) authorizes the Court to terminate supervised release at any

time after the expiration of one year, if satisfied that such action is warranted by the conduct of the defendant and the interests of justice. (4) The defendant submits that he satisfies the criteria for early termination. He has fully

complied with all conditions of supervised release including payment of his only financial requirement, the $100 special assessment. He is currently unemployed because of a disability and subsists on Social Security benefits. However, he participates in regular treatment and counseling sessions at Hartford Behavioral Health. He will continue with this program, which is paid for by the State, after termination of his supervised release. He has successfully re-integrated into society and poses no risk to the public safety in general or to any individual third party.

Case 3:02-cr-00221-AWT

Document 3

Filed 11/03/2004

Page 2 of 2

-2(5) termination. Wherefore, the defendant, William Velazquez, requests that his supervised release be terminated and that he be discharged from further supervision. Respectfully submitted, THE DEFENDANT, WILLIAM VELAZQUEZ THOMAS G. DENNIS, ESQ. Federal Defender His supervising Probation Officer, Ryan MacDougall, has no objection to an early

Dated: November 3, 2004

/s/ Thomas G. Dennis Federal Defender 10 Columbus Blvd, FL 6 Hartford, CT 06106-1976 Bar No. ct05100 (860) 493-6260 CERTIFICATION

I HEREBY CERTIFY that a copy of the foregoing Motion For Early Termination of Supervised Release has been mailed to Raymond Miller, Assistant United States Attorney and Ryan MacDougall, United States Probation Officer, Federal Building, 450 Main Street, Hartford, CT 06103, on this 3rd day of November 2004. /s/ Thomas G. Dennis