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

w FILED
___ nsosrven _rr__ Conv {
1 Steve D. Nelson
507 West Taos Street OCT 2 7 2008
2 Hobbs, NM 88240 cusnx u s oisrnicr counr
Telephone (505) 392-4707 DISTRICT OF ARIZONA
I 3 Pro Per Defendant BY———-?_T@ DEPUTY
I 4
5 IN THE UNITED STATES DISTRICT COURT
6 DISTRICT OF ARIZONA
I
I 7 UNITED STATES OF AMERICA )
I ) CR-04-623-01-PHX-SRB
8 Plaintiff, )
) DEFENDANT’S MOTION TO
9 vs. ) TERMINATE PROBATION
I
10 STEVE D. NELSON, )
I
11 Defendant )
I
12 COMES NOW the defendant, representing myself, who respectfully
13 requests that this Honorable Court terminate my probation pursuant to Rule 32.1
14 (b) of the Federal Rules of Criminal Procedure and 18 U.S.C. §3564(c). In
15 support of this Motion, i state:
16 1. On June 15, 2004, l entered a plea of guilty to one count of healthcare
17 fraud in violation of 18 U.S.C. §1347, a Class D felony.
18 2. I was sentenced on January 10, 2005, to tive months at a Federal
19 Prison Camp, Hve months house arrest, three years of probation and a $4,000
20 fine and placed under the supervision of the U.S. Probation Oflice for the United
21 States District Court for the District of New Mexico.
22 3. The statute governing early termination of probation, 18 U.S.C.
23 §3564(c) provides in pertinent part that the court may terminate a term of
l
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1 probation at any time after the expiration of one year of probation in the case of a _
2 felony if it is satisfied that such action is warranted by the conduct of the
3 defendant and the interest of justice.
4 4. In June 2006, I paid off my $4,000 fine.
l 5 5. While on probation I attended San Jose State University and will
6 graduate this December 2006 with a Masters Degree in Library and Information
7 Science. I maintained a 3.6 grade point average.
8 6. I talked to li/lr. Dirk Sonive, my Probation Officer. He reviewed my file,
9 verified that I had paid my fine in full, and stated that he did not oppose early
10 termination of my probation.
11 7. Ashley Adams-Feldman, the Assistant U.S. Attorney on my case, is no
12 longer employed by the U.S. Attorneys Ofhce. I called the U.S. Attorneys OfHce
13 to obtain the name of the attorney assigned to my case and I was told that my
14 probation officer would have this information. On Oct. 24, 2006 Mr. Sonive
15 contacted the U.S. Attorneys Office to obtain the name of the attorney assigned
16 to my case and was told the U.S. Attorneys Office did not have any records
17 related to my case. (I am sending a copy of my Notice of Orders and Judgment
18 to the U.S. Attorneys Office with this motion.)
19 8. I have been on probation since November 1, 2005, and have proven
20 that I meet the criterion based on my good conduct for early termination of my
21 probation under 18 U.S.C. §3564(c).
22
23 WHEREFORE, i respectfully request that, in the interest of justice, the Court
Case 2:04-cr-00623-SRB Document 109 Filed 10/27/2006 Page 2 of 3

J I
1 grant my motion for early termination of probation pursuant to 18 U.S.C.
2 §3564(c) and Rule 32.1(b).
3 Respectfully submitted thisgé day of October, 2006.
By ,
4
5 Steve D. Nelson
6 Ori inal of the foregoing Motion
€l hand—deIivered this ji clay
7 of October, 2006, to:
8 Clerk of Court
Sandra Day O’Connor U.S. Courthouse
9 Suite 130
401 West Washington Street- SPC 1
10 Phoenix, Arizona 85003—21‘l8
11 Co fthe foregoing Motion
/ hand-delivered this QQ day
12 of October, 2006, to:
13 U.S. Attorney
ATTN: Mrs. Ashley Adams-Feldman
14 Two Renaissance Square
40 North Central Avenue, Suite 1200
15 Phoenix, Arizona 85004-4408
16 Mr. Dirk Sonive
U.S. Probation Officer
17 500 North Richardson Ave., Room 337
Roswell, New Mexico 88201
18
19
20
Steve D. Nelson
21
22
23
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