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

1 Brian F. Russo (018594) i
111 West Monroe Street
2 suite 1212
Phoenix, AZ 85003
3 602—340-1133 telephone
602-258-9179 facsimile
4 e-mail:[email protected]
5 Attorney for Defendant Johnston
6 IN THE UNITED STATES DISTRICT COURT l
7 DISTRICT OF ARIZONA
s
9 STATE OF ARIZONA, Case No. CR O3-1167-PHX-DGC
Plaintiff, MOTION FOR EARLY
IO TERMINATION OF PROBATION
ll vs. i
12 ROBERT J. JOHNSTON, JR. (1), )
Defendant. g
13
14
is
1 6 COMES NOW the defendant Robert Johnston, by and through undersigned
17 Counsel and hereby moves this Honorable Court pursuant to 18 U.S.C. § 3564(c),
18 for an order terminating his probation and discharging him completely for the
19
following reasons. Mr. J ohnsotn has been on probation supervision for more than
20
Zl 1 year and has been a successful probationer. He was sentenced to two years
22 probation on December 18, 2006 and has successfully complied with all terms and
23 conditions as set forth by this Court and the Federal Probation Officer, Michael
24
Lipscomb assigned to his case. Mr. Johnston has paid all fines and been negative
25
on all random UAs. He has at all times been gainfully employed and maintained
Case 2:03-cr-01167-DGC Document 1447 Filed O1/08/2008 Page 1 of 2

l l
I constant contact with his probation officer. In essence, he has been a model
2 .
probationer.
3
4 In addition, one year of probation is satisfactory to reflect the seriousness of
5 a misprision of felony offense and to promote respect for the law. It should also be
6 noted that Mr. Johnston was on pretrial supervision for approximately 3 years prior ~
7
to the imposition of sentence and was at all times compliant with that agencies
a
9 requirements. Early termination of Mr. J ohnston’s probation is appropriate given
10 his stellar conduct and is certainly in the interests of justice.
H xx
12 N
RESPECTFULLY SUBMITTED this sth day of January, 2008.
ia
I4
/s/Brian F. Russo
N Brian F. Russo
16 Attorney for Defendant
U COPY of the foregoing
lg electronically mailed
Sth day of January, 2006, to:
ie
Hon. David G. Campbell
20 Judge the District Court
21
22 Assistant U.S. Attorney
23 By: /s/
24
25
Case 2:03-cr-01167-DGC Document 1447 Filed O1/08/2008 Page 2 of 2

Case 2:03-cr-01167-DGC

Document 1447

Filed 01/08/2008

Page 1 of 2

Case 2:03-cr-01167-DGC

Document 1447

Filed 01/08/2008

Page 2 of 2