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

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feder law office, p.a. post office box 44560 phoenix, arizona 85064-4560 (602) 257-0135 Bruce Feder - State Bar No. 004832

4 attorney for Defendant 5 6 7 8 9 v. 10 KELLY TIMOTHY LIU, 11 Defendant. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ... 26 ... 27 ... 28 s/Bruce Feder Attorney for Defendant 2. UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) NO. CR03-00543-001-PHX-SMM MOTION FOR EARLY TERMINATION OF PROBATION

The Defendant, Kelly Liu, by and through his attorneys undersigned, moves this Court for its order terminating his probation for the reasons that: 1. Mr. Liu has completed all of the requirements of probation including, but not limited to, restitution; The travel restrictions imposed by probation are impeding his ability to expand his business. This Motion is based on the attached Memorandum of Points and Authorities, the file in this matter, and such other arguments and evidence as may be presented. RESPECTFULLY SUBMITTED this 8th day of August, 2006. FEDER LAW OFFICE, P.A.

Case 2:03-cr-00543-SMM

Document 91

Filed 08/08/2006

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MEMORANDUM OF POINTS AND AUTHORITIES On March 14, 2005, this Court placed the Defendant, Kelly Liu, on probation for a period of three years. Since that time, Mr. Liu has participated in and expanded several businesses to a point where his days are substantially filled. The need for permission to travel and travel restrictions imposed by probation are impeding further expansion of his business. He has complied with all restitution and other requirements of probation. Based on these facts, it is requested that the probation of Mr. Liu be terminated earlier than the term previously set at sentencing. DATED this 8th day of August, 2006. FEDER LAW OFFICE, P.A.

s/Bruce Feder Attorney for Defendant

Case 2:03-cr-00543-SMM

Document 91

Filed 08/08/2006

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 s/Laurel Barord Frederick Battista [email protected]

CERTIFICATE OF SERVICE I hereby certify that on the 8th day of August, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants:

I hereby certify that on the 8th day of August, 2006, a copy of the attached document was sent by email and mail to: The Honorable Stephen M. McNamee United States District Court Sandra Day O'Connor U.S. Courthouse 401 West Washington, SPC 60 Phoenix, AZ 85003 [email protected]

Case 2:03-cr-00543-SMM

Document 91

Filed 08/08/2006

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