Free Motion for Hearing - District Court of Connecticut - Connecticut

Case 3:03-cr-00110-SRU

Document 47

Filed 09/20/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA vs. LEE JUPINA

: : : CRIMINAL NO. 3:03CR110 (SRU) September 19, 2007

MOTION FOR HEARING REGARDING MODIFICATION OF CONDITIONS OF RELEASE Pursuant to Rule 32.1 of the Federal Rules of Criminal Procedure the defendant, Lee Jupina, hereby moves this Honorable Court to schedule a hearing to consider modifying the conditions of his supervised release. In support of this motion, the defendant states: 1. Mr. Jupina appeared before this Court on April 25, 2006, at which time he admitted to violating several of the Special Conditions of his Supervised Release. This Court sentenced Mr. Jupina to a term of imprisonment of six months (with credit for time served) and a two year term of supervised release. As an additional term of supervised release, the Court ordered Mr. Jupina to participate in an in-patient substance abuse treatment program until such time as the probation office determines he is able to transition into an out-patient program. 2. At the time of his revocation hearing, Mr. Jupina was in the custody of the state of Connecticut for similar violations of his state supervision. 3. It was anticipated the time of the revocation hearing that Mr. Jupina would serve a period of time in state custody and would then be transferred into federal custody for service of his six month term of imprisonment. Mr. Jupina was paroled from his state sentence, however, prior to shifting from state to federal custody, he was served with warrants for new charges.

Case 3:03-cr-00110-SRU

Document 47

Filed 09/20/2007

Page 2 of 2

-24. At this time, Mr. Jupina is currently serving an eight year sentence, execution to be suspended after three years, for robbery. 5. Mr. Jupina seeks to modify the terms of his supervised release. He seeks a hearing to

determine if any modification is warranted in this case. WHEREFORE, the defendant respectfully requests that this Court schedule a hearing to consider whether a modification of his terms of supervised release is appropriate. Respectfully submitted, THE DEFENDANT, Lee Jupina THOMAS G. DENNIS FEDERAL DEFENDER

Dated: September 19, 2007

/s/ Deirdre A. Murray Assistant Federal Defender 10 Columbus Blvd, 6th FL Hartford, CT 06106 Phone: (860) 493-6260 Bar No.: ct22981 Email: [email protected]

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing Motion For Hearing Regarding Modification of Conditions of Release has been mailed to Alina Reynolds, Assistant United States Attorney, United States Courthouse, 915 Lafayette Boulevard, Bridgeport, CT 06604, on this 19th day of September 2007.

/s/ Deirdre A. Murray