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

Case 3:03—cr—00029-JCH Document 15 Filed 11/27/2006 Page 1 of 2
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` UNITED STATES OF AMERICA :
vs. : CRIMINAL NO. 3:03CR29(J CH)
M RICHARD CICHON : September 28, 2006
MOTION TO TERMINATE PROBATION
The defendant, Richard Cichon, respectfully moves this Court to terminate the term of probation
d on July 29, 2003. In support of this motion, the defendant states the following:
(i I gr 1. Under 18 U.S.C. §3564(c), the Court, "after considering the factors set forth in Section
AR \ L 3553(a) to the extent they are applicable, may, pursuant to the provisions of the Federal Rules of
Q ‘ -. Criminal Procedure relating to the modification of probation, terminate a term of imprisonment
sl previously ordered and discharge the defendant at any time in the case of a misdemeanor or an
` ll infraction or after the expiration of one year of probation in the case of a felony, if it is satisfied that
§ U such action is warranted by the conduct of the defendant and the interest of justice."
Q \ 2. On February 11, 2003, Mr. Cichon pled guilty to the charge of theft of government funds in
` { violation of 18 U.S.C. §641. On July 29, 2003, the Court sentenced him to probation for 5 years, with
§ \ p , peciai conditions of restitution in the amount of $5,385 and community service of 100 hours.
· 3. Mr. Cichon has fully satisfied the special conditions of probation by performing the required
E community service and by making full restitution.
. 4. The purposes of sentencing set forth in Section 3553(a) have been fulfilled, the defendant’s
3 conduct during the term of probation demonstrates that there is no longer a need for supervision, and
Q the interest of justice would be served by terminating probation more than three years after sentencing
(,3 was imposed.
\

i Ill l i Il
Case 3:03—cr—00029-JCH Document 15 Filed 1 1/27/2006 Page 2 of 2
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Respectfully submitted,
THE DEFENDANT,
RICHARD CICHON
THOMAS G. DENNIS
FEDERAL DEFENDER
Dated: September 28, 2006 L ·’ M;
Paul F. Thomas
Asst. Federal Defender
2 Whitney Ave., Suite 300
New Haven, CT 06510
Bar No. ct01724
(203) 498-4200
Email: [email protected]
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing MOTION TO TERMIN ATE PROBATION
has been mailed to James I. Glasser, Assistant United States Attorney, 157 Church Street, 23“’ F1, New
Haven, CT 06510, and Deborah S. Palmieri, United States Probation Officer, 157 Church Street, New
Haven, CT 06510, on this 28* day of September 2006.
Paul F. Thomas A