Free Motion to Modify Conditions of Release - District Court of Connecticut - Connecticut

Case 3:01-cr-00250-JBA

Document 39

Filed 12/21/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. KIERA KEENE : : : CRIMINAL NO. 3:01CR250 (JBA) December 20, 2007

MOTION TO MODIFY CONDITIONS OF SUPERVISED RELEASE Comes now, defendant, Kiera Keene, through undersigned counsel, Paul F. Thomas, and hereby requests a modification of the conditions of supervised release so as to waive urinalysis testing. In support of this motion, Ms. Keene states the following grounds: 1) On November 20, 2001, Ms. Keene was sentenced to one month of incarceration to be followed by a period of home confinement, pursuant to electronic monitoring. 2) United States Probation Officer Joseph Zampano reports that Ms. Keene has been compliant with all her conditions of Supervised Release and does not object to the waiving of urinalysis testing. 3) Assistant United States Attorney Anthony Kaplan takes no position with respect to this motion.

Respectfully submitted, THE DEFENDANT, KIERA KEENE THOMAS G. DENNIS FEDERAL DEFENDER

Dated: December 20, 2007

/s/ Paul F. Thomas Assistant Federal Defender 265 Church Street, Suite 702 New Haven, CT 06510 Phone: (203) 498-4200 Bar no.: ct01724 Email: [email protected]

Case 3:01-cr-00250-JBA

Document 39

Filed 12/21/2007

Page 2 of 2

-2CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing MOTION TO MODIFY CONDITIONS OF SUPERVISED RELEASE has been mailed to Anthony Kaplan, Assistant United States Attorney, 157 Church Street, 23rd Fl, New Haven, CT 06510, on this 19th day of December 2007.

/s/ Paul F. Thomas