Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:01-cr-00369-WDM

Document 64

Filed 03/29/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CASE NO. 01-cr-000369-WDM UNITED STATES OF AMERICA, Plaintiff, v. RONNIE RAY LEONARD, Defendant. _____________________________________________________________________ UNOPPOSED MOTION FOR EARLY DISCHARGE FROM SUPERVISED RELEASE _____________________________________________________________________ The defendant, Ronnie Ray Leonard, by and through undersigned counsel, hereby moves this Honorable Court, pursuant to 18 U.S.C. § 3583(c)(1), to discharge him from the remaining term of his supervised release. As grounds, defendant states: 1. Defendant pled guilty to uttering a counterfeit obligation of the United States. The conduct involved the defendant attempting to pass a counterfeit $100 Federal Reserve Note. The defendant was sentenced on May 5, 2002, to 18 months imprisonment to be followed by three years supervised release. He was also ordered to make restitution in the amount of $1,100 and pay a $100 special assessment fee. 2. The defendant's supervised release term began on September 15, 2005.1 He has been supervised by Amber Dennison, Federal Probation officer in New Mexico. 3. Undersigned counsel, as well as government counsel, contacted Ms. Dennison regarding the defendant's compliance with his supervised release terms as

The delay in beginning supervision was as a result of a state sentence that the defendant began serving upon termination of his federal prison sentence.

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Case 1:01-cr-00369-WDM

Document 64

Filed 03/29/2007

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well as her position on early discharge from his term of supervised release. Ms. Dennison related that Mr. Leonard has been in complete and full compliance with all conditions of his supervised release. He has paid his restitution as well as his special assessment in full. He has been under drug testing/treatment during the entire time on supervision, has been fully compliant, and has never submitted a positive urinalysis. He has remained gainfully employed and stable in his residence. He has not incurred any arrests or convictions during his period of supervision. Ms. Dennison does not oppose an early discharge from supervised release for the Defendant. 4. Assistant U.S. Attorney Linda McMahan was contacted regarding this motion. After speaking with Ms. Dennison, Ms. McMahan does not oppose the Defendant's early discharge from supervised release. WHEREFORE, defendant prays this Court will grant this motion and grant him early discharge from supervised release. Respectfully submitted, RAYMOND P. MOORE Federal Public Defender

s/ Janine Yunker JANINE YUNKER Assistant Federal Public Defender 633 Seventeenth Street, Suite 1000 Denver, Colorado 80202 Telephone: (303) 294-7002 Facsimile: (303) 294-1192 [email protected] Attorney for Defendant

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Case 1:01-cr-00369-WDM

Document 64

Filed 03/29/2007

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CERTIFICATE OF SERVICE

I hereby certify that on March 29, 2007, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Linda McMahan [email protected]

and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participant in the manner (mail, hand-delivery, etc.) indicated by the nonparticipant's name: Amber Dennison (505) 348-2603 ­ facsimile

s/ Janine Yunker JANINE YUNKER Assistant Federal Public Defender 633 Seventeenth Street, Suite 1000 Denver, Colorado 80202 Telephone: (303) 294-7002 Facsimile: (303) 294-1192 [email protected] Attorney for Defendant

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