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

Case 3:00-cr—00217-EBB Document 975 Filed 12/19/2006 Page 1 of 4
UNITED STATES DISTRICT COURT I
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA,
Plaintiff `
v. CRIMINAL NO. 3:00CR217(EBB)
FREDERICK MCCARTHY,
Defendant DECEMBER 19, 2006 ·
MOTION TO MODIFY TERMS OF SUPERVISED RELEASE
The defendant, through his undersigned counsel, respectfully requests
that this Court modify the Supervised Release by ordering it terminated.
l In support of this motion, the defendant states: l
I. He was sentenced in this Court on February 4, 2004, to a period of
incarceration for one year and one day to be followed by a period of three years E
Supervised Release.
2. The defendant has satisfactorily completed the incarceration portion
of his sentence. He has been on Supervised Release since the date of his
release from prison which is approximately 23 months ago. I-Ie has complied
with all the conditions of that supervised release, to wit:

- Case 3:00-cr—00217-EBB Document 975 Filed 12/19/2006 Page 2 of 4
a. He caused to be paid a total of $1,000,000.00 prior to his 2
incarceration, $850,000.00 of which went to the Treasurer of the State of
Connecticut; $110,000.00 to the Securities Exchange Commission; and
$40,000.00 to the United States Courts.
b. He completed 500 hours of community service through
assignment by the United States Probation Office in West Palm Beach, Florida,
to work with the Sickle Cell Foundation of Palm Beach County. He worked at V ‘
the Foundation from February to May, 2005, completing all the required hours.
c. In addition, subsequent to terminating his required hours at
the Sickle Cell Foundation, the defendant volunteered to assist in the S
Foundation’s 2006 annual fund drive and raised over $40,000.00 from more
than 120 donorsfor the Foundation. He has committed to assist again with
the Foundations 2007 fund raiser.
3. The defendant is anxious to seek restoration of his civil rights in
accordance with the laws of the State of Florida which require that he have ·
completed all conditions of any criminal sentence imposed.
4. The defendant is now 65 years old and wishes to spend time with his
family. His son Daniel and his wife, Olivia, are expecting his first grandchild
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Case 3:00-cr-00217-EBB Document 975 Filed 12/19/2006 Page 3 of 4 . i
and reside in Palm Desert, California; his son Frederick, III resides in New York I
City; and his daughter Catherine and her husband reside in Boston. Travel
restrictions require that he first seek permission to visit his children.
5. In addition, his 68—year old sister, Annette Dyer, resides in Winter
Park, Florida and his 7 O-year old cousin, Lee Harrington resides in De Bary,
Florida. Travel restrictions also make contact with these relatives difficult.
6. And for such further reasons as may become apparent upon the
hearing of this motion.
THE DEFENDANT,
FREDERICK MCCARTH
By {A
Willi . ow, III ct00l6l _
JACOBS, G UDBERG, BELT, DOW & KATZ P.C. .
350 Orange Street ¤
New Haven, CT 06503 ;
Telephone: [203) 772-3100 `
E—mail: [email protected] _
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Case 3:00-cr—00217-EBB Document 975 Filed 12/19/2006 Page 4 of 4 Q
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was mailed first class,
CYR
postage prepaid this I [ l day of December, 2006 to the following:
Nora Dannehy, Esq.
Assistant United States Attorney
Office of the United States Attorney
. 450 Main Street -
Hartford, CT 06103 ;
I
wi 1 F. DOW, 111
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