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

Case 3:00-cr-00249-JCH Document 202 Filed 07/20/2007 Page 1 of 4
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : Case No.: 3:00-CR-00249 (ICH)
ERNEST ORTALE : JULY 19, 2007
MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE AND
SUPPORTING MEMORANDUM
Ernest Ortale, through undersigned counsel, respectfully requests that this Court
terminate his probation pursuant to Rule 32. 1 (b) of the Federal Rules of Criminal Procedure, 18
U.S.C. § 3583(e), and 18 U.S.C. §3564(c). In support of this motion, Mr. Ortale shows the
Court:
1. The statute governing early termination of supervised release, 18 U.S.C. §3583(e), provides
that the court may terminate a term of supervised release “and discharge the defendant released
at any time aiter the expiration of one year of supervised release, . . . if it is satisfied that such
action is warranted by the conduct of the defendant released and in the interest of j ustice."
2. In January, 2005, Mr. Ortale began a four year term of supervised release under the
supervision of the United States District Court for the District of Connecticut, after having
served 18 months of` a 20-month sentence of incarceration.
3. Since January, 2005, Mr. Ortale has fulfilled all the conditions of his supervised release. He
presently works full—time at an auto dealership in West Haven, Connecticut. He has undergone

Case 3:00-cr-00249-JCH Document 202 Filed 07/20/2007 Page 2 of 4
and passed all required drug tests. In addition, he has maintained his own residence for almost
fifteen years, interrupted only by his prison sentence. He has continued to report to his probation
officer in a timely manner.
4. Counsel, on behalf of Mr. Ortale, has been informed that his probation officer, Ms. Jennifer
Amato, does not obj ect to vacating Mr. Orta1e’s probation.
5. As set forth in more detail in the accompanying memorandum of law, the sentencing factors
set forth at 18 U.S.C §3553 support the early termination of supervised release.
VVHEREFORE, it is respectfully requested that the Court grant Mr. Ortale’s motion for early
termination of his supervised release pursuant to 18 U.S.C. §3583(e) and 18 U.S.C. §3564(c).
THE DEFENDANT, ERNEST ORTALE
By: QJ E g 2 g
’ David R. Gronbach
Moynahan & Minnella, LLC
141 East Main Street, P.O. Box 2242
Waterbury, Connecticut 06722-2242
Phone No. (203) 573-1411
Facsimile No. (203) 757-9313
Email Address: dg;[email protected]
Federal Bar No. ct26900

Case 3:00-cr-00249-JCH Document 202 Filed 07/20/2007 Page 3 of 4
ORDER
The foregoing motion having been heard is hereby:
GRANTED / DENIED
Judge / Clerk

Case 3:00-cr-00249-JCH Document 202 Filed 07/20/2007 Page 4 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : Case No.: 3:00-CR-00249 (J CH)
ERNEST ORTALE : JULY 19, 2007
CERTIFICATE OF SERVICE
This is to oertify that a copy of the foregoing Motion To Terminate Supervised Release
And Supporting Memorandum has been served by lmail on this l9°h day of July, 2007 to:
The United States District Court
At Bridgeport
915 Lafayette Boulevard
Bridgeport, CT 06604
USAA Peter Youngblood
157 Church Street, 23"1 Floor
New Haven, CT 06510
Jennifer Amato
Connecticut Probation Office
Hartford Divisional Office
735 Abraham Ribicoff Federal Building
450 Main Street
Hartford, CT 06103-3022
» avid R. Gronbach
Federal Bar No.: ct26900