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

Case 3:03-cr-00029-JCH

Document 12

Filed 10/03/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA vs. RICHARD CICHON

: : : CRIMINAL NO. 3:03CR29(JCH) October 3, 2006

MOTION TO TERMINATE PROBATION The defendant, Richard Cichon, respectfully moves this Court to terminate the term of probation imposed on July 29, 2003. In support of this motion, the defendant states the following: 1. Under 18 U.S.C. §3564(c), the Court, "after considering the factors set forth in Section 3553(a) to the extent they are applicable, may, pursuant to the provisions of the Federal Rules of Criminal Procedure relating to the modification of probation, terminate a term of imprisonment previously ordered and discharge the defendant at any time in the case of a misdemeanor or an infraction or after the expiration of one year of probation in the case of a felony, if it is satisfied that such action is warranted by the conduct of the defendant and the interest of justice." 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 special 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 community service and by making full restitution. 4. The purposes of sentencing set forth in Section 3553(a) have been fulfilled, the defendant's conduct during the term of probation demonstrates that there is no longer a need for supervision, and the interest of justice would be served by terminating probation more than three years after sentencing was imposed.

Case 3:03-cr-00029-JCH

Document 12

Filed 10/03/2006

Page 2 of 2

-2Respectfully submitted, THE DEFENDANT, RICHARD CICHON THOMAS G. DENNIS FEDERAL DEFENDER Dated: October 3, 2006 /s/ 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 on October 3, 2006, a copy of the foregoing MOTION TO TERMINATE PROBATION was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. /s/ Paul F. Thomas ct01724 Office of the Federal Defender 2 Whitney Ave, Suite 300 New Haven, CT 06510 Phone: (203) 498-4200 Fax: (203) 498-4207 Email: [email protected]