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

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AUG 3 0 2000
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2 Manne Del Rey, CA 90292 EYWH NA
Telephone (310) 488-4901 rr e *`i""`““—‘—·-·— DEPUTY
3 Pre Per Defendant
4 IN THE UNITED STATES DISTRICT COURT
5 DISTRICT OF ARIZONA
6 UNITED STATES OF AMERICA l .
7 Plaintiff, ; CR 04-00623-002-PHX-SRB
8 ) DEFENDANT'S MOTION TO
"S· i TERMINATE Pnoaarion
9 CATHERINE S. NELSON l
10 Defendant, l
11 )

12 COMES NOW the defendant, representing myself who respectfully requests that
13 this Honorable Court terminate my probation pursuant to Rule 32. l(b) of the Federal
14 Rules of Criminal Procedure and IS U.S.C. §3564(c). In support of this Motion, I state:
15 l. On June 15, 2004 , I entered a plea of guilty to one count of healthcare fraud in
16 violation of 18 U.S.C. §l347, a Class D felony.
17 2. I was sentenced on January 3, 2005, to a three year term of probation, a
18 $4,000.00 fine and $100.00 special assessment and placed under the supervision ofthe U.S.
19 Probation Office for the United States District Court for the Central District of California.
20 3. The statute governing early termination of probation, 18 U.S.C. §3564(c)
21 provides in pertinent part that the court may terminate a term of probation at any time
22 after the expiration of one year of probation in the case of a felony if it is satisfied that
23 such action is warranted by the conduct of the defendant and the interest of justice.
24 4. In January 2005, I paid off my $4,000.00 fine and $100.00 special assessment.
25 5. On November 3, 2005, due to my favorable adjustment while on supervision,
26 my case was transferred from U.S.P.O. Roberta Houlton to the Administrative Caseload
27 reporting to U.S.P.O. Rachel Salamanca. Ms. Salamanca told me that she would review my
28 case in July, 2006 and she would recommend an early tennination of my probation.
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6. On June 23, 2006, I was infonned that Ms. Rachel Salamanca was no longer in
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the Inglewood Branch of the United States Probation Office to which I was assigned.
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7. On August 17, 2006, I talked to Ms. Erica Jackson at the United States Probation
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Office. She informed me that the United States Probation Office is not taking a position on
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my early termination of probation at this time and that I can petition the Honorable Court for
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an early termination myself.
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8. Ms. Ashley Adams-Feldman, the Assistant U.S. Attorney on my case, is no longer
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employed by the U.S. Attorney Office.
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9. I have been on probation since January 3, 2005, and have proven thatl meet
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the criterion based on my good conduct for early termination of my probation under 18
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U.S.C. §3564(c).
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WHEREFORE, I respectfully request that, in the interest of justice, the Court grant my
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motion for early termination of probation pursuant to 18 U.S.C. §3564(c) and Rule
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32.1(b).
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Respectfully submitted this 23rd day of August, 2006
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is
Br
19 Catherine S. Nelson
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22 | J ; · » of the foregoing Motion
and-delivered this 23rd day
23 of August, 2006, to:
24 Clerk of Court
Sandra Day O'Connor U.S. Courthouse
25 Suite 130
401 West Washington Street- SPC 1
26 Phoenix, Arizona 85003-2118
27 - = ;. ofthe foregoing Motion
@· and-delivered this 23rd day
28 of August, 2006, to:
Case 2:04-cr—00623—SRB Document 104 Filed 08/30/2006 Page 2 of 3

1 U.S. Attorney
ATTN: Mr. Howard Sunkenic
2 Two Renaissance Square
40 North Central Avenue, Suite 1200
3 Phoenix, Arizona 85004-4408
4 Ms. Erica Jackson
U.S. Probation Ottice
5 One La Brea Plaza
lll N. La Brea Aveune, Suite 209
5 lnglewood, Calitomia 90301-4602
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8 { Q
By U·-·».-
9 Catherine S. Nelson
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