STIPULATION REQUESTING EARLY TERMINATION OF SUPERVISED RELEASE

JENNIFER A. DORSEY, District Judge.

The Defendant, Louis Washington, by and through his counsel of record, Rebecca Levy, Assistant Federal Public Defender, submits this stipulation for early termination of supervised release.

STATEMENT OF FACTS

Louis Washington was indicted on September 9, 2014, with one count of Felon in Possession of a Firearm, in violation of 18 U.S.C. § 922(g). On December 2, 2014, Mr. Washington pled guilty without a plea agreement. On April 6, 2015 Mr. Washington was sentenced to eight months in custody and also three years of supervised release with eight months of home confinement on electronic monitoring. He is now out of custody on supervised release. On November 21, 2016, counsel for Mr. Washington filed a Motion for Early Termination of Supervised Release. Docket #35. On November 30, 2016, the Court held a hearing and while the motion wasn't granted, the Court specifically stated that a renewed motion or joint stipulation would be entertained if Mr. Washington continued to do well over the next six-months. Docket #38. Mr. Washington has continued to do well and thus, the government is agreeing to the termination of supervised release.

ARGUMENT

Mr. Washington has been on supervision since his release from custody over a year and a half ago. He has had no violations of supervised release. When he was first released, Mr. Washington had 8 months of home confinement with electronic monitoring. This confinement came with strict conditions, allowing him to leave for work. Mr. Washington started working as soon as he could, striving to better himself and his family. Mr. Washington and his fiancé have a three-year old and a four-month old, along with his seven-year old from a prior relationship. Mr. Washington pays child support for his seven-year old and fully supports his two other children as his fiancé is a stay-at-home mom. Mr. Washington fully completed counseling, which included several sessions per week. After he completed the counseling through Federal Probation, Mr. Washington enrolled on his own ongoing counseling paid by insurance. This is counseling he continues to attend bi-monthly.

Currently, Mr. Washington is working two jobs. He is working full-time at Firestone Auto Center. In addition to this full-time job, Mr. Washington works at Concrete Crafting of Centennial. Prior to his incarceration, Mr. Washington was doing long haul truck driving. He had to take a break from that work after a car accident. Mr. Washington would like the opportunity to do that type of work again if he was released from supervised release. Mr. Washington's life consists of work and taking care of his family. His attitude remains as positive as it was during the pendency of his underlying case. Mr. Washington is committed to making a better life for himself and his family.

Probation Officer, Elizabeth Olsen, now supervises Mr. Washington. Mr. Washington continues to do well on supervision and has had no violations.

Accordingly, Mr. Washington respectfully requests that the Court terminate the remainder of his supervision. The government is in agreement with this request.

IT IS SO ORDERED.