Case: 3:09-cr-00002-GHD-SAA Doc #: 222 Filed: 07/10/12 1 of 3 PageID #: 2295

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI UNITED STATES OF AMERICA, Plaintiff, v. BOBBY B. DELAUGHTER, Defendant. ) ) ) ) ) ) )

No. 09 CR 002-2 Judge Glen H. Davidson Magistrate Judge S. Allan Alexander

DEFENDANTS UNOPPOSED MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE Defendant, BOBBY B. DELAUGHTER, by and through his attorneys, THOMAS ANTHONY DURKIN and LAWRENCE L. LITTLE, pursuant to 18 U.S.C. 3583(e)(1) and Rule 32.1(B) of the Federal Rules of Criminal Procedure, respectfully moves this Court for the early termination of Defendants Supervised Release, in that early termination comports with the factors set forth in 18 U.S.C. 3553(a), is warranted by the conduct of Defendant while on Supervised Release, and is in the interests of justice. In support of this motion, Defendant, through counsel, shows to the Court the following: 1. On November 13, 2009, Defendant was sentenced by this Court to imprisonment

for a term of 18 months, to be followed by a term of Supervised Release of two (2) years as to Count Five. The Court did not order any special conditions of Supervised Release. Defendant was not ordered to pay any fine or restitution. In terms of monetary penalties, only the $100.00 special assessment was ordered, and that amount has been paid. 2. On January 4, 2010, Defendant surrendered to the Bureau of Prisons to begin

service of his sentence. 3. 4. On April 22, 2011, Defendant was released to Supervised Release. As of July 10, 2012, Defendant has successfully completed more than one-half of

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the term of Supervised Release, and has continuously complied with all of his terms of Supervised Release including any and all financial obligations. 5. It is respectfully submitted that Defendant is no longer in need of further

supervision, and it is in the interests of justice and a savings of judicial resources to terminate his Supervised Release early. Undersigned counsel, Durkin, has spoken with Deputy U.S. Probation Officer Marilyn Brasset who stated that her office has no objection to early termination of Defendants Supervised Release. 6. Undersigned counsel, Durkin, has also communicated with Assistant U.S.

Attorney Robert H. Norman who also has stated that his office has no objection to the early termination of Defendants Supervised Release. WHEREFORE, Defendant respectfully requests that this Court enter an order terminating his Supervised Release forthwith. Respectfully submitted,

/s/ Thomas Anthony Durkin THOMAS ANTHONY DURKIN

/s/ Lawrence L. Little LAWRENCE L. KITTLE, Attorneys for the Defendant Bobby B. DeLaughter. DURKIN & ROBERTS 2446 North Clark Street Chicago, IL 60614 (312) 913-9300 LAWRENCE L. LITTLE & ASSOCIATES, PA 829 North Lamar Boulevard, Suite 6 Oxford, Mississippi 38655 (662) 236-9396 2

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CERTIFICATE OF SERVICE I hereby certify that the foregoing DEFENDANTS UNOPPOSED MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE was served on July 10, 2012, in accordance with Fed.R.Crim.P.49, Fed.R.Civ.P.5, LR 5.5, and the General Order on Electronic Case Filing (ECF) pursuant to the district courts system as to ECF filers.

/s/ Thomas Anthony Durkin THOMAS ANTHONY DURKIN 2446 North Clark Street Chicago, IL 60614 (312) 913-9300