STIPULATED REQUEST FOR EARLY TERMINATION OF PROBATION AND ORDER
The United States of America, by and through its counsel the United States Attorney, and defendant Jessica McLellan, by and through undersigned counsel of record, hereby stipulate and agree as follows:
1. Ms. McLellan pled guilty on October 23, 2006, to one count charging her with securities fraud in violation of 15 U.S.C. §§ 78j(b) & 78ff and 17 C.F.R. § 240.10b-5. United States District Court Judge Percy Anderson of the Central District of California sentenced Ms. McLellan primarily to three years of probation and 300 hours of community service. See United States v. McLellan, No. CR 03-00940-PA (C.D. Cal.), Docket # 75. The case was transferred in May 2007 to this Court pursuant to 18 U.S.C. § 3605. Docket # 1.
2. Since sentencing, Ms. McLellan has complied in all ways with the terms of her probation, paid all applicable fines and fees, and completed more than 500 hours of community service. Ms. McLellan's Probation Officer, Wayne Mirikitani, informs counsel that the Probation Office has no objection to the early termination of Ms. McLellan's probation.
3. Ms. McLellan's probationary status hampers her work. Ms. McLellan is seeking employment that requires international travel, but foreign officials have at times denied her access to their countries because of her probationary status. Ms. McLellan understands that termination of her probationary status may aid in lifting these restrictions.
4. Judge Anderson of the United States District Court for the Central District of California has already granted early termination of probation to four defendants whose convictions arose from the same scheme as Ms. McLellan's. See United States v. Kalina, No. CR 03-0012-PA (C.D. Cal.) Docket # 59; United States v. Chan, No. CR 04-1259-PA (C.D. Cal.) Docket # 45; United States v. Patel, No. CR 03-00940-PA (C.D. Cal.) Docket # 78; United States v. Infeld, No. CR 04-1259-PA (C.D. Cal.) Docket # 31.
5. Wherefore, the undersigned parties request that Ms. McLellan's probation be terminated.
THOMAS O'BRIEN United States Attorney for the Central District of California By: Michael R. Wilner Assistant United States Attorney Central District of California Counsel for the United States of America
ARGUEDAS, CASSMAN & HEADLEY, LLP By: Raphael M. Goldman Counsel for Jessica McLellan
PURSUANT TO STIPULATION, it is SO ORDERED.
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