United States District Court, E.D. California
HEATHER E. WILLIAMS, Bar#122664 Federal Defender VICTOR M.
CHAVEZ, Bar #113752 Assistant Federal Defender Attorneys for
Defendant ISRAEL CARLOS TORRES
NOTICE OF MOTION AND UNOPPOSED MOTION TO TERMINATE
PROBATION; MEMORANDUM OF POINTS AND AUTHORITIES; ORDER
(HEARING NOT REQUESTED)
LAWRENCE J. O'NEILL UNITED STATES CHIEF DISTRICT JUDGE
SCOTT W. McGREGOR, UNITED STATES ATTORENY, AND KIMBERLY A.
SANCHEZ, ASSISTANT UNITED STATES ATTORNEY, COUNSEL FOR
TAKE NOTICE that defendant, Israel Torres, through
undersigned counsel, hereby files this motion for early
termination of probation. The motion is directed to the
Honorable Lawrence J. O'Neill. The defendant requests
that the Court grant this motion without first holding a
hearing based on the fact that Probation Officer, Adam
Tunison supports the motion and the government has no
objection to it.
Torres, by his counsel of record, Assistant Federal Defender
Victor M. Chavez, hereby moves this Court for an order
terminating his term of probation. This motion is made
pursuant to 18 U.S.C. § 3564(c), Eastern District of
California Local Rule Crim. 430.1, and such other statutory
rules as may be applicable.
motion is based upon the instant motion and notice of motion,
the accompanying statement of facts and memorandum of points
and authorities, the files and records in the above-entitled
case, and all other information that may be brought to the
Court's attention before or during any hearing on this
1. On January 9, 2014, Israel Torres was
charged by indictment with Count 1; felon in possession of a
firearm. (18 USC § 922(g)(1)), Count 2; possession of a
stolen firearm. (18 USC § 924(d)(1)).
2. Mr. Torres plead guilty to felon in
possession of a firearm, 18 USC § 922(g)(1) on February
3. On July 18, 2016 this Court sentenced Mr.
Torres to a five year term of probation.
4. On July 18, 2019 Mr. Torres successfully
completed 3 years of probation.
5. Mr. Torres requests early termination of
his probation. His probation officer Adam Tunison supports
6. On July 19, 2019 Assistant United States
Attorney Kimberly A. Sanchez advised the defense, by email,
that she does not have any objection to Mr. ...