Case 1:11-cr-00262-KD-N Document 480 Filed 02/19/16 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
UNITED STATES OF AMERICA,

)
)
v.
) Criminal No. 11-00262
)
STANLEY MARSHALL WRIGHT,
)
Defendant. )
MOTION TO TERMINATE SUPERVISED RELEASE
NOW COMES the defendant and moves the court to terminate the term of
supervised release which was imposed in the above case. As grounds for this motion the
defendant would show:
1. On June 28, 2013 Wright was sentenced to fifteen months imprisonment, fined
$10,000, ordered to pay $27,300 restitution, placed on three years of supervised release, and
ordered to pay a $400 special assessment. (Doc. 445)
2. Wright has served the sentence of imprisonment, has paid the fine and the special
assessment, and has made restitution. He has been under supervision for nearly 18 months
and has faithfully complied with all of the terms and conditions of supervised release.
3. Since the defendant has successfully completed more than one year of supervised
release, he meets the requirement of 18 U.S.C. §3583(e)(1) for termination of supervision.
Stanley Wright’s age, stable family and community background, lack of criminal history,
business acumen and financial resources, as well as his conduct while under supervision1,
strongly indicates there is no risk of recidivism. The family’s oyster processing business
1

In addition to the present supervised release, the defendant was released on conditions on October 12, 2011
and for more than 18 months abided by the terms of pretrial supervision.

 Case 1:11-cr-00262-KD-N Document 480 Filed 02/19/16 Page 2 of 2

suffered during the period of his incarceration. In order to rebuild the business Wright must
travel to maintain contact with suppliers and customers, and develop new markets.
Termination of supervision will enable him to do this more freely.
4. Termination of supervised release is appropriate in consideration of the factors in
18 U.S.C. §3553(a) and would serve the interests of justice.
WHEREFORE the defendant prays that the court will terminate the term of
supervised release and grant such other and further relief as he maybe entitled to receive the
premises considered.

/s/ Arthur J. Madden, III
Arthur J. Madden, III
MADDA0656
Attorney for Defendant
465 Dauphin Street
Mobile, Alabama 36602
(251) 432-0380

CERTIFICATE OF SERVICE
I hereby certify that on February 19, 2016 I electronically filed the foregoing with
the Clerk of the Court using the CM/ECF system which will send notification of such filing
to the following:
AUSA Sean P. Costello, Esq.
63 South Royal Street, Suite 600
Mobile, Alabama 36602
/s/ Arthur J. Madden, III
Arthur J. Madden, III