Motions for Early

Discharge From Probation

*NOTE: The below should not be construed as a promise or guarantee of similar results. Results will vary depending on the particular facts and legal circumstances of each individual case.

State v. B.B. – Ms. Denholtz successfully filed and argued a motion for early termination from probation.  Client was sentenced to a term of 2 years of probation.  About 1 year and 3 months into his probationary term, client received notice his employer wanted him to move out of state to work for the company at a different location.  Ms. Denholtz showed the Court that the client had been in full compliance with all of the terms of his probation leading up to the filing of the motion.  The Court granted B.B.’s motion and B.B. was successfully discharged from probation 9 months early.

State v. J.H. – Ms. Denholtz successfully argued a motion for early termination from probation.  Client was sentenced to 1 year of probation with various terms.  About 7 months into his probationary term, J.H. decided that he wanted to move out of state.  Ms. Denholtz showed the Court that the client was in full compliance with all of the terms of his probation.  The Court granted J.H.’s motion and J.H. was successfully discharged from probation 5 months early.

State v. G.S. – Ms. Denholtz successfully argued a motion for early termination from probation.  The client was sentenced to a period of 36 months of probation (3 years).  After completing just 13 months of his probation, Ms. Denholtz was able to show the court that G.S. was substantially in compliance with the conditions of his probation, and he had completed a 6-month anger management program.  The Court granted G.S.’s motion and G.S. was successfully discharged from probation 23 months early.

State v. J.L. – Client contacted Ms. Denholtz to seek to end his probationary term early so he could move to Puerto Rico to live with his father.  The client was placed on probation for a period of 4 years and had only completed 14 months of that 4-year period.  Ms. Denholtz collected extensive information which showed that the client’s performance on probation during those 14 months was exemplary—he had completed anger management treatment, paid his fines, and was in full compliance with all other conditions of his probation.  Ms. Denholtz successfully filed and argued a Motion for Early Termination From Probation, which was granted by the Court. The Client was released from probation approximately 34 months early.

State v. K.G. – Ms. Denholtz successfully negotiated a PTI resolution for a client charged with many firearms offenses.  After completing 1.5 years of PTI, Ms. Denholtz successfully filed and argued a Motion for Early Discharge from Probation, by showing that the client had been in full compliance with all of the terms of his probation for more than half of the 3-year probationary period.  The Court granted this motion and the client was released from probation approximately 18 months early.

State v. M.V. - Ms. Denholtz successfully argued a Motion for Early Discharge from Probation by showing the court that the client completed all of the conditions of his probation, remained offense free, and had no violations of probation during his probationary term.  The Court granted the motion and the client was released from probation early.

State v. R.S. - Client was charged with felony-level possession with intent to distribute, possession of CDS, possession of drug paraphernalia, and money laundering.  The State executed a search warrant of client’s home that client shared with other people.  They found a large quantity of drugs in common areas of the apartment.  State’s plea offer was initially a 5-year State Prison sentence.  Ms. Denholtz successfully made the State realize that there was no way they could connect the drugs found in the apartment to the Client, because they were found in common areas of the shared apartment (which meant the drugs could have belonged to anyone in the apartment, not necessarily the Client).  Ms. Denholtz negotiated a plea to one disorderly person’s offense (equivalent of a misdemeanor), and dismissal of all felony charges.  Client was placed on 1-year of probation, and Ms. Denholtz successfully argued a motion to end the Client’s probation early after approximately 8 months.

State v. K.G. - Client was charged with unlawful possession of several firearms.  The Client was a retired police officer with no prior criminal history.  His guns were validly registered in another state but not in New Jersey.  The State’s opening plea offer was for K.G. to plead guilty to 2nd degree Unlawful Possession of a Firearm subject to 3 years in New Jersey State Prison with a 1 year parole disqualifier.  This case was heavily negotiated.  The Client was eligible for the Pre-Trial Intervention diversionary program but the State and the alleged victim were adamantly opposed to this as a resolution.  After months of negotiation, the State ultimately relented and allowed the Client to enter a conditional guilty plea to enter PTI.  20 months into his 36 month PTI term, Ms. Denholtz filed a Motion for Early Discharge from Probation, highlighting the fact that the Client had been in substantial compliance with probation.  The Court granted this Motion and the Client was successfully discharged from PTI 16 months early.  All of his charges were dismissed as a result.