IN THE CIRCUIT COURT, SIXTH JUDICIAL CIRCUIT

IN AND FOR PINELLAS COUNTY, STATE OF FLORIDA

FELONY DIVISION

STATE OF FLORIDA
vs.

UCN: 521993CF007005XXXXBI
REF: CRC9307005CFANO-D

DENNIS D. CORREA
SPN: 01073379

0)

MOTION TO CONVERT REMAINING

PROBATION TO ADMINISTRATIVE PROBATION

'~;',\:.
'-:,.~

Comes now, the defendant, by and through his undersigned attorney,

-u

;...

~~

\:

-;
'\

'and!116ve~iS
..
\
\

honorable court for an order, converting the remaining fifteen years of his probation to
administrative probation, and as grounds therefor would show:
1.

The only remaining outstanding condition of probation is restitution.

2.

The defendant has paid court ordered restitution each and every month since he

was placed on probation fifteen years ago.

3.

At the last hearing, the court found that the only reason that the defendant is on

probation is to oversee collection of payments.

4.

The defendant has been on probation for fifteen years with no problems or

violations.
5.

The defendant has complied with every court order.

6.

The defendant already has permission to work out ofthe county with extended rights

to stay overnight for business purposes.

7.

Converting the defendant's remaining probation to administrative probation would

enable the defendant to obtain the highest paying job for restitution purposes.
8.

The crimes are financial in nature, not violent crimes or drug related.

,.. .

"

9.

The defendant would still be available to meet with the probation officer anytime that

the office determined it was appropriate to meet with him.

WHEREFORE, the defendant herein respectfully prays that this honorable court will convert
the remaining part of his probation to administrative probation and change his reporting
requirements from once a month to once a year.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy hereof has been furnished by maii to the Office of Bernie
McCabe, State Attorney, Post Office Box 5028, Clearwater, FL 33758, and to Michael Lambert,
Department of Corrections, Probation and Parole, 11351 Ulmerton Road, Suite 200, Largo, Florida
~--"'1

33778, on January

_ l _ ' ,2009.

;' S/(

,0,-

/ GREGORY L. "O_LNEY II, ESQUIRE

Meros, Smith, Lazzara & Olney, P.A.
Post Office Box 27

81. Petersburg, Florida 33731

(727) 822-4929/ Fax (727)821-7140
8PN: 00241712 FBN: 362913
Attorney for Defendant