Motion for Early Termination of Probation — United States v. Imeesha Bradley (S.D. W. Va.)

Record facts

U.S. District Court, Southern District of West Virginia · No. 2:23-cr-00112 · Doc. 53 · 2026-03-25 · Docket on CourtListener

Full text

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IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA 
 
CHARLESTON DIVISION 
 
 
UNITED STATES OF AMERICA 
 
v. 
 
 
 
 
 
 
 
 Criminal No. 2:23-00112 
 
IMEESHA BRADLEY 
 
 
MOTION FOR EARLY TERMINATION OF PROBATION 
 
 
Defendant, Imeesha Bradley, through Assistant Federal Public Defender 
Emily L. Szopinski, moves this Court pursuant to 18 U.S.C. § 3564(c) and requests 
the Court terminate the remaining portion of her five-year term of probation.  In 
support of this Motion, Ms. Bradley states as follows: 
1. 
On January 9, 2024, Ms. Bradley appeared before this Court for 
sentencing in conjunction with her guilty plea to a single count of receipt of stolen 
money in violation of 18 U.S.C. § 2315.  Dkt. No. 28.   
2. 
Ms. Bradley’s underlying offense involved applying for and receiving the 
proceeds of a Paycheck Protection Program Loan.  Ms. Bradley received this money 
during the pandemic, which was a financially trying time for her as a single mother 
of two young children.  Ms. Bradley used the proceeds of the loan to purchase clothes 
and shoes for her children, help family members who needed money for groceries or 
who were behind on rent because of the pandemic, and provide financial support to 
her sister who was about to start college in South Carolina and who was recovering 
from a traumatizing incident.   
Case 2:23-cr-00112     Document 53     Filed 03/25/26     Page 1 of 4 PageID #: 168

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3. 
Ms. Bradley was sentenced to a sixty-month term of probation.  Dkt No. 
29.  As part of her judgment, Ms. Bradley was also ordered to pay restitution in the 
amount of $18,703.00.  Id. 
4. 
Pursuant to 18 U.S.C. § 3564(c), the Court may terminate probation 
after one year after consideration of the 18 U.S.C. § 3553(a) factors, if such action is 
warranted by the conduct of the defendant and the interests of justice.   
5. 
Ms. Bradley has served 26 months of her term of probation. 
6. 
Since her sentencing in this case, Ms. Bradley has made consistent 
payments towards her restitution.  See Dkt Nos. 33-34, 36, 38-52.  Additionally, Ms. 
Bradley’s tax returns have been garnished and applied towards her restitution.  
7. 
Accordingly, as of March 25, 2026, Ms. Bradley has satisfied her 
restitution obligation. 
8. 
Ms. Bradley has been residing in Jacksonville, Florida, for the pendency 
of her probationary period.  There, she established a strong community within her 
church.   
9. 
Ms. Bradley has three young children who are the main priority in her 
life. 
10. 
Ms. Bradley has been working with a realty company in Jacksonville 
where she has been renovating and cleaning properties.  Specifically, her duties have 
included painting, demolition of floors, and staging and cleaning the properties. 
Case 2:23-cr-00112     Document 53     Filed 03/25/26     Page 2 of 4 PageID #: 169

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11. 
Prior to the instant offense, Ms. Bradley had never been arrested or 
charged with another criminal offense.  She has continued to live a law-abiding life 
while serving her term of probation. 
12. 
Since Ms. Bradley was released on bond on August 1, 2023, she has not 
had any non-compliance violations related to her pretrial supervision or her probation 
supervision. 
13. 
The instant offense was clearly an aberration in Ms. Bradley’s otherwise 
law-abiding life, and she has taken great strides to overcome the hurdle that her new 
felony conviction has created. 
14. 
Nevertheless, Ms. Bradley will continue to be marked by the felony 
conviction and all of its attendant consequences. 
15. 
Ms. Bradley has demonstrated that she has been and will continue to be 
a law-abiding citizen.  In nearly three years of supervision by the United States 
Probation Office, Ms. Bradley has complied with her release conditions, met her 
restitution obligation, maintained employment, and continued living a law-abiding 
life. 
16. 
Ms. Bradley’s pre- and post-offense conduct demonstrates that she does 
not need additional supervision by the United States Probation Office to continue 
leading a law-abiding life.   
17. 
Additionally, Ms. Bradley’s supervising probation officer in the 
Southern District of West Virginia, Jordan Clark, supports Ms. Bradley’s request for 
early termination of her probation.   
Case 2:23-cr-00112     Document 53     Filed 03/25/26     Page 3 of 4 PageID #: 170

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18. 
Undersigned counsel has attached to this Motion a letter which Ms. 
Bradley wrote to the Court supporting her early termination of probation. See Exhibit 
A. 
19. 
Additionally, counsel has attached several character letters written by 
members of Ms. Bradley’s community who have gotten to know her over the past 
several years.1 
In conclusion, Ms. Bradley respectfully requests that the Court terminate the 
remainder of her term of probation. 
Date: March 25, 2026. 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
IMEESHA BRADLEY 
 
 
 
 
 
 
 
 
By Counsel 
WESLEY P. PAGE 
FEDERAL PUBLIC DEFENDER 
 
s/Emily L. Szopinski    ________________                
Emily L. Szopinski, WV Bar No. 14231 
Assistant Federal Public Defender 
Office of the Federal Public Defender 
300 Virginia Street, East, Room 3400 
Charleston, WV 25301 
Telephone: (304) 347-3350 
Facsimile: (304) 347-3356 
E-mail: Emily_Szopinski@fd.org  
 
 
1 The character letters refer to Imeesha Bradley as Imeesha Miller as Ms. Bradley primarily goes by 
her maiden name, Imeesha Miller. 
Case 2:23-cr-00112     Document 53     Filed 03/25/26     Page 4 of 4 PageID #: 171

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