Court filing
Motion for Early Termination of Supervised Release — United States v. Bully (S.D. Fla.)
Filed February 27, 2026 in U.S. v. Bully; one of 11 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2026-02-27 |
U.S. District Court for the Southern District of Florida · No. 9:23-cr-80141-DMM · Doc. 33 · 2026-02-27 · Docket on CourtListener
Full text
-1- LAW OFFICES OF PAUL D. PETRUZZI, P.A. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 23-CR-80141-DMM UNITED STATES OF AMERICA, : : Plaintiff, : : : v. : : EMMANUEL BULLY, JR, : : Defendant. : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE The Defendant, EMMANUEL BULLY, JR, through undersigned counsel, pursuant to 18 U.S.C. § 3583(E)(1) and [with/without] the agreement of the United States Attorney’s Office, respectfully requests that this Honorable Court enter an Order terminating the balance of his supervised release. In support, Mr. Bully states as follows: 1. On December 7, 2023, Mr. Bully was sentenced to 24 months of incarceration followed by two years of supervised release. Mr. Bully served his sentence and was released on January 15, 2025, to begin serving his sentence of supervised release with special conditions. 2 Mr. Bully successfully completed a total of 250 hours of community service. See letter from The Underline attached as Exhibit A. The Underline is a community organization tasked with the care, maintenance, and utilization of the park space below the Metrorail in Miami. Mr. Bully demonstrated his commitment to the organization through hands on volunteer work cleaning trash and debris, weeding out overgrown areas, and assisting in Family Day events for the community. Id. Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 1 of 12 -2- LAW OFFICES OF PAUL D. PETRUZZI, P.A. 3, Mr. Bully also renewed his faith with family and loved ones; being Baptized in his church and attending events with his church community doing good works and expressing their beliefs. See Certificate of Baptism attached as Exhibit B. 4. Since his release, and in addition to his work, family, church, and community service, Mr. Bully returned to school to complete his Bachelor's Degree. Mr. Bully attended Florida Atlantic University and graduated in December of 2025 with a Bachelor’s Degree in Science. See attached composite Exhibit C. 5. Mr. Bully has been employed by Taylor Sports Group since his release. Mr. Bully has served in an administrative role within the company, supporting and managing the needs of its and is looking forward to expanding his responsibilities. MEMORANDUM OF LAW Supervised release eases a defendant’s transition to community life and facilitates training and rehabilitation. See United States v. Johnson, 529 U.S. 53, 59-60 (2000). Mr. Bully is asking for that opportunity. Where continued supervision no longer serves the goals at sentencing for the rehabilitated, it may be terminated early. Thus, district court may, after considering the factors in Sections 3553(a)(1), (a)(2)(B), (a)(2)(C), (a)(2)(D), (a)(4), (a)(5), (a)(6) and (a)(7): terminate a term of supervised release and discharge the defendant released at any time after the expiration of one year of supervised release, pursuant to the provisions of the Federal Rules of Criminal Procedure relating to the modification of probation, if it is satisfied that such action is warranted by the conduct of the defendant released and the interest of justice. 18 U.S.C. § 3583(e)(1). In determining whether early termination is warranted, the district court must consider the nature and circumstances of the offense and the history and characteristics of the Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 2 of 12 -3- LAW OFFICES OF PAUL D. PETRUZZI, P.A. defendant; the need for deterrence, to protect the public, and to provide correctional treatment for the defendant; the advisory Sentencing Guidelines and pertinent U.S. Sentencing Commission policy statements; the need to avoid unwarranted sentencing disparities; and the need to provide restitution to any victims of the offense. United States v. Cochran, 815 Fed.Appx. 361, 363 (11th Cir. 2020); see also United States v. Reagan, 162 Fed.Appx. 912, 914 (11th Cir. 2006); 18 U.S.C. §§ 3553(a), 3853(e)(1). Because the language of Section 3583(e)(1) notes that the district court “may” terminate supervised release if it is satisfied that “such action is warranted by the conduct of the defendant released and the interest of justice,” a district court has discretion in deciding whether to terminate a defendant’s supervised release. See United States v. Perry, 397 Fed.Appx. 521 (11th Cir. 2010); United States v. Johnson, 877 F.3d 993, 997 (11th Cir. 2017) (“We review a district court’s denial of a motion for early termination of supervised release for an abuse of discretion.”). The phrase “the interest of justice” gives the court latitude to consider a broad range of factors in addition to a defendant’s behavior in considering whether to terminate her supervised release. United States v. Pregent, 190 F.3d 279, 282 (4th Cir. 1999). “Occasionally, changed circumstances – for instance, exceptionally good behavior by the defendant or a downward turn in the defendant’s ability to pay a fine or restitution imposed as conditions of release – will render a previously imposed term or condition of release either too harsh or inappropriately tailored to serve the general punishment goals of section 3553(a).” United States v. Lussier, 104 F.3d 32, 36 (2nd Cir. 1997). Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 3 of 12 -4- LAW OFFICES OF PAUL D. PETRUZZI, P.A. The Guide to Judiciary Policy Section (e) states that after the expiration of one year of supervised release in subsequent assessments, there is a presumption in favor of recommending early termination for probationers and supervised releasees: (1) Who have been under supervision for at least 18 months and (a) are not career violent and/or drug offenders (as described in 28 U.S.C. § 994(h)), sex offenders, or terrorists, (b) present no identified risk to the public or victims, and (c) are free from any moderate (see: Guide, Vol 8E,§ 620.40.20) or high (see: § 620.40.30) severity violations; and (2) Who have been under supervision for at least 42 months and (a) are not career violent and/or drug offenders (as described in 28 U.S.C. § 994(h)), sex offenders, or terrorists, and (B) are free from any moderate (see: Guide, Vol 8E, § 620.40.20) or high (see: § 620.40.30) severity violations. Guide to Judiciary Policy, Vol. 8E, Ch. 3 § 380.10(b), “Early Termination” (Monograph 109) (rev’d 2010) (emphasis added). Pursuant to this policy, “there is a presumption in favor of recommending early termination” for supervisees after 12 months if they are not “career violent and/or drug offenders, sex offenders, or terrorists,” if they “present no identified risk to the public or victims,” and if they are “free from any moderate or high severity violations.” Id., §380.10(g). The early termination of Mr. Bully’s supervised release is appropriate given his conduct. He gave his time in community service, he graduated from Florida Atlantic University with a Bachelor’s degree, he re-established his faith and has done so while being employed. Pursuant to Local Rule 88.9, undersigned made numerous attempts to obtain the position of the United States attorney and has received no response to both emails and phone calls, thus the position of the United States is unknown. Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 4 of 12 -5- LAW OFFICES OF PAUL D. PETRUZZI, P.A. WHEREFORE, the Defendant, EMMANUEL BULLY, JR, through undersigned counsel, and pursuant to 18 U.S.C. § 3583(E)(1), respectfully requests that this Honorable Court enter an Order terminating the balance of his supervised release. Respectfully submitted, Law Offices of Paul D. Petruzzi, P.A. 8101 Biscayne Blvd. PH 701 Miami, FL 33138 Telephone: (305) 373-6773 E-mail: petruzzi-law@msn.com By: /s/ Paul D. Petruzzi PAUL D. PETRUZZI, ESQ. Florida Bar No. 982059 CERTIFICATE OF SERVICE I hereby certify that, on February 27, 2026, a true and correct copy of the foregoing was furnished by CM/ECF to all parties of record. By: /s/ Paul D. Petruzzi PAUL D. PETRUZZI, ESQ. Attorney for Defendant Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 5 of 12 Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 6 of 12 Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 7 of 12 Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 8 of 12 Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 9 of 12 Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 10 of 12 Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 11 of 12 Case 9:23-cr-80141-DMM Document 33 Entered on FLSD Docket 02/27/2026 Page 12 of 12
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