Page 1 – UNOPPOSED MOTION FOR EARLY TERMINATION OF 

PROBATION 

HOEVET OLSON HOWES, PC

ATTORNEYS AT LAW

1000 S.W. BROADWAY, #1500

PORTLAND, OREGON 97205

(503) 228-0497

Celia Howes, OSB #033450

HOEVET OLSON HOWES, PC 

1000 SW Broadway, Suite 1500

Portland, Oregon 97205

Telephone: (503) 228-0497

Facsimile: (503) 228-7112

Email: celia@hoevetlaw.com

Of Attorneys for Defendant 

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

UNITED STATES OF AMERICA,

Plaintiff,

v.

KYLE KEOKI YAMAGUCHI,

Defendant.

Case No. 3:14-CR-00282-SI-2

UNOPPOSED MOTION FOR EARLY 

TERMINATION OF PROBATION

Defendant, Kyle Keoki Yamaguchi, moves to terminate his probation pursuant to 

18 U.S.C. § 3564(c): 

“Early Termination.— The court, after considering the factors set forth in 

section 3553(a) to the extent that they are applicable, may, pursuant to the 

provisions of the Federal Rules of Criminal Procedure relating to the modification 

of probation, terminate a term of probation previously ordered and discharge the 

defendant at any time in the case of a misdemeanor or an infraction or at any 

time after the expiration of one year of probation in the case of a felony, if it is 

satisfied that such action is warranted by the conduct of the defendant and the 

interest of justice.”

/ / /

/ / /

Case 3:14-cr-00282-SI Document 96 Filed 10/19/17 Page 1 of 3
Page 2 – UNOPPOSED MOTION FOR EARLY TERMINATION OF 

PROBATION 

HOEVET OLSON HOWES, PC

ATTORNEYS AT LAW

1000 S.W. BROADWAY, #1500

PORTLAND, OREGON 97205

(503) 228-0497

On April 8, 2015, the Court entered a judgment of conviction and imposed a 

sentence of five years of probation as a result of Mr. Yamaguchi’s guilty plea to one 

count of Conspiracy to Transport, Receive, and Sell Stolen Goods (18 USC 371, 2314, 

2315). Mr. Yamaguchi’s conditions of probation included compliance with the terms of 

his civil settlement with Nike, Inc and complete 50 hours of community service. 

October 8, 2017 marked Mr. Yamaguchi’s halfway point, he has now served over 

30 months of his five-year probationary period. He has complied with all of the special 

and standard conditions of his probation, including compliance with his civil settlement 

and volunteer service in his community. Mr. Yamaguchi moved to Hawaii in September 

2015, and his supervision was thereafter transferred to the District of Hawaii. He 

maintains a stable home in Maui with his wife and two children, ages 1 and 3. He has 

been fully compliant with the terms of his probation, and has been on the administrative 

caseload with the District of Hawaii for over one year.

Mr. Yamaguchi runs an eyewear company with his wife. Business operations 

require that they make international trips to source supplies and manufacturing 

resources. His status on probation has resulted in Mr. Yamaguchi's temporary 

detentions at airports upon reentry into the United States.

The factors set forth in 18 U.S.C. § 3553(a)(1) and (a)(2)(B), (a)(2)(C) and (a)(4) 

support an early termination of supervised release. Mr. Yamaguchi’s conduct while on 

probation and the interest of justice warrant a termination of his supervised release at 

this time. 

Case 3:14-cr-00282-SI Document 96 Filed 10/19/17 Page 2 of 3
Page 3 – UNOPPOSED MOTION FOR EARLY TERMINATION OF 

PROBATION 

HOEVET OLSON HOWES, PC

ATTORNEYS AT LAW

1000 S.W. BROADWAY, #1500

PORTLAND, OREGON 97205

(503) 228-0497

This motion is supported by the Declaration of Counsel filed simultaneously with 

this motion. Neither the United States Probation Office, nor the United States Attorney’s 

Office, through AUSA Ryan Bounds, objects to this motion.

DATED this 19TH day of October, 2017.

HOEVET OLSON HOWES, PC 

 s/ Celia Howes 

Celia Howes, OSB #033450

Of Attorneys for Defendant

Case 3:14-cr-00282-SI Document 96 Filed 10/19/17 Page 3 of 3