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ELIZABETH A. STRANGE

Acting United States Attorney District of Arizona

VINCENT Q. KIRBY

Assistant U.S. Attorney Arizona State Bar No. 006377

Two Renaissance Square

40 N. Central Ave., Suite 1200

Phoenix, Arizona 85004

Telephone: 602-514-7500

Email: Vincent.Kirby@usdoj.gov Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff, 

vs. 

Robert Wood, III,

Defendant.

CR-15-50201-PHX-DGC

GOVERNMENT’S RESPONSE TO 

DEFENDANT’S MOTION TO 

TERMINATE SUPERVISED RELEASE 

TERM

The government strongly objects to any termination of his supervised release at this 

time, which is only 21 months into his court-ordered supervision of 60 months. The 

supervising probation officer also objects to the early termination request.

In this case, the defendant was convicted in the Eastern District of Missouri of the 

crimes of Count 1 Conspiracy to Distribute Cocaine and Count 2 Conspiracy to Commit 

Money Laundering. He faced a Guideline Range of 360 to Life based on the amount of 

drugs involved and his Criminal History of VI. (PSR ¶ 87.) He was also subject to a 

statutory minimum of ten years in prison. (PSR ¶ 86.) Originally, he was sentenced to 

120 months of custody but that was later amended to ten months. He was ordered to serve 

five years of supervised release on Count 1 and two years on Count 4. Supervision began 

on July 17, 2015.

At the time that the defendant committed the underlying crime he was on supervised 

release again out of the Eastern District of Missouri for the crime of Count 1 Conspiracy 

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to Distribute Marijuana, Cocaine and Cocaine Base and Count 6 Possession with Intent to 

Distribute Cocaine - CR-96-00114-ERW. (PSR ¶ 57.) He received 120 months of 

confinement in BOP along with five years of supervised release. He was described as the 

leader/organizer of that 1996 conspiracy. (PSR ¶ 59.) That supervision started on 

December 26, 2004 and the conspiracy in the instant case began in January 2005. The 

supervision in CR-96-00114-ERW was revoked based on the instant conviction and he was 

sentenced to 60-months in custody. (PSR ¶ 60.) 

The defendant’s criminal history includes convictions for Possession of a Controlled 

Substance in 1989; Assault Second Degree in 1989 involving a shooting; a 1990 

Conspiracy to Commit Robbery Second Degree again involving a weapon; Possession of 

a Controlled Substance in 1991 as well as the 1996 Conspiracy to Distribute Cocaine 

described above. (PSR ¶¶ 41, 45, 49 53, and 57.) His probation terms in all of those cases 

were revoked except for the 1991 Possession case.

In the instant case, the defendant was distributing eight to ten multi-kilogram 

cocaine shipments to the St. Louis area up to a total of 120 kilograms from the start of his

supervised release term. (PSR ¶ 13-14.) Similar to his 1996 conviction, the defendant was 

found the most culpable of the conspirators that included a local police department sergeant 

and was assessed a 4-level enhancement to his Guideline calculation as the 

leader/organizer. (PSR ¶¶ 23, 18 and 33.)

According to the probation officer, the defendant has not worked for anyone other 

than himself. He has yet to submit paperwork to the probation department establishing that

RJW Investments is a legitimate company. It is the assessment of the supervising probation

officer that this “business” is more of a hobby than a full time business. The officer was 

also unaware of the defendant’s claim that he has volunteered time at homeless shelters 

and food banks.

Furthermore, there have been no issues with approving the defendant’s travels in a 

timely manner. He has frequently been approved to return to St. Louis to visit family and 

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has even been allowed to travel to Tennessee for business purposes.

The government submits that based on his committing the current offenses shortly 

after the start of his earlier supervised release and the lack of stable employment that the 

Court should deny the Motion as premature.

Respectfully submitted this 22nd day of May 2017.

ELIZABETH A. STRANGE

Acting United States Attorney

District of Arizona

S/Vincent Q. Kirby VINCENT Q. KIRBY

Assistant U.S. Attorney

Case 2:15-cr-50201-DGC Document 3 Filed 05/22/17 Page 3 of 3