CAUSE NO. _____________
THE STATE OF TEXAS	§	IN THE DISTRICT COURT OF
	§
v.	§	_____________ COUNTY, TEXAS
	§
_____________	§	_____________ JUDICIAL DISTRICT

MOTION TO TERMINATE PROBATION
TO THE HONORABLE JUDGE OF SAID COURT:
	COMES NOW _____________ , the Defendant in the above styled and numbered cause, and pursuant to Article 42.12, Section 5(c) of the Texas Code of Criminal Procedure, respectfully moves the Court to terminate the period of probation in this cause, permit him to withdraw his plea of nolo contendere, and dismiss the indictment against him and discharge him. In support of this motion, the Defendant would show the Court as follows:
I.
	The Defendant was charged by indictment with the felony offense of _____________, and pleaded _____________. On _____________, this Court placed the Defendant on deferred adjudication probation for a period of two years.
II.
	The Defendant has now satisfactorily completed almost one year of the probationary period, and has complied with all the terms and conditions of said probation. The Defendant has fully and promptly complied with all reporting and other requirements imposed upon him during this period of his probation by the Court and by his probation officer.
III.
	The Defendant has earned strong support from the communities in which he lives and works, and by complying with all the terms and conditions of his probation, and considering his strong abiding citizen, and a productive member of the community.
IV.
	The ends of justice have been served, and the interest of the Defendant and of society will best be served by the Defendant being discharged from further deferred adjudication probation.
	WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that after conducting an inquiry this Honorable Court will terminate the period of probation in this cause, permit him to withdraw his plea of nolo contendere, dismiss the indictment against him and discharge him.

 Respectfully submitted,
 GROSS & ESPARZA, P.L.L.C.

 Michael C. Gross
 State Bar No. 08534480
 106 South St. Mary’s Street, Suite 260
 San Antonio, Texas 78205 (210) 354-1919
 (210) 354-1920 (Fax)

 Attorney for the Defendant

CERTIFICATE OF SERVICE
	This is to certify that a true and correct copy of the above referenced Motion to Terminate Probation was delivered to _____________, Assistant District Attorney, on this  day of _____________, 20__.

CAUSE NO. _____________
THE STATE OF TEXAS	 §	IN THE DISTRICT COURT OF
	§
v.	§	_____________ COUNTY, TEXAS
	§
_____________	§	_____________ JUDICIAL DISTRICT

ORDER

	On this ____ day of _____________, 20__, this cause coming on to be heard on Motion of the Defendant and this Court being fully advised in the premises and having been fully apprised of the following facts:
	That the Defendant in the above styled and numbered cause pleaded _________ to the felony offense of ___________. On _____________, this Court placed the Defendant on deferred adjudication probation for a period of two years;
	That the Defendant has satisfactorily completed almost one year of the probationary period and has complied with all the terms and conditions of said probation; and
	The Court is of the opinion that the ends of justice have been served, and that the interests of the Defendant and of society will best be served by discharging the Defendant from further probation, permitting the Defendant to withdraw his plea of nolo contendere, and dismissing the indictment against him.
	Therefore, it is hereby ORDERED, ADJUDGED AND DECREED that the Defendant’s deferred adjudication probation is terminated, his plea of nolo contendere is withdrawn, and the indictment herein is dismissed. The Defendant is hereby released and discharged from all penalties and disabilities resulting from the proceedings against him.
	SIGNED AND RENDERED on the _____________ day of _____________ 20__.

	
 JUDGE PRESIDING