This document is a notice of motion and motion filed by attorney Donald M. Re on behalf of his client Serhat Gumrukcu. It requests (1) early termination of Gumrukcu's 5-year probation, having already served 2.5 years, and (2) relief under Penal Code Section 1203.4 to withdraw his plea, reduce the offense to a misdemeanor, and dismiss the case. Both the California Attorney General and Gumrukcu's probation officer consent to these motions. The document provides background on Gumrukcu's plea and sentencing and argues he has performed well on probation.