IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF MISSOURI

UNITED STATES OF AMERICAN, )

)
Plaintiff, )
)
v. ) Case No. 11-00125-01-CR-W-GK
)
SONNY VLEISIDES, )
)
Defendant. )

MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE

PURSUANT TO TITLE 18 U.S.C. §3583(e)(1)

Sonny Vleisides, through undersigned counsel, respectfully requests that this Court

terminate his supervised release pursuant to Rule 32.1 (c) of the Federal Rules of Criminal

Procedure and 18 U.S.C. §3583(e)(1). Mr. Vleisides has demonstrated exemplary post-

conviction conduct during his period of supervision to this point and exceeded all expectations

set by the United States Probation Office. Accordingly, Mr. Vleisides hereby moves the Court

for an entry of an order terminating his supervised release. The U.S. Probation Officer is in

support of this request.

BACKGROUND

On February 28, 2007, Mr. Vleisides and four codefendants were charged in the United

States District Court for the Central District of California in an 23-Count Indictment alleging

various violations of 18 U.S.C. §1341 and 18 U.S.C. § 1956(a)(1)(A)(i), (2). Following a

complicated series of factual and legal events, including extradition proceedings, Mr. Vleisides

was sentenced to time served by the Court on September 15, 2010. Mr. Vleisides pled guilty to

Count 1 of the Indictment.

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 Mr. Vleisides was placed on supervised release for a term of three years. With the

permission of the Court, the United States Attorney’s Office for the District of California,

Central District, and the United States Probation Office, Mr. Vleisides returned home to Kansas

City, Missouri to live and work. The United States District Court for the Central District of

California transferred the case to the Kansas City area for supervision responsibilities. United

States Probation Officer Courtney Pierce has had supervision responsibilities for Mr. Vleisides

since his arrival in the Kansas City area more than two years ago. To this point, Mr. Vleisides

has served two years of his three year supervised release term. His supervised release term is

scheduled to end in September of 2013.

ARGUMENT

Under 18 U.S.C. § 3583(e)(1), the Court has the authority to grant early termination of a

previously imposed term of supervised release. Section 3583(e)(1) provides:

(e) Modification of condition or revocation. The court may, after considering the factors
set forth in Section 3553(a)(1), (a)(2)(B), (a)(2)(C), (a)(2)(D), (a)(4), (a)(5), (a)(6), and
(a)(7)

(1) 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); see also Fed. R. Crim. Procedure 32.1(c)(1), (2)(B) & (C) (providing for

hearings for modifications of supervised release, unless the result is favorable to the person

supervised and the government does not object after notice).

As of the filing of this motion, Mr. Vleisides will have successfully completed nearly 25

months of his 36-month term of supervision, leaving him with less than a year remaining. Mr.

Vleisides has performed well during his period of supervised release: he has had no new contacts

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with law enforcement, he has paid his special assessment, he has not engaged in any business

venture related to the basis for the original Indictment that was filed in 2007, and he has

cooperated with the US Probation Office in any and every way that has been required of him.

Mr. Vleisides took his obligations to obey all conditions of his supervised release very seriously.

Despite his conviction, Mr. Vleisides has made a positive contribution to society. Initial

job offerings for Mr. Vleisides following his conviction in 2010 were limited. He is a hard

worker, but found that doors for employment were often closed once a potential employer

learned that he had a felony conviction. Not content to let the mistakes of his past determine his

future, Mr. Vleisides decided that he would forge ahead with the development of his own

business. He has always had a love for all things technology related and a gifted mind. He

realized that with great focus and commitment he could combine these qualities to produce a

product that had great benefit in the business world.

With the generous support of his family and friends, Mr. Vleisides began working to

create a line of high speed encryption processors for use in research, telecommunication and

security applications. An idea that originally began on napkins, scraps of paper, and spare parts

on his kitchen table has taken shape and become the driving success behind a company located

here in Kansas City, Missouri named Butterfly Labs. His constant work as a product

development executive has helped fuel the success of the venture, which has created

approximately 22 jobs in the Kansas City area since 2010. This is particularly noteworthy given

the declining status of employment in our country during the same time period.

Mr. Vleisides enjoys his work and takes great pride in what he is doing on a daily basis.

The hours that Mr. Vleisides has put in to develop the product have been long and arduous.

There have been times when he arrived before the sun came up and left after it went down. But,

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this work has given him a purpose that will keep him on track to be a better citizen and a better

man. He is remorseful about what has occurred, but looks to a brighter future as he continues

down this current path of enlightenment and productivity. The justice system could not ask for

more from a person that has been punished.

Mr. Vleisides seeks to grow the business opportunities for Butterfly Labs. His goals

include participation in trade show events that will allow him to showcase the processor that he

has helped create, meetings with manufacturing groups, and general networking events outside

of the Kansas City area. The current limitations placed on him by his conditions of supervised

release prevent these possibilities and could be a potential liability to the company’s growth in

this industry. In the field of technology, delays in development and exposure of a product can

have a negative impact on the future viability of a company. Early release from his term of

supervision will ensure that these potential consequences are not a factor.

CONCLUSION

The exemplary performance demonstrated by Mr. Vleisides during his period of

supervised release warrants a reduction in his term. He has the approval of the United States

Probation Office to seek this reduction and respectfully moves this Court under 18 U.S.C. §

3583(e)(1) for early termination of his term of supervised release.

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 Respectfully submitted,

BERKOWITZ OLIVER WILLIAMS

SHAW & EISENBRANDT, LLP

By: /s/ Shazzie Naseem

Shazzie Naseem MO#59142
2600 Grand Blvd, Suite 1200
Kansas City, Missouri 64108
(816) 561-7007 (telephone)
(816) 561-1888 (facsimile)
Email: snaseem@bowse-law.com

CERTIFICATE OF SERVICE

I hereby certify that on the 5th day of October, 2012, I electronically filed the foregoing

with the clerk of the court using the CM/ECF system which sent the notification of filing to all

counsel of record.

/s/ Shazzie Naseem

Attorney for Defendant

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