IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI UNITED

STATES OF AMERICAN, Plaintiff, v. SONNY VLEISIDES, Defendant. ) ) ) ) ) ) ) ) )

Case No. 11-00125-01-CR-W-GK

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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