Motion for Early Termination of Supervised Release — U.S. v. Blotnick (D.N.J.)

Record facts

U.S. District Court, District of New Jersey · No. 2:21-cr-00796-BRM · Doc. 32 · 2026-03-23 · Docket on CourtListener

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NOTICE OF MOTION AND MOTION TO TERMINATE SUPERVISED RELEASE 
United States v. Blotnick, No. 2:21-CR-00796-BRM 
GREGORY J. BLOTNICK 
345 Banyan Blvd #913 
West Palm Beach, FL 33401 
gjb209@gmail.com 
 
UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
 
UNITED STATES OF AMERICA 
vs. 
GREGORY J. BLOTNICK 
Case No.: 2:21-CR-00796-BRM-1 
NOTICE OF MOTION AND MOTION 
FOR EARLY TERMINATION OF 
SUPERVISED RELEASE 
 
 
Defendant Gregory J. Blotnick, appearing pro se, respectfully moves this Court to terminate his 
supervised release term pursuant to 18 U.S.C. § 3583(e)(1) and U.S.S.G. § 5D1.4. In support: 
 
I. 
PROCEDURAL HISTORY 
 
1. On June 7, 2022, I was sentenced in this Court to 51 months’ imprisonment followed by 
two years of supervised release for wire fraud and money laundering. 
2. On March 12, 2025, I commenced supervised release in the Southern District of Florida, 
reporting directly to Probation Officer Danielle Caron. 
3. As of March 12, 2026, I have completed over one year, or 50%, of my two-year term, 
incident-free and in full compliance with all conditions of supervision. 
4. On March 16, 2026, I contacted Probation Officer Caron to ascertain Probation’s position 
regarding this motion. As of the date of filing, I have not yet received a response. 
Case 2:21-cr-00796-BRM     Document 32     Filed 03/23/26     Page 1 of 8 PageID: 253

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NOTICE OF MOTION AND MOTION TO TERMINATE SUPERVISED RELEASE 
United States v. Blotnick, No. 2:21-CR-00796-BRM 
II. 
BACKGROUND & RESTITUTION 
 
5. I have no prior criminal history and am a non-violent, first-time offender. 
6. During the 2020 pandemic, I knowingly and voluntarily committed loan fraud through 
the Paycheck Protection Program. I make no excuses for my actions; I was wrong, and I 
take responsibility for the harm I caused as I steadily rebuild trust with family and friends. 
7. I have consistently made good-faith restitution payments exceeding the court-
ordered minimum, with six consecutive months of increased contributions as my 
financial circumstances have improved (see Exhibit A: Payment History).  
8. I remain fully committed to satisfying the remaining balance post-termination through 
the Financial Litigation Unit. Termination of supervision will not affect this obligation. 
 
III. 
REHABILITATION & REINTEGRATION 
 
9. In 2021, I completed 30 days of inpatient rehabilitation. I am now four years fully sober. 
10. I have built a new career in digital marketing and work at The Discoverability 
Company as a project manager, where I assist small businesses with their online footprint 
and AI/LLM-readiness. My role is unrelated to the conduct underlying my offense.   
11. My employer has written a letter supporting this motion (see Exhibit B). 
12. I have reintegrated into the community, volunteering at Feeding South Florida, teaching 
ESL at DePorres Place, and providing mentorship through the Aleph Institute. 
13. I have authored two books supporting addiction and mental health recovery, with all 
book proceeds donated to the American Foundation for Suicide Prevention (AFSP). 
Case 2:21-cr-00796-BRM     Document 32     Filed 03/23/26     Page 2 of 8 PageID: 254

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NOTICE OF MOTION AND MOTION TO TERMINATE SUPERVISED RELEASE 
United States v. Blotnick, No. 2:21-CR-00796-BRM 
IV. 
CONCLUSION 
 
I understand that compliance alone does not merit early termination. However, the § 3553(a) 
factors, viewed in light of my conduct, show that continued supervision is no longer necessary. 
 
As a non-violent, first-time offender, my post-sentencing record reflects stable employment, 
housing, sobriety, consistent community involvement, and restitution payments exceeding the 
required minimum. My current career is unrelated to the conduct underlying my offense and 
poses no risk to public safety.  
 
I have fully reintegrated into society while maintaining recovery; no further treatment is needed, 
and early termination would also allow Probation to focus resources on higher-risk individuals. 
 
Continued supervision no longer serves the interests of justice, and early termination is 
warranted under 18 U.S.C. § 3583(e)(1) and U.S.S.G. § 5D1.4. 
 
WHEREFORE, I respectfully request that the Court grant this motion. 
 
 
 
 
 
 
Date: March 23, 2026  
 
 
 
Respectfully submitted, 
 
/s/ Gregory J. Blotnick________ 
GREGORY J. BLOTNICK, Pro Se 
345 Banyan Blvd #913 
West Palm Beach, FL 33401 
gjb209@gmail.com
Case 2:21-cr-00796-BRM     Document 32     Filed 03/23/26     Page 3 of 8 PageID: 255

 
 
EXHIBIT A – RESTITUTION PAYMENT HISTORY (POST-RELEASE) 
 
 
 
 
Case 2:21-cr-00796-BRM     Document 32     Filed 03/23/26     Page 4 of 8 PageID: 256

 
 
EXHIBIT B – EMPLOYER LETTER 
 
 
Case 2:21-cr-00796-BRM     Document 32     Filed 03/23/26     Page 5 of 8 PageID: 257

 
 
EXHIBIT B – EMPLOYER LETTER 
 
 
 
 
 
 
 
Case 2:21-cr-00796-BRM     Document 32     Filed 03/23/26     Page 6 of 8 PageID: 258

 
 
UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
 
UNITED STATES OF AMERICA 
vs. 
GREGORY J. BLOTNICK 
Case No.: 2:21-CR-00796-BRM-1 
 
 
CERTIFICATE OF SERVICE 
 
I, Gregory J. Blotnick, Defendant pro se, certify that on March 23, 2026, I served a true 
and correct copy of this motion upon the following parties via the methods indicated below: 
 
Via U.S. First Class Mail: 
United States Attorney’s Office 
District of New Jersey 
Attn: Criminal Division / Case No. 2:21-CR-00796-BRM-1 
970 Broad Street, Suite 700 
Newark, NJ 07102 
 
Via Electronic Mail: 
Probation Officer Danielle Caron 
United States Probation Office 
501 South Flagler Drive 
West Palm Beach, FL 33401 
danielle_caron@flsp.uscourts.gov 
 
 
 
 
 
 
 
/s/   Gregory J. Blotnick             
Date: March 23, 2026  
 
 
 
GREGORY J. BLOTNICK, Pro Se 
345 Banyan Blvd #913 
West Palm Beach, FL 33401 
gjb209@gmail.com 
 
Case 2:21-cr-00796-BRM     Document 32     Filed 03/23/26     Page 7 of 8 PageID: 259

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NOTICE OF MOTION AND MOTION TO TERMINATE SUPERVISED RELEASE; PROPOSED ORDER 
United States v. Blotnick, No. 2:21-CR-00796-BRM 
GREGORY J. BLOTNICK 
345 Banyan Blvd #913 
West Palm Beach, FL 33401 
gjb209@gmail.com 
 
UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
 
UNITED STATES OF AMERICA 
vs. 
GREGORY J. BLOTNICK 
Case No.: 2:21-CR-00796-BRM-1 
[PROPOSED] ORDER FOR EARLY 
TERMINATION OF SUPERVISED 
RELEASE 
 
 
 
GOOD CAUSE APPEARING, and upon consideration of Defendant’s motion for early 
termination of supervised release, 
IT IS on this ____ day of ________, 2026, 
ORDERED that Defendant Gregory J. Blotnick’s request for early termination of his 
period of supervised release is hereby GRANTED. 
 
 
 
 
 
 
 
 
_________________________ 
HON. BRIAN R. MARTINOTTI 
United States District Judge 
 
 
 
Case 2:21-cr-00796-BRM     Document 32     Filed 03/23/26     Page 8 of 8 PageID: 260

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