Reply to Opposition to Motion to Modify Conditions of Supervised Release — United States v. Reardon (Dkt. 236)

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A Defendant's Reply to Government's Opposition to Motion to Modify Conditions of Supervised Release, filed April 10, 2025 as Document 236 in United States v. Nathan Reardon, Case No. 1:21-cr-00061-LEW, in the U.S. District Court for the District of Maine; the filing is dated April 7, 2025. Nathan Reardon writes in the first person and asks the Court to remove the conditions prohibiting self-employment and requiring participation in the Computer and Internet Monitoring Program. The reply states that the filer has complied with all conditions since the October 13, 2023 revocation hearing, that electronic monitoring is not reasonably related to the offense of PPP bank fraud, and that the self-employment ban prevents restitution and rehabilitation. It also asks for a hearing.

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Case 1:21-cr-00061-LEW Document 236 Filed 04/10/25 Pagelof2 PagelD#:
1470

UNITED STATES DISTRICT COURT be
FOR THE DISTRICT OF MAINE oA os

UNITED STATES OF AMERICA
V.
NATHAN REARDON

Case No. 1:21-cr-00061-LEW

DEFENDANT’S REPLY TO GOVERNMENT?’S OPPOSITION TO MOTION TO
MODIFY CONDITIONS OF SUPERVISED RELEASE

I, Nathan Reardon, respectfully submit this reply to the government’s opposition (Dkt. #231) to
my motion to modify the conditions of my supervised release (Dkt. #230, Mar. 11, 2025). I
request that the court grant my motion to remove the conditions prohibiting self-employment and
requiring participation in the Computer and Internet Monitoring Program for the following
reasons:

1. Full Compliance with Supervised Release for Over a Year: | have been fully
compliant with all conditions of my supervised release since my revocation hearing on
October 13, 2023 (Dkt. #183-85), with no violations or issues reported by the U.S.
Probation Office. At that hearing, I apologized to the court and my probation officer,
committing to seek employment separate from my father’s businesses and to comply
fully with all conditions (Dkt. #183, pp. 19-20). My consistent compliance since then
demonstrates my commitment to rehabilitation and adherence to the law, suggesting that
the current restrictive conditions are no longer necessary to achieve the goals of
supervised release, such as deterrence or public safety, as outlined in 18 U.S.C. §
3553(a).

2. Electronic Monitoring Is Not Reasonably Related to My Offense: The condition
requiring electronic monitoring is not reasonably related to my offense of PPP bank
fraud, as the offense did not involve significant use of the internet or electronic devices in
a manner that would justify such a restriction. I have only had one bank loan in 25 years
of operating a business, demonstrating that I am not a serial bank fraudster or a high-risk
offender. Electronic monitoring imposes a significant deprivation of my privacy and
liberty, which exceeds what is reasonably necessary under 18 U.S.C. § 3583(d).
Furthermore, I believe I may be the only individual in the District of Maine charged with
PPP-related bank fraud who is subject to this condition, suggesting that it is
disproportionate compared to similarly situated defendants. I respectfully request that the
court review whether this condition is standard for PPP fraud cases in this district and
whether it remains necessary in my case.

3. Self-Employment Ban Prevents Restitution and Rehabilitation: At my initial
sentencing on November 2, 2022 (Dkt. #155-59), the court indicated that a total ban on
self-employment was overly restrictive and suggested a more balanced approach.
Specifically, Judge Walker stated, “I also agree with Mr. Tzovarras that a total ban on
Case 1:21-cr-00061-LEW Document 236 Filed 04/10/25 Page2of2 PagelD#:
1471

self-employment is probably a bridge too far. I think there is a middle ground to be had
here. I think that the probation officer can work with Mr. Reardon to ensure that he is not
in a position where he is managing money or has access to bank accounts, but I think a
total ban on self-employment is probably overly broad” (Dkt. #155, p. 15). AUSA Lizotte
responded, “We want to ensure that restitution is paid back as quickly as possible, and if
some form of employment can achieve that while mitigating risks, we would be amenable
to that” (Dkt. #155, p. 15). Despite these statements, the current condition imposes a
broad prohibition on self-employment, which prevents me from earning a living and
repaying restitution efficiently. At my revocation hearing on October 13, 2023, I
expressed my desire to work to repay the loan, noting that I cannot achieve this goal
while in jail (Dkt. #183, p. 20). Allowing me to engage in self-employment, with
appropriate restrictions as the court suggested in 2022, would enable me to repay
restitution more quickly, which aligns with the government’s stated goal and the goals of
rehabilitation and victim compensation under 18 U.S.C. § 3553(a). Given my compliance
and the court’s prior statements, I respectfully request that this condition be modified to
allow self-employment, consistent with the “middle ground” approach the court intended.

Conclusion: For the reasons stated above, I respectfully request that the court grant my motion
to modify the conditions of my supervised release by removing the requirements for electronic
monitoring and the prohibition on self-employment. These modifications are warranted under 18
U.S.C. § 3583(e) and would better serve the goals of supervised release while allowing me to
continue my rehabilitation and repay restitution. I also respectfully request a hearing on this
motion to allow me to present additional evidence of my compliance and the court’s intent at
sentencing regarding the self-employment condition.

Dated: April 7, 2025

Bangor, Maine —y~ a
Respectfully submitted,
Nathan Reardon

PO Box 52

Detroit, ME 04929
207-745-7575
nathan@membershipauto.com

=
—

Certificate of Service
I, Nathan Reardon, certify that on April 7, 2025, I served a copy of this reply on the government
by mailing it via U.S. Postal Service to Andrew K. Lizotte, Assistant United States Attorney, at

202 Harlow Street, Bangor, ME 04401.

Dated: April 7, 2025
Nathan Reardon


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