Motion, Expunge Record of His August 2023 Probation Violation — United States v. Reardon (D. Me., Dkt. 244)

Summary

A motion filed May 8, 2025 as Document 244 in United States v. Nathan Reardon, Criminal No. 1:21-cr-00061-LEW, in the U.S. District Court, District of Maine, by Nathan Reardon, proceeding pro se. It asks the Court to expunge the record of his August 2023 probation violation and related incarceration. The motion states that the violation was for a supervised release condition prohibiting self-employment, that the First Circuit Court of Appeals struck down the same condition in May 2024, and that the district court vacated the ban in April 2025. It asks the Court to expunge the violation from his criminal record, strike references to it from the docket and BOP file, and declare the condition unconstitutional as applied. The motion bears the /s/ signature of Nathan Reardon, Pro Se.

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Case 1:21-cr-00061-LEW Document 244 _ Filed 05/08/25 Pagelof2 PagelD#:
1500

UNITED STATES DISTRICT COURT
DISTRICT OF MAINE

UNITED STATES OF AMERICA, MS HAY -9 D1
Plaintiff,

NATHAN REARDON,
Defendant.

Criminal No, 1:21-cr-00061-LEW

COMES NOW, Nathan Reardon, Defendant, proceeding
pro se, and respectfully moves this Court to expunge the
record of his August 2023 probation violation and related
incarceration. This motion is grounded in newly available
appellate authority and constitutional considerations, and
seeks to correct a profound miscarriage of justice.

On or about August 2023, Defendant was arrested and
incarcerated for allegedly violating a condition of
supervised release that prohibited self-employment.
Defendant consistently objected to this restriction, noting it
lacked statutory basis and unjustly interfered with his
livelihood.

In May 2024, the First Circuit Court of Appeals issued a
ruling striking down this same self-employment condition
as unconstitutional. Despite this appellate ruling, the
district court had previously enforced the condition and
ordered Defendant’s incarceration. In April 2025, the same
court vacated the self-employment ban, validating
Defendant’s long-standing position that it was unlawfully
imposed and enforced.

The record of the probation violation and related
incarceration must be expunged for the following reasons:

1. The condition forming the basis of the violation was later
deemed unlawful by the First Circuit.
2. Enforcement of the condition violated Defendant’s due
CRG ck sda ARO 061-LEW Document 244 _ Filed 05/08/25 Page2of2 PagelD#:

3. Continued retention of the sieilafion i Defendant’s
record imposes collateral consequences that are
unwarranted and unjust.

4. The supervising attorney, Hunter Tzovarras, failed to
timely file for relief from the condition despite multiple
requests, contributing to Defendant’s wrongful
incarceration.

5. The district court itself recognized the overreach and has
since rescinded the condition.

This probation violation is constitutionally tainted and
factually unsupported. It would be inequitable and unlawful
for it to remain on Defendant’s record.

Defendant respectfully requests this Court to:

(1) Expunge the August 2023 probation violation from his
criminal record;

(2) Strike all references to the violation from the docket and
BOP file;

(3) Declare the condition unconstitutional as applied in this
case;

(4) Grant any, additional relief deemed just and proper.

Respectfully submitted,
/s/ Nathan Reardon

Nathan Reardon, Pro Se

773 Lower Detroit Rd.

Plymouth, ME 04969

Phone: 207-745-7575

Email: nathan@membershipauto.com


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