Reply to Government's Opposition to Motion to Expunge Probation Violation (D. Me., Dkt. 260, filed 06/02/25)

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A Reply to Government's Opposition to Motion to Expunge Probation Violation, filed June 2, 2025 as Document 260 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, pro se. The reply states that the Government's response fails to address the core issues. It argues that the Defendant was not self-employed during the period in question, listing the absence of a corporate registration, authority over business bank accounts, compensation or invoices, and signed contracts, and says the only act cited was a message to a tenant sent before supervised release began. It states that admissions were made under duress at an October 2023 hearing. The reply asks that the motion be granted or that an evidentiary hearing be scheduled.

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Case 1:21-cr-00061-LEW Document 260 Filed 06/02/25 Pagelof2 PagelD#:
1671

UNITED STATES DISTRICT COURT _

DISTRICT OF MAINE
UNITED STATES OF AMERICA
Nathan Reardon

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

REPLY TO GOVERNMENT’S OPPOSITION TO
MOTION TO EXPUNGE PROBATION VIOLATION

Now comes the Defendant, Nathan Reardon, pro se, and
respectfully submits this Reply to the Government’s
Opposition (Dkt. #244) to his Motion to Expunge the
Probation Violation. The Government’s response fails to
meaningfully address the core issues raised by the
Defendant, including the misapplication of legal standards,
procedural misconduct, and material omissions that led to a
fundamentally flawed revocation process.

1. The Government cites Violation of Special Condition #6
on Page 1, stating that 'Defendant shall not be self-
employed.' However, the Defendant was not self-employed
during the period in question. Specifically:

- Defendant was not listed on any corporate registration;

- Defendant held no authority over business bank accounts;
- Defendant did not receive compensation or issue invoices;
- Defendant did not sign contracts or exercise decision-
making control.

Thus, Defendant did not meet any objective legal criteria
for self-employment.

The Government’s argument relies on Defendant ‘acting as
self-employed,’ but that is a subjective characterization not
grounded in statutory or regulatory definition. The only act
cited was a message to a tenant sent prior to the
commencement of supervised release. Sending such a
message, without more, does not establish self-employment
and does not fulfill any formal test for independent
contractor or entrepreneurial status.
violations during the October 2023 htffng. Defendant
maintains that these admissions were made under duress
due to his pre-hearing detention, emotional pressure related
to his minor children, and lack of full disclosure—
specifically, the omission of exculpatory testimony from
Unit 8 tenants. These concessions do not equate to
knowing, voluntary, and intelligent waivers of his
constitutional rights.

3. Defendant reasserts that the revocation proceedings were
predicated on incomplete and misleading information, and
that the conduct alleged was either non-violative or did not
occur while under supervision. For example, the alleged
text message predated probation start, and Oswald relied on
subjective interpretations rather than objective legal
thresholds.

WHEREFORE, Defendant respectfully reiterates his
request that the Court grant the Motion to Expunge the
Probation Violation, or in the alternative, schedule an
evidentiary hearing to resolve the contested factual and
constitutional yssyés presented.

Respectfally submitted,
Nathan Reardon
773 Lower Detroit Rd.
Plymouth, ME 04969
nathan@membershipauto.com
(207) 745-7575
Pro Se Defendant


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