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

UNITED STATES OF AMERICA, Plaintiff, v. SONNY CHRIS VLEISIDES, Defendant. Case No. 11-00125-01-CR-W-DGK

JOINT MOTION FOR ENTRY OF ORDER MODIFYING PREVIOUS ORDER ON CONDITIONS OF SUPERVISED RELEASE WITH SUGGESTIONS IN SUPPORT

Defendant Sonny Chris Vleisides, by and through undersigned counsel, and the United States jointly move this Court for the entry of an Order modifying conditions of the defendants supervised release. In further support of this request, the parties state as follows: 1. On September 5, 2013, this Court issued an Order to Show Cause pursuant

to Criminal Rule of Procedure 32.1. The Courts Show Cause Order sought information regarding why defendants previously imposed conditions of supervised release should not be revoked. (See Doc. 11). The defendants supervised release was set to expire on September 15, 2013. The defendant acknowledges that the district court had jurisdiction to revoke his supervised release after September 15, 2010, because the Show Cause notice was issued before the defendants term of supervised release had expired. See 18 U.S.C. 3583(i)(court has jurisdiction to revoke supervised release so long as before its

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expiration, a warrant or summons has been issued on the basis of an allegation of such a violation.). 2. Due to a series of mutually agreeable continuances by both parties to

gather facts and conduct discovery, the revocation hearing to determine whether any supervised release conditions had been violated did not begin until December 17, 2013. The hearing began, but was continued to January 28, 2014, to allow defense counsel more time to confront facts and issues presented in the first hearing. 3. The final Order in this case was issued on January 31, 2014. (Doc. 29).

That Order extends the defendants period of supervised release for an additional twentyfour (24) months, but does not indicate the date the extension becomes effective. 4. The parties are mindful of 18 U.S.C. 3583(i) and how it operates to extend

the district courts power to revoke beyond the supervised release period in certain circumstances. However, the parties agree that the hearing continuances in this case, while necessary, were not designed to extend the period of supervised release beyond the statutory maximum of five years, which designates September 15, 2015 as the appropriate date in the event of modification by this Court. 5. Accordingly, the parties jointly move the Court for entry of an Order to

Modify Conditions of Defendants Supervised Release. This Order seeks only to establish September 15, 2015, as the termination date for the extended supervised release period. All other supervised release conditions, as amended by the Court, are reflected in the proposed Order. WHEREFORE, the undersigned parties jointly move the Court for an entry of an Order Modifying the Conditions of Defendants Supervised Release.

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Respectfully submitted,

BERKOWITZ OLIVER WILLIAMS SHAW & EISENBRANDT LLP By:/s/ Shazzie Naseem Shazzie Naseem MO #59142 Jeffrey D. Morris MO #45243 2600 Grand Blvd, Suite 1200 Kansas City, Missouri 64108 (816) 561-7007 (telephone) (816) 561-1888 (facsimile) Email: snaseem@berkowitzoliver.com Email: jmorris@berkowitzoliver.com & By:/s/ Kathleen D. Mahoney____________ Kathleen D. Mahoney Assistant United States Attorney Charles Evans Whittaker Courthouse 400 East Ninth Street, Suite 5510 Kansas City, Missouri 64106 Telephone: (816) 426-3122

CERTIFICATE OF SERVICE I hereby certify that on this 14th day of February, 2014, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record via transmission of Notices of Electronic Filing generated by CM/ECF.

/s/ Shazzie Naseem_________________ Attorney for Defendant Sonny Vleisides

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