Thomas Vranas' Request For Probation

Case: 1:15-cr-00620 Document #: 111 Filed: 04/06/17 Page 1 of 73 PageID #:2568
UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
UNITED STATES OF AMERICA, )

)
Plaintiff, )
)
-v- ) No. 15 CR 620
) Honorable Edmond E. Chang
TOM VRANAS )
)
Defendant. )
TOM VRANAS SENTENCING SUBMISSION AND REQUEST FOR A SENTENCE

OF PROBATION
Tom Vranas, by and through his attorneys, MONICO & SPEVACK, submits this
Sentencing Submission along with the attached letters to aid the Court in imposing a fair
and reasonable sentence in this case. The parties agree that Mr. Vranas should be
sentenced below the advisory guideline range (60 months). The government anticipates
requesting a sentence of 39 months imprisonment. The U.S. Probation Officer
recommends less - 24 months imprisonment. We believe a sentence of three years
probation with a lengthy period of home detention and significant community service is
the appropriate sentence under the unique facts of this case. This sentence would
accomplish the statutory sentencing goals and is supported by: (1) Mr. Vranas extensive
and significant cooperation; (2) Mr. Vranas exemplary family, employment, and
community history; (3) Mr. Vranas lack of criminal history; (4) Mr. Vranas unlikelihood
of recidivism; (5) Mr. Vranas role in the offense; (6) and the collateral consequences of
conviction. A sentence of non-incarceration would also better serve the public in that it
would allow Tom Vranas to continue his critical volunteer work at the ARK of St. Sabina
and other volunteer organizations.
I. INTRODUCTION
As the 131 letters submitted to the Court attest, Tom Vranas, 36, lives an exemplary
life of generosity, integrity, and extraordinary charitable commitment. But, after re-
connecting with his codefendant, his high school dean and a mentor to Tom, he got caught
up in a bribery scheme to secure business from the Chicago Public Schools (CPS). Tom
did not plan or initiate the scheme and he would likely not have engaged in the instant
behavior if not for his codefendants involving him. (Sentencing Rec. at 4).
Still, when pulled into the scheme originated by his codefendants, Tom knowingly
participated in the conduct. He is deeply ashamed of himself. He also is profoundly
remorseful for contributing to the breach of the public trust in government and CPS. He
confessed his crimes to the Government, to this Court, to his family, to his friends, to his
colleagues, and to his priest. In doing so, he never lied or minimized his conduct. He
accepts full responsibility for his crimes and has truthfully cooperated with the
Government in its investigation.
No amount of punishment will match the pain and suffering that Tom has already
experienced for participating in the scheme. He has gone from being a son and husband
who brought joy and happiness to his family to someone who caused them tremendous
pain and anxiety. (Def. Version at 1). During the last three years, he lost his companies,
destroyed his career, and irreparably damaged his reputation. After this case broke, he
was asked to step down from a beloved volunteer position performing magic tricks for
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hospitalized children and from co-teaching a class at his church. His self-blame weighs
heavily on him, and he is tormented by guilt and shame. He suffers from severe anxiety,
depression, and insomnia for which he is prescribed medication. He will live with his
failings and the disgrace of being a convicted felon for the rest of his life.
Yet, even in these darkest hours, Tom has remained productive and redoubled his
efforts to help those in need, a passion that he has been committed to for the last 20 years.
Tom meets with his priest regularly to discuss his transgressions, his remorse, and his
desire to make amends for his conduct. To that end, in addition to pleading guilty and
cooperating, Tom immediately set aside funds to make full restitution to CPS and has
been working diligently to determine a fair settlement that will result in giving money
back to CPS exceeding restitution in this case. Additionally, Tom works part-time at a
company focused on helping young professionals find meaningful and socially conscious
work.
At the same time, Tom currently devotes about 30 hours a week volunteering at
the ARK of St. Sabina (ARK), serving at-risk youth from Englewood and Auburn-
Gresham on the far South Side of Chicago. Tom not only works with the children on
homework, life skills, and other important activities, but he also works directly with the
ARKs Executive Director, Jocelyn Jones, on fundraising projects, marketing, web site
development, and social justice programming. In the relatively short time that Tom has
volunteered with the ARK, he has completed important fundraising projects that have
allowed the ARK to fund important programs during a difficult financial time for social
service agencies. Ms. Jones is deeply concerned that Toms absence from the ARK
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would leave a huge void in the program. It is Ms. Jones most fervent hope that the
Court sentence Tom in a manner that allows him to continue his critical volunteer work
with the ARK. (Ex. 1). We hope for the same.
II. TOMS PERSONAL BACKGROUND AND CHARACTER
Tom submitted a statement concerning the offense that includes a detailed
description of his personal background and his role in the offense. Additionally, the
probation officer prepared a thorough summary of Toms personal and family data. (PSR
57-86).
A. Personal History, Education and Career
Tom Vranas is 36 years old and has no criminal history. He has been married for
ten years to Allison Vranas, 32, a former preschool teacher at St. Peters and Paul Orthodox
Church in Glenview, Illinois. Tom and Allison live in Glenview with their two rescue
dogs. Due to multiple miscarriages, several failed IVF treatments, and Toms rare fertility
disorder, they have no children. (PSR 111). With this case and the uncertainty of Toms
future, they have had to put off additional fertility treatments. They are hoping to resume
the treatments and start a family soon.
Tom is the youngest of two boys born to John and Annette Vranas. John and
Annette raised Tom and his brother Paul, 38, in a modest home in Skokie, Illinois. Toms
grandparents immigrated to the United States from war-torn Greece, narrowly escaping
the Nazi occupation and the December 1943 Nazi massacre of over 700 civilians in their
home town of Kalavryta. They came to the United States with nothing, seeking freedom
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and a better life for the next generation. They lived in a small apartment with 14 other
family members and worked tirelessly in a grocery business that eventually prospered.
They built a life in America for their children and grandchildren, based on hard work,
family, education, and religion.
Toms grandparents had a tremendous influence on him. He grew up listening
to his grandparents stories of immigration to America, their struggles to work for a better
life and their dedication to the Orthodox Church. (Def. Version at 1). Likewise, Toms
parents honored the sacrifices made by their immigrant parents by raising Tom and his
brother Paul with these same values. As such, Tom grew up in an extremely close-knit
family, whose cornerstones are faith, family, community, education, and hard work.
Toms mother, Annette, worked in public education for 23 years, first as a Chicago
Public School teacher and then in administration, concentrating on physically and
mentally handicapped students. Now retired, Annette is a tutor for dyslexic students
and a volunteer advocate for special needs children in Chicago. Toms father, John, who
initially planned to become a priest, works in a family real estate business and volunteers
over the years with numerous charities, including organizations providing housing and
other assistance to families in crisis. John also served as the leader on two suburban
school boards.
Annette and Johns hard work and commitment to civic responsibility profoundly
impacted Tom as a child. When Tom attended Niles West High School in Skokie, Tom
not only excelled academically, but he also donated a significant amount of his free time
to charitable endeavors. For example, Tom earned nearly a full year of college credit
5
through advanced placement courses and was an elected official of the National Honors
Society. At the same time, Tom served as an officer of West Helps Others, (WHO), a
school charity group through which Tom participated in numerous volunteer projects,
including tutoring younger students from Chicago and Evanston Public Schools and
working with disabled adults from Skokie. He also began volunteering with The Greater
Chicago Food Depository and Habitat for Humanity. By his sophomore year in high
school, Tom was named the fundraising chairperson for a Habitat service trip to Florida.
In his senior year, Tom chaired another Habitat service trip to Florida during which 20 of
his fellow high school students built houses. While all this was going on, Tom worked at
a fast food restaurant to help his parents out. Tom graduated high school in 1998.
In 1999, Tom went to Northwestern University, where he studied economics and
continued his volunteer work, despite his rigorous academic commitments. He tutored
students weekly at Evanston Public Schools and acted as a Big Brother (mentor) for
elementary school students. He also participated in many volunteer projects throughout
Chicago with the Northwestern Community Development Corps (NCDC) and
Northwesterns Habitat for Humanity chapter, even returning to Niles West High School
to chaperone another spring break service trip. Additionally, Tom sang with Melodious
Thunk, a campus acapella group that raised money for numerous charitable causes, both
locally and globally, through concerts and other performances.
After graduation in 2003, Tom, like many of his fellow students, worked in finance
at a consulting group. Despite career success, Tom only stayed at the consulting group
for one year. Working in finance left Tom feeling empty and disconnected. (Def.
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Version at 3). After struggling to find more meaningful employment in line with the
values [he] had grown up with Tom started, SolTyra, a marketing firm. Running his
own company made Tom feel more fulfilled than working in finance. He felt good
helping local and small companies succeed and grow. In addition, he had more free
time, which allowed Tom to participate in volunteer work, including environmental
clean-up in the Chicago area and fundraising for Chicago youth arts programs. Tom also
served as his churchs Youth Director, leading high school students on many community
and faith based projects.
B. Gary Solomon and the Supes Entities
Tom first met Gary during his senior year of high school. Gary was a Dean at Niles
West and the faculty advisor of the National Honors Society, on which Tom served as an
elected student officer. Tom also grew up knowing Garys in-laws, who like Toms
family, were active in the Greek Orthodox Church and community.
In 2004, about one year after Tom graduated from college, Tom saw Gary Solomon
at a charity event. Gary told Tom that he was the Vice President of Sales and Marketing
for The Princeton Review (TPR) and that TPR might be able to outsource some marketing
work to Tom. Shortly thereafter, TPR interviewed and hired Tom on a contract basis,
eventually offering Tom a full-time position to help grow a federally-funded program
that provided over 7,500 low-income CPS students, primarily on the South and West
Sides of Chicago, with free after-school tutoring. After the Illinois State Board of
Education rated the program of the highest quality, Tom worked with other TPR offices
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across the country to successfully grow and manage additional federally-funded after-
school tutoring programs.
At TPR, Tom had found his true calling - combining business skills and social
good to make a positive impact in the world through education. (Def. Version at 4).
Around this same time, Tom met Allison, becoming engaged to her just six months later.
TPR next promoted Tom to help turnaround and grow its national call center in Houston,
TX, where Tom and Allison, now married, spent the next two years. When TPR asked
Tom to relocate to their corporate headquarters in Massachusetts, he decided to leave
TPR and look for work in Chicago. Tom and Allison wanted to be around their family in
Chicago and hopefully start a family of their own.
By this time, Gary had left TPR and founded Synesi Associates, a company that
helped turn around struggling schools and school districts. After founding Synesi, Gary
sought to acquire PROACT Search, Inc, which specialized in executive search and
placement for educators and administrators. Gary called Tom and offered him 10%
ownership in PROACT. Tom jumped at the chance, joining as President in November
2009. Not only could he and Allison return to Chicago, but Tom would be part-owner of
a company that Tom believed aligned good work with the goal of education reform. A
few months later, Gary asked Tom to join Synesi as President. While Gary didnt offer
Tom a large salary (about $40,000), he offered Tom the opportunity to grow his equity in
both companies, which appealed to Tom. Two years later, Gary and Tom acquired The
SUPES Academy, a company that specialized in leadership and professional
development services for school districts, and Tom became the 1/3 owner of SUPES,
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PROACT and Synesi (the Supes Entities). Tom used the money he had earned in college
and high school to pay the $80,000 buy-in requested by Gary for the increased ownership.
As the public face of the Supes Entities, Gary focused largely on sales and
meeting with customers. Tom worked in operations, typically spending 12-15 hours a
day at the office, trying to ensure that the programs and contracts ran smoothly.
Although Tom held an ownership interest in the Supes Entities, it was clear to Tom, and
the other employees, that Gary was the ultimate boss. Gary held the majority interest,
was older than Tom, had more experience than Tom, and made more money than Tom.1
He had also been an authority figure to Tom when Tom was a high school student.
At the Supes Entities, Gary developed a culture of constant availability and loyalty
to him. If you did not follow Garys lead, you risked being on Garys bad side, which
was not a good place to be. (Def. Version at 5). So, most employees, Tom included,
worked to please Gary and not upset him. There was even a running joke within the
company and with clients that Tom would have to ask Gary before he could start a
family. Id. Ultimately, the job took over Toms life. He went five years without taking
a vacation or any kind of extended break. He lost contact with friends and family
members, had little time to himself, and even put off starting a family. There were many
times when Tom questioned whether the job was worth it. But his strong work ethic,
1
For example, without consulting with Tom, Gary had the Supes Entities pay the leases
on Garys cars, pay back Garys personal PROACT loan, and give Gary other financial
benefits that Tom did not receive.
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loyalty to Gary, passion for helping urban school districts, and drive to succeed, kept him
from leaving. Id.
C. Barbara Byrd Bennett
Gary met Barbara Byrd Bennett in 2010 when Synesi had a team working in five
of the Detroit Public Schools. At the time, Barbara was Detroits acting Chief Education
Officer and was one of the most well-known and well-respected education leaders in the
country. She had successfully turned around the district in Detroit and held high
positions in New York and Cleveland. Gary kept Tom updated on his growing
relationship with Barbara. Eventually, Gary persuaded Barbara to join the Supes Entities
as a part-time consultant. After which, Gary introduced Tom to Barbara at a meeting at
the Cleveland Airport where the three of them discussed Barbaras prospective role at
the Supes Entities.
Tom remembers being in awe of her deep experiences and successes. (Def.
Version at 6). Barbara had a lot of knowledge about school turnaround and was a gifted
speaker and teacher. Tom was surprised and honored when Barbara agreed to join the
team. Id. To Tom, having someone of Barbaras stature and accomplishments on board
was an incredible win for the Supes Entities and he believed it would have a
significantly positive impact on [the] company and the districts they worked in. Id.
In fact, when CPS leadership hired the Supes Entities to conduct a training for 26
of their senior administrative leaders (Chicago Executive Leadership Academy or CELA),
CPS selected Barbara from a list of master teachers to teach at CELA. The CELA
participants reported being enthralled by Barbaras abilities, skills and experience.
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Barbara also developed a school turnaround tool kit that was reviewed favorably. Tom
looked forward to other successful engagements due to Barbaras stature in the field.
But in March 2012, Gary advised Tom that they might lose Barbara to CPS. While
Tom believed that it would be good to have a champion at CPS who knew the quality
of their work, Tom was concerned that they would lose Barbaras efforts to improve
operations and establish contracts with other schools. Tom was comforted by his
understanding from Gary that Barbaras absence from the Supes Entities was only
temporary.
On May 1, 2012, midway through her teaching responsibilities with the Supes
Entities, CPS hired Barbara as a consultant. At the time, the Supes Entities still owed
Barbara around $80,000 for contracts she helped them win in St. Louis and Prince
Georges County. It was Toms understanding from Gary that they would pay Barbara
this money when the Supes Entities received payment on the contracts and when Barbara
came back to the Supes Entities. Similarly, when Tom signed Barbaras consulting
agreement (the terms of which had been negotiated prior to her leaving for CPS) on behalf
of the Supes Entities on May 29, 2012, a month after Barbara began consulting for CPS, it
was Toms understanding that the contract was for her past work at the Supes Entities.
D. The Offense Conduct
In October 2012, Tom did not yet know that Gary had promised to pay Barbara for
steering contracts to the Supes Entities when she was a CPS consultant. Gary (and
Barbara) kept this corrupt arrangement a secret. (Governments Consolidated Sentencing
Memorandum, Dkt. #91 at 18). However, based on Toms observations of the unique
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relationship that Barbara continued to have with Gary and the Supes Entities, Tom
understood that Barbara was still on Team Supes and would legitimately recommend
the Supes Entities to CPS.
Around early fall 2012, money on the contracts Barbara helped win before she
joined CPS as a consultant started coming in. After considering several ways to pay
Barbara the money owed to her, Tom and Gary eventually decided to pay her out of a
development fund that they had set up to accrue money (about 4% to 9% of payments
received from CPS and other entities) to pay taxes and for general growth activities. In
addition to money for Barbara and general growth, they also used the development fund
to pay corporate retreats, tax payments, furniture, and other office expenses.
Barbara became the CEO of CPS in October 2012. In late fall or early winter 2012,
Gary told Tom that he had promised Barbara money upon her return to the Supes Entities
for acts she took in her official capacity at CPS that benefitted the SUPES Entities. Id. at
19. While Gary and Tom did not discuss the exact amount that Gary had promised
Barbara, Tom understood that Barbara would be paid out of the development fund,
which eventually reached a maximum amount of $360,000 to $380,000. As Tom
acknowledged in his plea agreement, these contracts included the $2.09 million contract,
the $450,000 settlement and contract extension, and the $20.5 million three-year sole
source contract.
Although Tom did not originate the conduct in this case, he eventually
participated in it. Id. And, while he wholeheartedly believed in the value of his
companies and worked hard to deliver the contracted work to CPS, Tom knew that the
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financial arrangement with Barbara was wrong and illegal. When the Inspector General
for CPS requested documents, Tom, after consulting with Gary, agreed to delete the bad
emails to conceal the arrangement with Barbara. In the end, instead of leaving SUPES
or confronting Gary, as Tom admits, he acted out of fear and self-interest, and
participated in the scheme. (Def. Version at 7).
E. The Aftermath
Toms decision to participate in the scheme hatched by Gary and Barbara is a
decision that will haunt him forever. With this case, Tom strayed from the moral
compass that has guided [him] throughout his entire life. Id. at 1. Tom confesses, I let
down the students, teachers, and the education system that I worked so hard to improve.
He also subjected his family to severe emotional pain. Consumed by shame, remorse and
regret, Tom suffers from nightly insomnia, and anxiety so severe that sometimes he
finds it hard to get out of bed in the morning. Tom knows that he has nobody to blame
but himself, a realization that makes all of this even more painful to him. Id.
The love and support of his family, his faith, his commitment to the community,
and his strong desire to make amends for his conduct have allowed Tom to persevere
throughout this difficult period. Tom pled guilty and cooperated with the Government,
meeting with them whenever requested for lengthy periods of time, during which he
readily and truthfully acknowledged all his criminal conduct and the conduct of his
codefendants.
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Even before Tom pled guilty, he set aside dividend checks he received from the
Supes Entities after this case to pay restitution to CPS.2 He is also working diligently with
his civil attorney to fairly settle CPSs case against him in an amount that will be much
greater than the criminal restitution. Importantly, Tom candidly and without
minimizing, discussed with friends and colleagues his illegal conduct and the dramatic
collateral consequences that flowed from it. While this was often painful and
embarrassing, Tom hoped that others like him would be deterred from similar conduct
and walk away if confronted with a similar situation.
Finally, Tom did whatever he could to stay productive. After he pled guilty, he
fought the urge to just stay in bed, working part-time delivering groceries and take-out
food, and helping friends and family members with handiwork around their homes.
Eventually, through friends, Tom found part-time work with two local businesses,
during which he continued to volunteer weekly with the Harvest Food Pantry and
Habitat for Humanity. Although Tom earns significantly less income than he did in the
past, he is extremely grateful for the opportunity to be working. Most recently, Tom
volunteers 30 hours per week with the ARK of St. Sabina and 3-4 hours per week at
Harvest Food Pantry. Tom promises to devote the rest of his life to being a productive
member of society and making the world a better place. Id. at 9.
2
At the time the dividend checks were cut, Tom was no longer involved in decision
making for the Supes Entities.
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III. Toms Letters - A Lifetime of Compassion, Generosity, Integrity and Hard

Work.
Tom has made significant contributions of time and talents to the community
throughout his entire life. (Ex. 2, listing Toms charitable activities from 1993 to the
present). In addition to his family members, those that have witnessed Toms lifetime of
giving and personally benefitted from Toms generosity, have written letters to the Court.
Given the large volume of letters received on Toms behalf, we have organized the letters
into groups, recognizing that many of the letters sound common themes. For the Courts
convenience, we have summarized several of the letters from each group below and
attached the rest of the letters received as Group Exhibits A-E.
1. Family Members
Allison Vranas, 32, met Tom over ten years ago, and they married in July 2007, just
a little over a year after they met. (Ex. 3). Allison taught preschool in Glenview, Illinois
and recently received her interior design certification. Allison was immediately drawn
to Toms considerate, kind, compassionate, honest, and giving personality. During
their marriage, Allison observed Tom to be the kind of person who would give you the
shirt off his back and as someone who is selfless and good down to his core. For
Allison, Toms volunteer work with Open Heart Magic, an organization that provides
magic shows to hospitalized children, best reflects Toms charitable spirit and innate
desire to help others. Allison marveled at Toms commitment to Open Heart Magic,
despite a grueling work schedule with the Supes Entities. Allison recalls how Tom,
exhausted after a full day of work, trained for more than a month with Open Heart to
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learn magic tricks before being assigned to Lutheran General Hospital. It all seemed
worth it, writes Allison, when Tom returned home and told Allison how he made a sick
child smile and brought a moment of relief to the parents in the room that were sick
with worry. Tom even stayed well after the obligatory hours to get in every last child
or to entertain a family that was enjoying the show too much for him to walk away.
Not surprisingly, notes Allison, Lutheran General eventually awarded Tom employee
of the month, an accolade he cherished more than any other he had received. Tom loved
his volunteer work with Open Heart Magic and felt honored to work with the children
and their families. Allison will never forget how it crushed Tom when Open Heart
Magic asked him to resign from his volunteer position after this case became public.
Characteristic of Toms selfless nature, what hurt him the most was not his ego or pride,
but knowing that has actions ultimately impacted the children and families he tried so
hard to help.
Likewise, even though Tom wrestle[s] with intense feeling of shame, sadness,
self-doubt, and remorse every day, Allison writes, he does not feel sorry for himself.
Instead, Tom feels most sorry for the children at CPS, for Chicago, and for [Allison] and
[their] families. Knowing this, and seeing the good work Tom has done in the
community, Allison is certain that Toms conduct was not motivated by greed or
materialistic desires and he never could have intended to hurt the public schools, the
children of Chicago, or anybody else. For Tom, working at the Supes Entities was not
just about making money, it was the natural outgrowth of Toms genuine desire to
blend entrepreneurship and charity. Tom really believed in his work and he put his
16
heart and soul into it, work[ing] day and night to make positive changes at CPS.
Allison recalls one time when after CPS imposed a last-minute deadline on a holiday
weekend, Tom cancelled their weekend plans and spent the entire time staffing,
emailing, catering, finding venues, and negotiating to ensure the success of the program.
Allison notes that this is just one example of many where Toms demanding work
schedule interfered with his personal life he lost touch with friends, put family
obligations on hold, and missed events.
Most difficult for Allison and Tom though, is that while Tom focused on work,
they put off trying to have a family, a missed opportunity exacerbated by Allisons
subsequent miscarriages, Toms rare fertility issues, Toms uncertain future, and the
public nature of this case. Not one day goes by where Tom and Allison do not discuss
this case. Allison has sought therapy to deal with her anxiety and grief. There are many
sleepless nights and despite Allisons therapy, sometimes the pain is so great that
Allison cries so hard and for so long that she forgets to breathe. Allison is grateful that
Tom is always there to pick [her] up off the ground. He is her rock and a source of
comfort for their family. Remarkably for Allison, [I]nstead of lying around in despair,
[Tom] has found work stayed productive, and even continued his volunteer work.
No matter what happens, writes Allison, she will never regret one day of being
with Tom. She hopes for a sentence that will allow them to put their lives back together
and start a family. Allison believes that Tom is truly deserving of mercy and a second
chance. She is confident that if he is given the opportunity he will make a positive
difference in the world.
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Toms mother, Annette, also prays for mercy and for a second chance for Tom. (Ex.
4). She too is confident that Tom has a bright future and can be of tremendous value to
society. Like Allison, Toms mother has witnessed his profound remorse and she knows
in her heart that Tom had no intent of malice or harm. Annette hopes that her letter
shows this and reveals that Tom is so much more than the conduct he pled guilty to.
Annette traces Toms genuine desire to improve education for all students back to
his childhood. Annette was a public school special education teacher with CPS for 23
years. As such, Tom grew up listening to [her] trials and tribulations of working in the
Chicago Public Schools and he realized the plight of all children in the educational
system. Likewise, Tom exhibited extraordinary dedication and selflessness at a young
age. In middle school, he took part in education programs focusing on researching and
solving global problems and participated in many activities centered around the
church. When he was just nine, he volunteered himself to serve as an altar boy for a six-
hour church service. Annette further recalls how, at age ten, Tom insisted that his family
regularly travel to Iowa (an eight-hour drive) to visit his aunt, who was battling cancer,
and to cheer up his three younger cousins during their moms illness.
In high school, Tom was a well-rounded student, who excelled academically
and participated in sports, theatre, and music. However, Annette writes, unlike most
high school students, Tom focused less on parties and hanging out with friends and more
on charitable causes and helping others. At the same time, at age 15, Tom got a workers
permit and worked in a local fast food restaurant, riding his bike to work because he was
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too young to drive. Tom was such an asset to the business that the owner felt
comfortable leaving Tom in charge while he honeymooned for three weeks.
When Tom attended Northwestern, he again made a positive name for himself
for his non-stop commitment in creating, and supporting many important causes. He
even gave up attending part of his freshman orientation week to drive his grandparents
to an out-of-state funeral. And despite rigorous academic demands, Tom made time to
help coach Annettes students in the Chicago Cubs Buddy Baseball Team (a sports
program pairing disabled students with able bodied peers), helped Annette in the
classroom with cleaning and moving furniture, and assisted with computer work. For
many of Annettes students, she writes, Tom was a beloved mentor, leading Annette to
conclude that Tom was as much of a part of my CPS school as I was. And although he
was not a runner, he trained for months and ran the Chicago Marathon in honor of
children suffering with Leukemia. Annette recalls how Tom finished the race, despite
suffering from hypothermia and needing medical assistance. Likewise, Tom trained for
and completed a 150-mile bike ride, co-captaining a team raising over $100,000 in honor
of Multiple Sclerosis for a family member that is affected by the disease. On a more
personal level to Annette, Tom, at 22, made the funeral arrangements for his grandfather,
who unexpectedly died while out of town. Tom also drove his grandmother to
chemotherapy appointments, drove his uncle to dialysis, and helped Annette recover
from a difficult knee replacement surgery.
Further reflecting his uniquely selfless nature, Annette writes, after graduation
Tom declined to follow his peers into the world of consulting and finance. Instead,
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Tom searched for a job that would allow him to combine his intellect with his passion
to serve. Tom found his calling at the Princeton Review where he led a program that
gave thousands of low-income [Chicago] students free tutoring. Annette recalls Toms
tireless efforts to promote the program, visiting over 250 schools across the district
and getting to know the communities, teachers, and principals. Tom truly believed he
could fix a broken system. So, writes Annette, it was not personal gain or
materialistic desires that motivated Tom to invest in and become a part of the Supes
Entities. Rather, Tom was excited about joining companies who were highly regarded
in the education field and passionate about helping to make a difference in childrens
lives.
Joining the Supes Entities began as the highlight of [Toms] life. That is why,
Annette writes the day he pled guilty was truly the saddest and most difficult day of
her life. Despite this case, Annette believe[s] that [her] son grew up to be a remarkable
man. She continues to be proud of her son. She marvels at his courage in the
aftermath of this very public case. Not only has Tom remained the rock of the family,
but he has stayed productive and committed to helping others. Even during the
investigation, Tom found the strength to read scripture to his paternal grandmother
while she was in hospice and do a magic show for [Annettes] great aunt before she died.
For Annette, Tom is not defined by his conduct in this case, but by his lifelong
commitment to helping others. She prays for mercy and a fair sentence that allows him
to be of value to society again.
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Toms father, John Vranas, also hopes for a sentence that take[s] into account all
of the good that [his] son has done in his life and all the promise that he holds for the
future. (Ex. 5). He too sees Tom as unique in that he seemed to be born with an innate
kind and caring spirit and had an early interest in civic responsibility. As John
witnessed his sons early involvement in numerous charitable organizations, he knew
that Toms commitment to public service was not just a passing fancy, but a lifelong
commitment. What impressed John even more were the personal sacrifices Tom made to
help others. For example, instead of going on the typical spring break vacations in
college, Tom volunteered with Habitat for Humanity building homes. Likewise, after
college, Tom returned to his family church and volunteered as a Youth Director and
teacher.
John was very happy when Tom chose a career that would allow him to continue
his service to the community by improving education. As the past president of a school
district, John understood how much hard work and passion goes into improving a
school district. Tom possessed both these traits and became involved in a company
focused on educational excellence and the development of school leadership. Given
Toms commitment to public service, compassion for others, and his tremendous drive
to better public education, John had every reason to believe Tom would be successful.
That is why this case is so profoundly sad and perplexing for John. And while John may
never truly understand why Tom went along with this scheme, he is certain that Toms
conduct was very out of character and that Tom did not participate in the scheme out of
malice or greed.
21
Despite the horror of this case, John is proud of the man that Tom has become,
which has never been more evident to [him] than during this difficult time period in his
life. Tom has not blamed others or minimized his conduct. Instead, Tom is steadfast
in holding himself accountable for his actions, admitting to his father that he
participated in a serious crime, pleading guilty, and cooperating with the Government.
These big steps towards redemption, reassure John that Tom will never forget the
important lessons he learned in this case and that he will work every day to make amends
for his conduct. They also confirm for John that Tom is the same good, compassionate,
and kind son that he raised. John is certain that if the Court gives Tom a second chance,
he will become the outstanding individual that he set out to be in the first place.
Likewise, Toms older brother, Paul Vranas, is confident that Tom will make a
positive and long-lasting impact on this world if he is given the opportunity. (Ex. 6).
Paul describes Tom as being motivated by Church, Family and Community. Even after
Tom pled guilty, Paul named Tom the legal guardian of his two-year-old son, because,
as Paul writes, I trust Tom implicitly and literally would put my sons life in his hands.
Although Paul is older than Tom, Paul turned to Tom to help him through what Paul
describes as his rock bottom. After taking exorbitant financial risks to start his own
business, Paul wound up shutting the business down and having a lot of debt. After
which, Paul felt like he had to regain respect from the community. But Tom never
judged [him] or made him feel bad. Instead, Tom was supportive, helpful, and patient
with him. Paul is thankful to have had the support of an intelligent, compassionate,
and helpful person like [Tom] by his side.
22
Now that Tom has hit his rock bottom, Paul hopes to be able to support him in
the same compassionate and helpful way. Paul sees that Tom is struggling with his
guilt, shame, and remorse and that he is anxious to continue making amends for his
conduct. Paul is certain that Tom will do this and be a productive citizen again. Not
only was Tom honest with [Paul], but he held himself fully accountable and would
swiftly correct anyone who sought to shift the blame or make excuses for his conduct.
Paul prays that the Court takes Toms genuine remorse and excellent character into
account in passing sentence on [his] younger brother.
Peter Coorlas, Toms father-in-law, is heartbroken for Tom and Allison. (Ex. 7). He
was in Court with Tom the day that Tom publicly admitted his guilt and is moved by
the courage, fortitude, honesty, and respect for others that Tom has displayed throughout
this ordeal. An Illinois lawyer and former Assistant States Attorney in Cook County for
30 years, Peter strongly believes that if there was ever a man deserving of a second
chance, it is Tom Vranas. Tom is a model husband to Allison, writes Peter, and he is
one of the finest, hardworking, and upstanding individuals I have ever met. Tom
candidly discussed his conduct with Peter, during which he apologized to Peter and
expressed his deep sorrow for contributing to the publics negative view and lack of
trust in government. As a former prosecutor, Peter understand[s] that Tom faces
sanctions under the law for his serious conduct. But, he also sees that Tom has learned
a very hard lesson, that his remorse is genuine, and that he lives with his shame and
sorrow on a daily basis. Having been close to Tom for over 10 years, Peter is certain that
Toms conduct is atypical of his character and an aberrant event in his otherwise
23
extraordinary life. This, coupled with Toms exceptional talents and his potential to
benefit society in the future leads Peter to request leniency from the Court.
Toms mother-in-law, Anastasia Coorlas, also believes that Tom is an
extraordinary young man. (Ex. 8). Anastasia describes Tom as compassionate,
sympathetic, and extremely sensitive to others feelings. When Anastasias mother died
unexpectedly, Tom helped her immeasurably. Anastasia was so distraught that she
could not bear to go to her mothers home and get sentimental items for the funeral.
Understanding her emotional difficulty, Tom, without prompting, offered to collect the
sentimental items and bring them to Anastasia. Likewise, even though Tom suffered
emotionally too after Allison miscarried their first pregnancy, it was Toms compassion,
love and sensitivity that helped keep [Allison] from going to a very dark place.
Despite this case, Tom has remained Allisons rock and bright shining light in their
family. Anastasia is so grateful that this dark and frightening time in Toms life has not
hindered his kind soul or loving spirit. While this highly public case has caused a huge
set back in [Toms] career, reputation, starting a family, and life itself, Tom is not bitter
about his life or angry. Rather, he is profoundly remorseful and accepts full
responsibility for his actions and the consequences of them. He has also remained
productive, committed to charity and continued to be a wonderful, caring, and loving
son-in-law. Anastasia prays for mercy for both Tom and her daughter. As a mother,
she hopes for a second chance for Tom so he and Allison can move beyond this case and
she will see [her]daughter smile again.
24
Allisons brothers, Stephen, an architect, (Ex. 9) and Peter, a Chicago attorney, (Ex.
10) hope for mercy for Tom and Allison. Both brothers view Tom as a mentor and like
an older brother. Tom encouraged Stephen to volunteer with him at Habitat for
Humanity, thereby writes Stephen, restoring my sense of selflessness for those in need,
and the value of contributing to the progress of individuals, families, and our
community. Stephen also credits Tom for teaching him to be confident in [his]
abilities. Most importantly, regarding this case, Tom has humbly expressed his remorse
to Stephen and the rest of the family.
Likewise, despite a large family and support system, for Peter, Tom markedly
stands out as someone who [he] trusted and relied upon for advice and guidance. Peter
recalls how Tom helped him with his college applications and gave him career and life
advice. During the summer of Peters junior year in college, Tom offered him an
internship at PROACT. As an intern, Peter writes, I had an unfiltered view of Toms
professional achievements and work ethic that I still to this day strive to emulate. I saw
how hard Tom worked and witnessed his desire for the company to do good and helpful
work. Tom was the one who provided much of the grunt work in the office and he
seemed to work non-stop, day and night. Yet, he still managed to make time for Peter
and stand by him through [the] trials and tribulations of growing up. Even now, Peter
continue[s] to learn from Tom everyday throughout this difficult process. Peter
remains proud to know Tom and he is positive that the world is a better place because
of Toms contributions to society.
25
Similarly, Rebecca Petropoulos, Toms aunt, is grateful to Tom for being a kind
and patient mentor and amazing role model to her children. (Ex. 11). For Rebecca,
Tom was the perfect example of how hard work and perseverance can be rewarded, not
just with material things but also spirituality. In addition to emulating Toms drive and
work ethic, Rebecca hoped that her children would have his sense of empathy for
others. In her letter, Rebecca details Toms long history of fighting for a good cause or
the underdog. She also recalls Toms kindness and generosity which directly impacted
her. When Rebeccas father (Toms grandfather) died in a tragic accident, Tom helped
the family by handling the funeral arrangements and taking on other chores that were
too emotional for Rebecca and her sister (Toms mother). He rearranged social events,
without hesitation or complaint, to help Rebecca drive her uncle to dialysis and her
mother (Toms grandmother) to chemotherapy. Most importantly, Rebecca writes,
Tom kept his frail grandmothers spirits up throughout her battle with pancreatic cancer
by keeping her company during the cancer treatment. More recently, in July 2015, despite
this case weighing heavily upon him, Tom performed a magic show for Rebeccas
terminally ill aunt. After which, Rebecca recalls, her aunt called her and sobbed in
amazement how Tom lifted her spirits.
For Rebecca, these examples reveal Toms life-long character traits of selflessness
and compassion. And, despite this case, Toms core character continues to be revealed
through his deep humility, his profound remorse, full accountability, and his deep
desire to continue making amends for his conduct. Rebecca hopes that Tom gets this
26
sacred opportunity and she knows if he does he will continue to serve his family and
the community.
Rebeccas daughter, Stefanie Petropoulos, confirms that Toms participation in her
childhood as a babysitter, church youth group leader, and mentor, positively impacted
her life. (Ex. 12). Stefanie, now the Creative Director for the Republican National
Committee in Washington D.C, writes I am the person I am today because of Toms
influence. Ten years younger than Tom, but extremely close to him, Stefanie grew up
observing Toms hard work and commitment to the public good and believes that it
influenced [her] to move to Washington D.C., to attend college, and commit [her] career
to influencing public policy on a national level. Stefanie is still incredibly proud of Tom
and believes that if given the opportunity, he will prove that his good intentions
outweigh his misjudgments.
Likewise, Toms 19-year-old cousin, Arianna Vranas, tells the Court that Tom
played a critical role in her life. (Ex. 13). Tom became Ariannas godfather when he
was just a teenager himself, but he took the role seriously, attending her dance recitals
and otherwise taking an interest in her life. Recently, Tom helped Arianna through a
difficult decision to transfer from her college in Texas to Loyola University. Arianna
remembers feeling like a failure and unsure of her life. Even though Tom was going
through a difficult time himself with this case, Tom reached out to Arianna and patiently
discussed her options with her. Arianna admires Toms close ties to family, his strong
and continuously growing Orthodox Faith, his inspirational marriage to Allison, his
hardworking work ethic his educational and communal accomplishments, and much
27
more. This case has not changed Ariannas positive image of Tom. In fact, Toms
remorse and strong desire to make amends for his conduct have only made Arianna
admire Tom even more.
Tom also helped his cousin, Elena Liveris, through her difficult college years. (Ex.
14). Tom and Elena went to Northwestern together. College proved difficult for Elena,
but Toms emotional support made it easier for her. Tom often visited Elena at her dorm
to cheer her up with ice cream and long talks. Elena recalls Tom being a patient listener
and that he was genuinely interested in helping [her] through some rough times. Now
an attorney, Elena believe[s] that Toms compassion and understanding made an
impact on her life. Toms generosity towards Elena, and his selfless enthusiasm and
commitment to community service, leads [her] to conclude that Toms desire to help
others is deeply instilled in him and reflects his true personality.
Demetra Flevaris, another cousin who attended Northwestern with Tom, feels the
same way. (Ex. 15). After witnessing Toms life-long commitment to religion, family, and
charity, she too is surprised by this case and believes that Toms conduct is
uncharacteristic of who Tom is. She personally experienced Toms generosity and
kindness after the birth of her daughter. A teacher at the time, Demetra felt conflicted
about leaving the work force. She worried about giving up her career and the additional
income, but at the same time felt anxiety about not being home with her child. Tom
discussed the situation with Demetra and assured her that he would help her find a job
when she was ready to go back to work. After about six months of staying home with
the baby, Demetra reached out to Tom. Within a few days of sending Tom her resume,
28
Tom helped Demetra get a job in the education field that fit perfectly with her schedule
and helped her personal and emotional well-being. Demetra will never forget how
Tom went out of his way to keep [her] in mind and help [her] get through what could
have been a difficult time.
Sandy, a pre-school teacher, (Ex. 16), and her husband of 34 years, Dan OMalley,
(Ex. 17), write separately to the Court about events they believe demonstrate Toms
charitable nature and true character. Allison is their niece and they have known Tom
about 10 years. Sandy was very happy when Allison married Tom. She finds him kind,
thoughtful, caring, and always thinks of others. Sandy will never forget Toms kindness
to her after her mother died just before Easter. Sandys mother always baked bread for
Sandy and her siblings as an Easter gift. The first Easter after her mother passed, Tom
and Allison figured out the recipe, baked several loaves of the bread, and then Tom
personally delivered it to Sandy and her siblings just like their mother used to. Sandy
and her siblings found it extremely touching. For Dan, Toms caring nature was
revealed during a pool party at their house that could have ended in tragedy, if not for
Toms diligence and attentiveness. At some point during the party, Tom noticed a
child struggling in the pool. Without hesitation, Tom, fully clothed, jumped in the pool
and pulled the child to safety.
Sandy and Dans son, Joseph OMalley (Allisons first cousin), a Senior Analyst at
a trading firm and an MBA student, sees Tom as a role model in both personal and
business matters. (Ex. 18). Like his parents, Joseph is touched by Toms unselfish and
caring nature. Joseph will never forget how Tom made Joes 84-year-old grandmother
29
so happy when he included her in a surprise birthday celebration for Allison. When Joes
grandmother died about a year later, Joe and the other grandchildren, remembered the
excitement and joy their grandmother felt at the surprise party. It was a cherished
memory of pure happiness for them all that would not have existed without Toms
unselfish and caring attitude towards others.
These same attributes lead Toms cousin, attorney Georgia Kyriacou, to
confidently conclude, like many of his other family members, that Toms conduct in this
case was not motivated by greed or the prospect of making a quick buck. (Ex. 19).
Georgia has known Tom since he was a baby. She has never known Tom to be anything
other than caring, supportive, hard-working and honest. Georgia remembers how Tom
gave up more lucrative endeavors to work in education and how hard he worked
day and night - to improve the schools and lives of the students. She knows that
Tom sincerely believed in his goals and that he is devastated by the outcome. Despite
this case, Georgia still looks upon Tom as a role model for her sons and hopes they
emulate his work ethic, his zest for life and his dedication to others. She asks for leniency
for Tom and hopes her letter reveals that Tom is a kind, sincere, compassionate, selfless
individual with great promise for the future.
Toms godmother, Lynda Chioros, also believes that if given the opportunity, Tom
will become the positive force that he was hoping to be. (Ex. 20). Having known Tom
his entire life, she confidently write[s] that Toms conduct does not define him as a
person and she is certain that his conduct could not have been motivated by greed or
a desire to harm others. For Lynda, Tom has always demonstrated tremendous
30
generosity with his time and resources and a deep compassion for others. Lyndas faith
in Toms future is further strengthened by Toms accountability, genuine remorse, and
continued motivation to help others.
Like his wife, Michael Chioros, a real estate developer and past-president of
several organizations serving children in Chicago, also believes that Tom has much
more to offer to [our] family and the community. (Ex. 21). Michael sees Tom as the
embodiment of their immigrant grandparents highest dreams and aspirations -
Intelligent, honest, and hard-working. Michael remembers how shortly before Tom
was getting ready to look at colleges, Toms father suffered some financial set-backs that
could have impacted Toms choices. As Michael notes, Tom didnt complain or act like
he was entitled to go wherever he wanted. Instead, he did what he could to help out and
at age 16 began not just working, but managing a fast food restaurant in Skokie. He also
did hours of college research about financial scholarships. After learning that oboe
players were more likely to get scholarships than other students, Tom learned and
mastered the Oboe. For Michael, Toms lack of entitlement and strong worth ethic, in
addition to his extraordinary generosity and community involvement, confirms
Michaels belief that Toms conduct in this case does not reflect who Tom Vranas really
is and he is certain that Tom did not intend to make this kind of choice when he initially
began working at SUPES. Michael hopes that in sentencing Tom, the Court will
consider the many contributions that a good and willing man like Tom can make to the
community and society. Additional letters from family are collected at Group Exhibit
A.
31
2. Friends
George and Lucia Economos are long-time family friends that have known Tom
since he was born and believe he is kind, honest and forthright. (Ex. 22). George is
retired from a career in publishing and Lucia is a retired librarian. Their daughters were
part of the church youth group led by Tom, which they attended regularly because of
Toms efforts and dedication to providing meaningful and spiritual programs. One
night before youth group, the Economos daughters were involved in a car accident on
the way to youth group. Upon hearing about the accident, Tom immediately went to the
scene to assist them. George and Linda are grateful that Tom helped [their children]
stay calm while the police filled out the accident report and believe this event
exemplifies Toms willingness to help others.
Chicago attorney Elias Matsakis, who has also known Tom since he was born, is
steadfast in [his] belief that Tom did not act out of greed or malice in this case. (Ex. 23).
Elias writes that Tom was different than the normal teenager who just focused on
himself. Tom was smart, respectful, engaging, creative, diligent, and very active in the
church. Elias, who served six years on the Glenbrook District 225 School Board, sees
Toms decision to work in education reform as a natural outgrowth of his long-term
commitment to public service and a genuine desire to improve school systems. To this
end, notes Elias, Tom worked countless hours and his work was both innovative and
exemplary. Elias finds it particularly unfortunate that Toms involvement in this case
and the media attention it has drawn will overshadow all of his hard work and passion
32
for education reform. He hopes that the Court will recognize Toms unique talents and
allows Tom to make amends for his conduct by giving back to the community.
Likewise, Joshua Golden, who met Tom in 1999 during college at Northwestern,
believes that Tom is a fundamentally good person with a lot of great things left to do for
our society. (Ex. 24). Toms excellent character and his genuine regret about his
actions convince Joshua that Tom will never act illegally again and that he will return to
making the world a better place and being a source of inspiration to others. Joshua,
who has created several technology companies, is so convinced of Toms future abilities
that he personally vouched for him to a client of his for a prospective job with the
clients company. After hiring Tom, the client raved about how helpful, honest, and
positive Toms impact has been on his company. Like Joshuas client did, Joshua hopes
that the Court gives Tom a second chance and that it will see that Tom has a bright
future and his positive impact over the rest of his life and the community will far
outweigh his conduct in this case.
Benjamin Levin, a friend since 1999, is one of these people who Tom has had a
positive impact on. (Ex. 25). During college, Benjamin witnessed Toms extracurricular
volunteer work with Habitat for Humanity and the church. After college, Benjamin
observed Toms continued commitment to family and community. In his letter,
Benjamin tells the Court about the time he flew into Chicago from New York and Tom
recruited him to help him clean a park in Glenview, Illinois. When Benjamin asked Tom
why they had to volunteer to clean a park in Glenview, Illinois, Tom told him that the
park was near his grandmothers house and that helping the community tend to the
33
park was something that made him feel good as he knew it would make his grandmother
smile. This blending of commitment to family and the community resonated with
Benjamin. It made him want to do good things in [his] own life. Benjamin writes, I
stayed close friends with Tom because of several life qualities that Tom embodies
respect for humanity, charity, connection of community, and love of family. I truly
believe that I learned more from Tom about these qualities than just about anyone else
(including my father and mother).
Benjamin hopes that Tom will not be defined by his conduct in this case. This
conduct is completely opposite of the Tom that Benjamin knows as Tom does not have
a greedy or malicious bone in his body. Because of Toms heartfelt remorse, his taking
accountability for his actions, his focus on making things right, and his continued
commitment to community service, writes Benjamin, Tom is still a role model for what
I define as the person I strive to be. Benjamin is certain that Tom will continue to be a
benefit to humanity, his community, and the country.
Brendan Murnane, 33, who works for AOL and lives in NYC with his wife, tells
the Court that he really would not be where I am today without [Tom] in my life. (Ex.
26). Brendan and Tom bonded as freshman at Northwestern through Melodious Thunk,
a college a cappella group. From day one, it was clear that Tom was (and is) one the
most supportive and warm-hearted individuals I have ever met, writes Brendan. A self-
described coaster through high school, Brendan was completely taken aback by the
amount of work and rigor at Northwestern. So much so, that by the end of his
sophomore year, Brendan was close to failing out and was suffering from depression.
34
Tom noticed Brendans plight and played a vital role in helping Brendan get back on
track. He listened, he empathized, and he helped Brendan put together a plan of
attack. Despite Toms own academic demands and other time consuming commitments,
Tom never failed to check in with to see what he could do to help him. Given this vital
role, Brendan truly believed that Tom had found his calling and destiny in the field of
education. And, since Tom is not the kind of person who seeks to benefit himself,
Brendan can only conclude that Tom could not have intended to harm anyone in this
case. Brendan hopes that the Court sentences Tom in a way that allows him the
opportunity to change another persons life for the better.
Similarly, Tom acted as a professional and personal mentor to Joseph Rusinak,
who attended the same high school as Tom and has known him for over a decade. (Ex.
27). Three years younger than Tom, Joseph remembers he always had a positive
impression, even during high school when they were not as close as they are now. Tom
is always willing to sit down and discuss work, relationships and even financial advice
with Joseph. Tom never made Joseph feel uncomfortable about asking for help and
Tom never asked for anything in return. Tom even answered every question that
Joseph had about Toms involvement in this case. Joseph has always known Tom to be
a thoughtful, generous, and extremely caring man.
The important and impactful work Tom does in the community also made John
Serritella reassess [his] goals and strive to be a better person. (Ex. 28). John, the
general manager of a Chicago metal finishing business, has known Tom for about ten
years. John remembers an immediate connection with Tom. John could tell just by
35
talking with Tom for a short time that he was not only a good guy, but that he was full
of promise and going to do great things. As time went on and they got closer, John
gained insight into Toms commitments and achievements. But he also learned more
about the core of Toms personality his genuine selflessness. As John puts it, to know
Tom is to know the real deal. Tom is the guy who types a letter of recommendation
to a prospective employer without ever having to be asked. The guy who will write you
a two-page e-mail about a job he heard about that might be a good fit for you. The guy
who walks into your house with his arms open, and makes you feel comfortable in your
own home. The guy who calls and offers to take you under his wing when you cant find
a job or a path in a struggling economy. The guy who everyone goes out of their way to
say, is such a great guy.
Now with this case, John has learned that Tom is also the guy who is humble and
responsible for his actions. Tom and John discussed this case at length. Tom shared
with John his tremendous remorse and shame about his conduct. Knowing Tom as well
as he did, John could tell that this case had decimated him. Still, John writes, Tom
NEVER ONCE tried to make an excuse for himself and Toms greatest sorrow was not
for himself, but for the students who, because of his conduct, would never reap the
benefits of the programs he worked tirelessly to create. John prays for a fair and just
sentence that recognizes how passionate Tom is about life and work and that allows
him to start the process of rebuilding his life.
John McLaughlin, a former combat search and rescue pilot in the U.S. Navy, can
think of no higher compliment than to say that Tom is a man Id like to have at my side
36
when bullets start flying. (Ex. 29). John has known Tom for 14 years. They met in 2003
through Johns volunteer work with the education fund of the Union League Club of
Chicago. At the time, John worked at a Chicago charter school in East Garfield Park and
Tom was a senior at Northwestern. John was immediately impressed with Tom. Unlike
most seniors in college indulging in the final excesses of their college life, Tom was
regularly commuting from Evanston to the Loop looking for ways to improve the lives
of children left behind by a failing school system. With Toms help, the Union League
Club gained new members and increased the resources devoted to closing the education
gap between wealthy and poor school districts.
John was excited and impressed when Tom became involved with the Supes
Entities as it would allow Tom to continue to leverage his talents to make public
education, in our nations urban schools, better. That is why John was shocked and
deeply saddened when he learned about Toms case. While John has the greatest respect
for the rule of law and for our legal system, he believes that Tom has earned a second
chance not only because of the way he lived his life before this case, but also because of
the way he took responsibility for his actions. When John asked Tom about this case,
Tom was forthright and direct about his conduct. John never heard Tom express an
iota of self-pity or attempt to minimize or divert blame onto someone else. Tom has
earned back Johns trust and John would endorse him for the most sensitive of
positions, including, if necessary, the care of Johns wife and children. John hopes for a
sentence that will allow [Tom] to use his tremendous talents to strengthen our
community, our state, and our country.
37
Jon Elhardt also feels grateful to have someone like Tom in [his] life. Jon and
Tom met 14 years ago, when they were in college. (Ex. 30). He has observed Tom to be
an extremely well devoted, hardworking person with an entrepreneurial spirit. Not
only has Tom been involved with numerous charitable organizations during the last 14
years, but he enjoys an excellent reputation and is respected for his trustworthy and
helpful nature. Jon remembers Tom being helpful even in college. When Jon was
struggling to find a part-time job, it was Tom who went out of his way to offer [him]
guidance and advice and proved to be a great help. Given this, Jon was admittedly
shocked when he heard about this case. After the case became public, he met Tom for
lunch. Tom told him how he desired to own his mistake and hold himself accountable.
As difficult as this candid conversation must have been for Tom, it reassured [Jon] that
Tom, despite this case, was the same good person that [he] knew and loved. Jon is
certain that Tom would never go out of his way to harm someone and that he is not
greedy. Rather, Jon writes, Tom is someone who definitely cares about the community
and others. Jon hopes Toms punishment will reflect the genuine, honest, and authentic
man that truly is and has always been.
Even Toms primary care physician, Dr. John Revis, has written a letter to the
Court on Toms behalf. (Ex. 31). He has known Tom for 15 years as his doctor and as a
member of the same church. Dr. Revis was very surprised when Tom admitted his
transgressions to him. For Dr. Revis, Toms conduct is completely out of his character.
Dr. Revis has only known Tom to be a community minded individual who regularly
puts the needs of others before his own. For example, writes Dr. Revis, Tom created
38
our churchs first website, led the high school youth group, taught Sunday School, and
coached the youth athletic team.
Dr. Revis has seen the tremendous negative impact that Toms involvement in this
case has had on him. In addition to intense regret and embarrassment, Tom has
suffered from anxiety that arose during this case, for which Dr. Revis is treating him. Dr.
Revis reports that Toms goal now is to work hard, better himself, and make amends for
his conduct by continuing to contribute positively to our society through hard work and
charity. Additional letters from friends are collected at Group Exhibit B.
3. Colleagues
As he did with his friends and family members, Tom candidly discussed his illegal
conduct with former colleagues, employees, interns, and educators. In confessing his
conduct, Tom held himself fully accountable and did not minimize the seriousness of his
conduct. Moved by Toms genuine remorse, contrition, and otherwise exemplary life,
these individuals have written letters to the Court in support of Tom. These letters
provide specific, first-hand evidence of Toms tireless work ethic and his genuine desire
to improve education despite his transgressions.
Dr. Vilicia Cade, an educator for the past 20 years, met Tom in 2012. (Ex. 32). At
that time, Dr. Cade worked in Chicago helping leaders to improve education in high
poverty communities. Dr. Cade grew up in foster care and group homes and knows
first-hand the transformational power of education. Dedicated to providing all
students with a high quality education, Dr. Cade was immediately drawn to Tom who
she describes as a kind and hard-working, authentic individual. Dr. Cade recalled
39
many conversations with Tom about improving the quality of education by developing
highly effective leaders. Dr. Cade admits that given the public nature of this case, she
was anxious regarding writing this letter. Many people told her not to get involved.
Ultimately, Dr. Cades conscious and gut told her it was the right thing to do because
Tom held himself fully accountable.
Similarly, Dr. Bernard Taylor, an educator for 28 years and a former
superintendent of the East Baton Rouge Parish School System, also sought advice from
his Pastor about writing a letter for Tom. (Ex. 33). Dr. Taylor met Tom in 2006 as a search
candidate. Dr. Taylor decided in favor of writing a letter because of Toms acceptance of
responsibility, his genuine remorse, his strong commitment to improving education, and
his belief that Tom can still be an asset to the community. Dr. Taylor appreciated
[Toms] sensitivity to and understanding of a myriad of issues confronting urban school
districts and his help in finding Dr. Taylor service opportunities that enabled [him] to
serve districts where the need to improve educational opportunities was an imperative.
Even after becoming a superintendent, Tom continued to be a knowledgeable colleague
and a trusted advisor who was just a phone call away. For Dr. Taylor, Tom is one of a
few people that are committed to improving educational outcomes for students in
underserved districts. Given Toms commitment, Dr. Taylor is certain that one of
[Toms] biggest regrets is comprising the ability to serve the students of urban school
districts. That is why it is Dr. Taylors sincerest hope that his road to redemption allows
for his talents and skills to be used to continue his service to those students.
40
Dr. Cozzette Buckney, the owner of an educational consulting firm, is a life-long
educator. (Ex. 34). She worked at CPS for over 35 years and then in several other districts
for another six years. Dr. Buckney met Tom ten years ago, when she did some training
with the Supes Entities. In working with Tom, she saw first-hand, his interaction with
my colleagues, his tireless work ethic, and his leadership with many school districts and
staff to meet their goals. She believes that all the good in Toms life outweighs the bad
and hopes for leniency.
Dr. Earl Metzler also hopes that the Court gives Tom the well-deserved chance
to again positively contribute to the community and those around him. (Ex. 35). He
met Tom in 2009 during his participation as a student and later as a coach/mentor at
SUPES. A former pubic high school principal, Dr. Metzler is the current Superintendent
of Schools in a multi-district cooperative School Administrative Unit in New Hampshire.
While he does not make excuses for Tom, he supports and trusts him today because of
Toms obvious passion for helping students achieve and because he is truly
remorseful for any hurt that he caused. Dr. Metzler also stand[s] behind the hard work
that we did despite the recent controversy. Dr. Metzler remembers Tom as being
inspiring both professionally and personally and as someone who always offered
sound advice and was an excellent support system for aspiring superintendents. Dr.
Metzler believes that Tom is a good person and that he will do whatever he can to
make up for his conduct and he will not be in trouble again.
Teresa Cummings, an executive vice president for a national education non-profit,
has worked in education for 24 years as a teacher and administrator. (Ex. 36). She met
41
Tom in 2011 when she participated in a superintendent training program. She worked
with him in 2013 and 2015 in a principal development program in California and a
superintendent search. Teresa tells the Court that [a]s an instructor, and peer, I always
found Tom to be a kind and generous man with a passion for equitable education for all
students, regardless of where they come from, or whom they go home to. Even after
they stopped working together, Tom remained a sound board for Teresa and
encouraged her to continue to fight for students and families who do not have the ability
to fight for themselves. She knows that Toms actions were wrong, but hopes that her
letter provided insight on another side of Mr. Tom Vranas, a man who has ignited
passion in others to fight for an equitable education for all students.
Kelvin Adams, the Superintendent of the St. Louis Public Schools and an educator
for 35 years, worked with Tom for about five years. (Ex. 37). He describes Tom as a very
honest, hardworking, and transparent leader. Kelvin recalls how Tom successfully
assisted our school district in writing a School Improvement Grant that supported
increasing academic achievement in our lowest achieving schools. He completed the task
through a process of collaboration and collective decision making with our school leaders
and central office administrators. Kelvin notes Toms 100% acceptance of
responsibility and his deep remorse in asking the Court to give Tom a second chance.
Dr. Matthew Wendt, the Superintendent of Schools for School District 308, an
Illinois district serving over 18,000 students, met Tom in late 2012 during a SUPES
training program, where Dr. Wendt served as an instructor. (Ex. 38). Working with Tom
allowed Dr. Wendt to gain personal and professional insight into Toms character. Of his
42
experience working closely with Tom, Dr. Wendt writes Tom is a caring person and has
afforded to me that compassionate concern on many occasions. He is a great listener and
conscientious about the feelings and opinions of others. As I questioned and sought
support as a SUPES teacher, Toms advice was based on a deep desire to focus on others
and a conviction to balance and family.
Dr. Wendt was so impressed with Tom that prior to this case he was prepared to
hire SUPES in his district. While this case showered unwanted attention within his
district on Dr. Wendt regarding his employment with SUPES, Dr. Wendt is not angry at
Tom and he is still proud of his work there. Dr. Wendt sees courage in Toms guilty plea
and his personal apology to him and other colleagues. Dr. Wendt hopes that the Court
will consider the whole person prior to sentencing and offer a good and decent man the
opportunity to redeem himself.
Dr. Patrick Russo, an educator for over 40 years who served in various supervisory
positions throughout schools across the United States, asks for the same. (Ex. 40).
Specifically, he hopes the Court will consider all the good that Tom has done during his
work and efforts with the many school districts to improve the education for all children
throughout the United States. Dr. Russo worked with Tom at SUPES and PROACT for
two years. He found Tom to be direct, honest, and fair in his dealings and that Tom
always treated people with respect. Notably, writes Dr. Russo, Tom focused on
providing services to the school districts we were working with to improve public
education and the lives of children [sic] school districts were serving.
43
Jenai Emmel, a national education consultant in Memphis Tennessee, met Tom in
2014 during her participation in a PROACT academy. (Ex. 40). Jenai describes the
program as selective and high quality. Despite her disappointment after learning
about this case, Jenai writes, To this day, I still cite my experience with them as one of
the best professional development opportunities of my professional career. Since
graduating from the program, Jenai notes, she and many of the other attendants have
assumed cabinet roles and superintendent roles throughout the country. Jenai is
humbled by Toms honesty when he personally apologized to Jenai for his conduct.
She hopes that the Court will balance Toms actions in this case with his significant and
positive contributions to urban school reform and to children within low income school
districts. Similarly, 2012 SUPES graduate, Tony Lamair Burks, tells the Court that after
participating in a year-long training program with SUPES, he felt a renewed passion
for the students and working to improve education for all children. (Ex. 41).
Julio Cesar Contreras, a district administrator in the Tulsa Public Schools and
educator for 15 years, is also committed to positively impacting the lives of children and
adults through education. (Ex. 42). He met Tom in 2012, while participating in a
leadership academy at SUPES. At the time, Julio was the Deputy Chief of Schools for the
CPS. Julio remembers Tom as helpful, friendly, involved, and knowledgeable. He writes
about how Tom reached out and worked with [him] to keep-up with the program after
Julios mother got sick and Julio fell behind. Notably, at the time, Julio didnt even know
Tom that well, revealing to Julio that Tom has a good heart. Despite this case, Julio is
44
thankful to Tom for his support and knows that he is kind, generous, selfless, caring
and good intentioned.
Bruce Kelly Barton has known Tom for over seven years. (Ex. 43). Bruce believes
that his 40-year career in education working with many different professionals makes
him uniquely qualified to judge the character and quality of individuals. When
working with Tom, Bruce noticed Toms dedication to his work and commitment to
mak[ing] a difference in our education system. Bruce never got the impression that
Tom was in it for personal gain, which is the quality that he admired most. Bruce
recalls Toms hard work and how Tom was available to everyone at all times regardless
of the time of day or how busy he was. Bruce is certain that Toms conduct in this case
is not representative of the person that [he] knows. He hopes that Toms conduct in
this case does not overshadow all of his hard work and the positive contributions he had
made to the education field and to the community.
Victor Saad, the founder and President of Experience Institute, a company that
assists graduate students in career choice through apprenticeships in a variety of
industries, met Tom after this case became public. (Ex. 44). Victor feels that his letter is
important in revealing Toms character because they met during the worst time in
[Toms] life. For Victor, a mans character is not defined by their mistakes alone, but by
how he acts in the face of those mistakes. During a time of tremendous stress and
shame, Victor observed Tom to be a man striving to rebuild his career and integrity,
through honesty, self-reflection and hard-work. At their first meeting, Tom told Victor
about this case and that he has made serious mistakes. He was also honest and
45
remorseful about his case and his desire get back on his feet. Instead of wallowing
in self-pity notes Victor, Tom was trying to remain constructive, positive, and a
contributing member of society. Victor was impressed and decided to give Tom a
chance. Given Toms work ethic, skill set, and thoughtful nature, he quickly became
a helpful confident and close friend. When Victors father was diagnosed with stage
four pancreatic cancer, Tom was one of the first people he told. Not only did Tom help
Victor with work so he could take time off to be with his family, but Tom showed great
guidance and compassion to Victor during this difficult time. In working with Tom, it
is obvious to Victor that Tom has learned from his mistakes in this case. Notably, Victor
tells the Court, he is evidence of the fact that Tom is using his experiences good and
bad- to help others do better work and live better lives. Victor hopes that his letter
reveals a fuller picture of Tom and the man that he is and will continue to be in the
future if given the opportunity. Additional letters from colleagues are collected at
Group Exhibit C.
4. Interns
Tom created and ran the internship program at the Supes Entities, hiring over
100 college students to work directly with him. Tom hoped these students would
eventually consider a career in education or public service. Several of Toms former
interns at the Supes Entities have written to express their gratitude for his mentorship
and role in their post-collegiate success.
Meg Power, a high school math teacher who interned from 2010-2011, writes that
Tom helped push me to see that I had a passion for education, while challenging me to
46
not settle for less than what I am capable of. Without his encouragement and support, I
would have never pursued a teaching career. (Ex. 45). Meg kept in touch with Tom
after she finished her internship and he remained a source of advice, support and
encouragement. Tom was honest with Meg about his conduct in this case. Still, she
writes, I feel truly lucky to have Tom Vranas in my life, he has proven to be a great
mentor and an even greater friend.
Travis Hiller, an associate for an executive search firm, also calls Tom a great
mentor in spite of this recent wrongdoing. (Ex. 46). Travis interned at the Supes Entities
in 2012 and began working full time in 2014. Of his experience, Travis writes Tom
challenged me to reach levels of productivity and growth that I did not think possible.
And even when Travis made mistakes, Tom remained supportive and always
approached the situations as teaching moments. In working for Tom, Travis also saw
that Tom cared deeply about his employees and Tom contributed extensively to his
companies culture of hard work and fun. In 2015, when Travis had to find another job
after the companies shut down, Tom generously helped him land on [his] feet.
Kristin Osborn also started out as an intern and then began working full time in
2011. (Ex. 47). She directly reported to Tom for five years. During that time, Kristin
writes, Tom became far more than a boss to me, he was more like the older brother I
never had. Despite a busy schedule, Tom managed to take time to teach Kristin
professional development and a strong work ethic. Kristin truly believes that she is
a much better, smarter, and prepared person for the world having known Tom Vranas.
47
Andrea Marcos, an Analyst at a California start-up, who interned for Tom in 2010,
describes him as a trustworthy manager who took her seriously, even though she was
simply an intern. (Ex. 48). She credits Toms guidance for becoming more self-
confident and better able to advocate for herself. Andrea has learned important
lessons from Tom during the honest discussions they had about his conduct.
Brittany Smith, who works for Google, interned at PROACT in the Summer of
2009, when she was in college. (Ex. 49). She credits her internship at PROACT for helping
her land a job at Google after graduating college. Brittany worked directly with Tom,
describing her time on his team as incredibly valuable in that it helped her define
important career goals. She writes, Tom has a knack for working with young adults,
bringing out the best around him, and finding creative ways to motivate and encourage
others. Brittany continues to admire Tom, citing his long history of kindness,
compassion, and living in service to others as a true testament to his character. She
believes that he if given the chance, can still make positive contributions to issues that
he cares about, especially in communication and community outreach.
Former intern Anna Steward, now a legal recruiter in New York, credits her
internship and everything [she] learned from working closely with Tom, to [her] success
as a recruiter over the last two years. (Ex. 50). From practical advice on saving, life
expenses, and working hard, Tom was extremely generous with his time and preparing
his interns for real life. From the beginning, it was clear to Anna, that Tom was an
extremely hard worker who was dedicated to his business and to his family. It was also
clear to Anna that Tom genuinely desired to improve the education system and hoped
48
that his business would have a net positive effect on the world. Tom has expressed his
deep regret and shame to Anna. While Anna does not know why Tom got involved in
this case, she does know that he is not a malicious or bad person and that his conduct
does not define him. For Anna, Tom is a good man who can make the world a better
place. Additional intern letters are collected at Group Exhibit D.
5. Clergy and Members of the Saints Peter and Paul Greek Orthodox Church
and Service to the Community
Reverend Father Chris Kerhulas, a Greek Orthodox Priest since 1975, has known
Tom and his family for over 15 years. (Ex. 51). Impressed with Toms honesty, love for
our faith, sincerity, and motivation, Reverend Kerhulas enlisted Toms help throughout
the years to reach out to the youth movement and they planned numerous retreats
together (involving 400 participants) and camp programs. As a volunteer, Reverend
Kerhulas writes, Toms creativity was second to none among those involved on this
level. No task was ever beneath him and he never turned down a challenge. Even to this
day, Tom never fails to roll up his sleeves to help the Church in any program that needs
help. Having had numerous discussions with Tom about the ethical and moral
realities surrounding his conduct, Reverend Kerhulas is certain that Tom realizes his
mistakes and that his remorse is genuine. He hopes for a sentence that will allow the
community to continue to benefit by Toms commitment to bettering the lives around
him through his charity and concern for others.
When Reverend George Pyle, who has worked over 29 years in youth ministry,
thinks of Tom, he thinks of someone whose Sunday School teachers always called a
49
Great Kid and someone who was equally well respected and loved by his peers. (Ex.
52). People gravitated toward Tom and admired him for his integrity, honesty, and
kindness. In his own encounters with Tom, Reverend Pyle writes, Tom revealed
himself as a person beyond his years in wisdom and character and as someone he could
completely trust. This trust, adds Reverend Pyle, continues today and he has no
hesitation in standing for Tom Vranas character.
Anna Kallis, the religious education curriculum developer for Saint Peter and Paul
Greek Orthodox Church, has known Tom for 14 years. (Ex. 53). Anna describes Tom as
an incredible human being who genuinely cares about people and has a servants
heart. She remembers meeting Tom when she was a freshman in high school. Tom, in
his 20s, was the advisor for her youth group. Not only was Tom unique in that he gave
up his time every Tuesday evening along with many weekends to assist with the
program, but he was also fun, engaging, hardworking, interested in our lives, faithful,
and a great example of the kind of young adult I hoped to grow into.
As an adult, Anna crossed paths with Tom again when she began teaching Sunday
School at the Church. Although she did not fully appreciate the kind of selflessness it
takes for a young adult in their twenties to volunteer as a youth group advisor, as a
teacher now herself, she appreciated Tom even more. When Anna needed a teaching
assistant that was both engaging and relatable, she naturally looked to Tom, to which
he readily agreed. They taught the first few classes together, but then Tom humbly and
remorsefully stepped down after this case became public. He told Anna that he felt
terrible about what he had done and did not want his presence to hinder the students
50
experience and relationships with their faith, which only strengthened Annas belief that
Tom genuinely cares about the growth and development of young people. While she
understands why Tom stepped down, Anna still wholeheartedly believe[s] in Tom and
his abilities and that he will continue to positively impact the lives of others if he is
allowed.
Brad DeSent, who has known Tom for 25 years through the church, also believes
that Tom has a lot more to contribute to the community. (Ex. 54). Tom co-led the youth
group at church that Brads daughters, now grown, were part of as children. Brad
recalled Tom being a warm and nurturing leader and his girls still talk today about
the experience they had over 20 years ago. Another positive experience Brad had with
Tom was when they worked together at Habitat for Humanity construction sites. In the
past year, Brad worked with Tom to build a fire pit and recreation area at the parish.
Brad respected Tom not only for his hard work on the project, but also for not dodging
the project because of the negative publicity surrounding his case. In Brads view, Tom
showed integrity and grace by keeping his word.
John Colis children were also a part of the church youth group co-led by Tom,
when Tom was a young adult. (Ex. 55). John has known Tom for over 30 years, and has
observed him as an active member of the church as a child, teenager, and adult. He is
thankful to Tom for his service as a youth group leader and believes his children were
the better for his efforts. He also finds it particularly significant that Tom undertook
this role in our church at an age when most people who are single and out of college are
busy living a care free life style. For John, Toms service to the church is reflective of
51
his core character traits giving, caring, and a person of action. When Tom and John
discussed this case, John was impressed by Toms level of self-awareness. Tom was
clearly heartbroken over his actions and made no excuses for his conduct. Toms
high level of contrition and remorsefulness gives him great hope for Toms future.
Father Panagiotis Boznos, the head priest of Saints Peter and Paul Greek Orthodox
Church, knows that Tom will receive a multitude of letters describing his charitable
nature, his life of service, and his general character, so he focuses on Toms repentance,
which Father Boznos has witnessed and am witnessing. (Ex. 56). For Father Boznos,
Toms difficult journey began with his public acknowledgement of guilt and has
continued with his taking accountability for the hurt he has caused others, both within
the Chicago Public Schools and personally with his own life. After many profound
and contrite conversations with Tom, Father Boznos sees that although there have been
many painful moments, Tom has been positively impacted, by his experience in terms
of future growth. As Toms priest, Father Boznos pleads to the Court for leniency for
Tom and a sentence that allows him to continue to walk the path of renovation.
Additional letters are collected at Group Exhibit E.
6. Current Service to the Chicago Community
As the above letters reveal, Toms compassion, kindness, and generosity, has been
ongoing throughout his entire life in fact, dating back to Toms high school years - and
well before his conduct in this case began. See (Ex. 2, Chronology of Volunteer and
Charitable Activities 1993-2017). After the Supes Entities shut down, Tom intensified his
community efforts, completing over 500 hours of community service (about 8 hours a
52
day) since January 2016 at Habitat for Humanity, Harvest Food Pantry, and the ARK of
St. Sabina on Chicagos far Southside. This work is vital, unique, and ongoing.
Jocelyn Jones, the Executive Director of the ARK of St. Sabina, describes in detail
the many ARK programs benefitting at risk youth on the Southside of Chicago. (Ex. 1).
Unfortunately, state budget cuts over the last two years dramatically limited the ARKs
ability to build a website, create marketing materials, develop the donor database, and
apply for grants all of which are important to fund the services and programs for the
some 600-young people that rely on them. In January of this year, it became so
overwhelming to identify and bring in funding sources that Jocelyn prayed that God
would provide us with some additional help securing resources. Shortly thereafter,
Jocelyn met Tom, who quickly became an asset to the ARK, leading Jocelyn to conclude
that God answered [her] prayer by sending Tom to volunteer.
Tom showed up at the ARK eager to help in any area he could. He started out in
the youth center playing basketball with the kids and tutoring them after school, which
he continues to this day. The kids absolutely love Tom, and they look for him each week
when he comes to volunteer. Importantly, Tom is in the middle of planning a Chicago
Police vs. Fire Department basketball game that is part of [The ARKs] Annual Hoops for
Peace event, so the youth get to meet the first responders in a neutral/fun environment.
After a few weeks at the ARK, Jocelyn, also realized Toms unique and impressive
administrative skill-set. She shared with Tom the ARKs desperate need for a new
website, something the agency had been attempting to build for over a year. Within a
month, Tom helped build a completely new website. At the same time, Tom
53
restructured, customized, and trained [ARK] staff on the Salesforce Database, he helped
to organize one of our agency community events, he has been working with other St.
Sabina outreach arms to help with their marketing and websites, and he conducted
extensive research on foundations that can potentially fund us and has generated
donations from his efforts.
This remarkable work, however, is not what impressed [Jocelyn] the most
about Tom. Rather, she writes, In my nine years working at the ARK, I never worked
with a volunteer that was more committed and passionate about the work that they were
doing. Whether it is working with the young people at the ARK or helping Jocelyn with
the important administrative tasks, Tom is deeply committed to the children and getting
the agencys message out to the world. His passion and energy have even motivated
other ARK staff members to work harder for the cause and he is considered an important
and valuable member of the St. Sabina team.
Jocelyn is grateful to Tom for the time, commitment, and passion that he has
devoted to the ARK and the children. The incredible work that Tom has done over the
last few months is a prime example of how unique and invaluable Tom is to the ARK.
Jocelyn does not want to lose Toms help. She truly believes that it would leave a huge
void in our program if Tom was unable to do this critical work for us. Jocelyn graciously
asks the Court for any consideration that [the Court] can give to allowing Tom to
continue his work at the ARK. As the Executive Director, Jocelyn would be happy to
work with the Court system to formalize and expand Toms work as a component to
his sentence. It is her greatest hope that Tom will have the opportunity to continue using
54
the gifts that God gave him to serve and make a difference in the lives of the children in
our community.
7. Genuine Remorse, Acceptance of Responsibility, and Cooperation
In addition to publicly pleading guilty, Tom privately took responsibility for his
conduct to his family, friends, colleagues in the education industry, clergy members, and
the community. He admitted his participation in the bribery scheme and his deletion of
emails during the IG investigation of his conduct. A common theme among Toms letters
is that Tom did not diminish the seriousness of his conduct, minimize his role, or blame
others. Many of the writers were moved by Toms genuine remorse and his candid
discussion with them about how his conduct affected others, especially in the education
industry. Likewise, Tom held himself accountable for contributing to breaking the
publics trust in government. Those that know Tom best conclude that Tom understands
the gravity of his conduct and that his remorse and desire to make amends for his conduct
is genuine. Too, the probation officer concluded, that despite Toms illegal conduct in
this case, it was aberrative within the context of his entire life and [t]here is no
evidence that [Tom] harbors any animus or resentment towards the criminal justice
system or its representatives. (Sent. Rec. at 2).
Toms substantial cooperation in this case also demonstrates his genuine remorse
and desire to make amends for his conduct. Although he was not the first person to plead
guilty and cooperate with the Government in its investigation, it is the Governments
position that Tom was immediately more truthful and forthcoming than his
codefendants. (Sent. Rec. at 3). Tom met with the Government on three separate
55
occasions. During his proffer sessions, Tom candidly and fully explained the nature and
extent of his conduct and took full responsibility for his actions. Tom also provided the
Government with significant and extensive information regarding the conduct of others
involved in the scheme. Tom admitted that the scheme did not end once the October
2012 contract was finalized, but that it encompassed the $20.5 million contract to the
Supes Entities. Toms admission to the full scope of the conduct was important because
there was no explicit quid pro quo regarding the $20.5 million contract and his codefendant
vehemently denied that it was part of the corrupt agreement.
Finally, in anticipation of his paying restitution and prior to pleading guilty, Tom
escrowed, with his attorneys, distribution checks that he received from the Supes Entities
after the companies shut down. Tom has also been working diligently with CPS to
determine a settlement that will result in him paying money greater than restitution to
the district.
IV. THE SENTENCING CALCULATION
A. The Guideline Range
On April 12, 2016, Tom pled guilty to one count of conspiracy to commit federal
program bribery in violation of 18 U.S.C 371. The parties agree that Toms advisory
guideline range of 108-135 months, is based on a total offense level of 31 and zero criminal
history points).3 Toms advisory guideline range is capped at 60 months imprisonment
3
The offense level of 31 depends on a base offense level of 12, plus 16 points because the value of
the benefit received, $2.9 million, was more than $1,500,000 but less than $3,500,000; plus four points
because the offense involved a public official in a high-level decision-making position; plus two points for
obstruction of justice; and, a decrease of three points because Tom clearly demonstrated an acceptance of
responsibility for the offense and timely notified the government of his intention to plead guilty.
56
because the statutorily authorized maximum of sentence of five years is less than the
minimum of the applicable guideline range (108 months). 18 U.S.S.G. 5G1.1.
Because of Toms substantial assistance, the Government will move, pursuant to
5K1.1, to depart downward from the low end of the applicable guideline sentence (60
months), and is further expected to recommend a sentence of 39.6 months imprisonment
or 66% of the low-end of the applicable guideline sentence. The probation officer
recommends a below-guidelines sentence of 24 months imprisonment. For the reasons
set forth below, we submit that a sentence of incarceration in this case would be greater
than necessary to achieve the goals of sentencing. We ask for a sentence of three years
probation, including a lengthy period of home confinement and substantial community
service.
B. The 3553(a) Factors
The plea agreement allows Tom to ask for any sentence that is permissible under
18 U.S.C. 3553(a). In determining a reasonable sentence under the facts of each
individual case, the sentencing court must look beyond the advisory guidelines to the
factors set forth in 18 U.S.C. 3553(a). See United States v. Dean, 414 F.3d 725, 729-731 (7th
Cir. 2005) (Section 3553(a), unlike the Guidelines themselves after Booker, are
mandatory and the guidelines, being advisory, can be trumped by the other
sentencing factors under 18 U.S.C. 3553(a)).
The Supreme Court has described that statutes parsimony provisionthe
instruction to impose a sentence sufficient, but not greater than necessary, to
accomplish the purposes of sentencingas its overarching command. Kimbrough v.
57
United States, 552 U.S. 85, 101 (2007). Those purposes include the need for the sentence
imposed to reflect the seriousness of the offense, to afford adequate deterrence, to protect
the public, and to provide the defendant with needed training, medical care, or other
correctional treatment. See 18 U.S.C. 3553(a) (2) (A)-(D). The statute also directs courts
to consider, among other things, the nature and circumstances of the offense and the
history and characteristics of the defendant, the kinds of sentences available, and the
need to avoid unwarranted sentence disparities among defendants with similar records
who have been found guilty of similar conduct. Id. at 3553(a) (1), (3), (6). District
courts enjoy broad discretion to fashion an appropriate, individualized sentence in light
of the factors in 18 U.S.C. 3553(a). United States v. Warner, 792 F.3d 847, 855 (7th Cir.
2015). Although the Court must make a finding regarding the correct Guidelines range,
it must not presume that a within-Guidelines sentence is reasonable, United States v.
Hill, 645 F.3d 900, 905 (7th Cir. 2011), or that a below-Guidelines sentence is unreasonable,
United States v. Jordan, 435 F.3d 693, 698 (7th Cir. 2006). Further, as the Supreme Court
has made clear, no extraordinary circumstances are required to support a variance
from the advisory Guidelines range or to justify a sentence of probation. Gall v. United
States, 552 U.S. 38, 47 (2007). Rather, in all cases, the sentencing court must make an
individualized assessment based on the facts presented to determine a sentence
sufficient, but not greater than necessary. Id. at 50; United States v. Young, 590 F.3d 467,
474 (7th Cir. 2010).
1. Toms Personal History and Characteristics Support a Sentence of

Probation
58
Section 18 U.S.C. 3553(a) directs the sentencing court to consider a defendants
history and characteristics. Warner, 792 F.3d at 857. The outpouring of letters provided
on Toms behalf present a true and accurate portrayal of the man beyond the criminal
conduct that brought him before this Court. The letters reveal that Toms conduct in this
case stands in stark contrast to an otherwise praiseworthy life filled with repeated and
continuous good deeds, selflessness, and ethical conduct. The letters show that Tom is
not a greedy, selfish, or materialistic person. But rather, they reveal that Tom is a kind,
generous, and compassionate person and that hard work, family, community service,
education, and religion are at the core of who he is. Id. at 858 (defendants character
letters were sincere and credible evidence of defendants excellent personal qualities
that were different from those which he manifested in committing the crimes he has
admitted.). See also (Sentencing Rec. at 3) (Tom lived a responsible, law-abiding, and
otherwise upstanding personal and public life, including charitable and volunteer work
that predates his detection in the instant case).
Many of the letters are written by individuals who witnessed and benefitted from
Toms generosity first-hand. From sacrificing vacations to building homes with Habitat
for Humanity, to accompanying elderly relatives to chemotherapy and dialysis
appointments, to helping friends get back on track by being a patient listener and
advisor, and even learning magic to perform for hospitalized children and their families,
Tom is the kind of person who can be relied upon in times of need, no matter how busy
he is or what hardship is going on in his own life. Importantly, Toms letters also confirm
that Toms dedication to charity and good work goes back many years - to high school,
59
in fact and goes beyond simply donating money, but involves true sacrifice and time
commitment, making it credible and persuasive evidence of Toms character which the
Court can rely upon to justify a sentence of probation. Warner, 792 F.3d at 857
(defendants long record of charity was the primary mitigating factor that led the
district court to sentence Warner to two years probation and community service, rather
than the custodial sentence of 46-57 months recommended by the Guidelines).
The letters also unanimously describe Tom as a hard worker that was truly
dedicated to education reform and bettering struggling school districts. Finally, Toms
letters reveal that he understands the gravity of his conduct, his remorse is genuine, and
that he is a person of high character who can and will if given the opportunity continue
to make significant contributions to the community. All of which are important
considerations under 18 U.S.C. 3553(a) and support, whether taken alone or in
consideration with the other mitigating factors discussed in this memorandum, a
sentence of probation with home confinement and community service. Id.
2. Toms Cooperation Supports a Sentence of Probation
Likewise, Toms extraordinary cooperation with the Government in this case
reflects his sincere remorse and desire to make amends for his conduct and should be
considered in mitigation. United States v. Fernandez, 443 F.3d 19, 26 (2nd Cir. 2006)
(defendants cooperation can be considered as a measure of his remorse and contrition,
important considerations under 18 U.S.C. 3553(a)(1)). Tom implicated himself in a
crime, and fully cooperated with the Government. Unlike his codefendants, from the
beginning of his cooperation, Tom told the truth and he did not minimize his conduct or
60
try to limit the scope of the fraud during his proffers or in his plea agreement.
(Sentencing Rec. at 4). Undoubtedly, Toms decision to tell the truth influenced Gary,
who persisted even in denying the full scope of his conduct up until sentencing, to forgo
a trial and plead guilty. Moreover, in proving loss against Gary at sentencing, the
Government relied on Toms admissions to the full scope of the fraud and his statements
about Garys direct involvement in compensating Barbara for securing the $20.5 million
contract. (Dkt. #91 at 6).
Toms full and truthful cooperation strongly supports, along with other factors
described in this memorandum, a sentence of probation with home confinement and
community service. United States v. Wachowiak, 496 F.3d 744, 754 (7th Cir. 2007)
(observing that the district court may give further weight to a defendants remorse and
cooperation, beyond the acceptance of responsibility adjustment, and affirming the
below-Guidelines sentence for child pornography offender based on his character,
remorse, and low risk of recidivism).
61
3. The Unique Nature and Circumstances of the Offense Support a Sentence of

Non-Incarceration
Tom acted illegally and there is no doubt that he willingly participated in a serious
offense resulting in a breach of the publics trust in government. But, a sentencing judge
must consider not only the seriousness but also the nature and circumstances of the
offense. Warner, 792 F.3d at 859. Here, the nature and circumstances of the offense,
when taken together with the other factors, supports a sentence of non-incarceration for
Tom. These facts do not justify or minimize the offense, but aid the Court in assessing
Toms culpability at the time he began participating in the offense. An assessment of the
individual facts of this case also provides the Court with an understanding of how this
otherwise decent, hard-working man, deeply committed to public education and
community with no criminal history, got involved in a bribery scheme.
Tom is 36 years old and has no criminal history whatsoever. Prior to his work
with the Supes Entities, Tom had an unblemished academic record and the beginning of
a promising career in the education field. Tom began working with Gary at the Supes
Entities with good and honest intentions and there is no evidence that he intended to
commit a crime.
Rather, the evidence reveals the opposite. Tom was not involved at the beginning
of the scheme. Tom was not the driver of the scheme. It was Gary, Toms former
mentor, who cultivated the relationship with Barbara and concocted the corrupt payment
agreement, initially keeping it a secret from Tom. Ultimately Gary corrupted Tom and
Tom willingly participated in the offense instead of confronting Gary or leaving the Supes
62
Entities. From these facts, there is no doubt, that Toms ultimate participation in the
scheme was a direct result of his association with his codefendants who brought him into
the scheme to help them. (Sent Tr. at 87) (The Court - he [Tom] knew about it but he
really helped you [Gary] and Ms. Byrd-Bennett as opposed to being a driver of the
scheme); (Sent. Rec. at 3) (The Probation Officer - it is recognized that Defendant Vranas
would likely not have engaged in the instant behavior if not for his codefendants
involving him.); (Sent. Tr. at 39) (The Government - Gary was the one who had the
agreement and ultimately corrupted Tom Vranas in the process, someone who was not
involved in the corrupt scheme from the beginning). All of which fully supports the
probation officers conclusion that Toms moral blameworthiness is distinguishable
from his codefendants. (Sentencing Rec. at 4); See also (GV Exhibits at 122)(email from
Gary to Tom highlighting Toms remorse and understanding that their conduct was
wrong, as compared to Garys lack of regret and chalking the crime up to business as
usual).4
Those that know Tom best also confirm that Tom would not have committed this
crime on his own. Additionally, given Toms passion for helping others, his proven
record of charity, and his genuine remorse, Toms supporters unanimously conclude that
Toms conduct was not motivated by greed or a desire to harm others. For example,
Toms wife tells us that when Tom became a part of PROACT, SUPES, and Synesi, he
really believed that he could do excellent work and make a difference in the lives of so
4
Gary apologizes to Tom writing, I am sorry that you are feeling like we did something wrong with the AG and
that he (Tom) has a great sense of right and wrong so I dont want you to feel to [sic] badly, or guilty about
anything.
63
many people. It was not about the money. (Ex. 3). Toms mother knows in her heart
that he had no intent of malice or harm. (Ex. 4). She heartbreakingly recalls how joining
the Supes Entities was the highlight of Toms life and that he was not interested in
personal gain, greed, or materialistic desires, but rather, he was excited to be in the
field and was passionate about helping to make a difference in peoples lives. Despite
admitting that he may never truly understand why Tom went along with the scheme,
Toms father is also certain that Tom did not participate in this scheme out of malice or
greed. (Ex. 5).
Tom knew at the time that their conduct was wrong and that he could not rely on
Garys reassurance that everything would be okay. (Def. Version at 7). Looking back
now, Tom admits that he stayed because he did not have the strength to confront Gary
or to risk losing everything that he had worked so hard for and leave the company. At
the time, Tom believed that if he worked hard and delivered to CPS what was expected
of me, it would be okay. Id. Tom took some comfort in knowing that the contracts were
not a sham and that he had worked hard and made tremendous personal sacrifices to
deliver the promised services to CPS. See (Sent. Tr. at 79-80) (considering in mitigation
that the program was not a sham and that the evidence overall showed that CPS got
value).
Tom understands that none of these excuses his unlawful conduct and he takes
full responsibility for his actions. He pled guilty and admitted that he participated in the
scheme, the cover up, and personally benefitting from the illegally obtained contracts.
Still, the above unique facts mitigate the nature and circumstances of Toms conduct
64
and distinguish him from his codefendants and the typical bribery defendant. As such,
they should be considered by the Court under 18 U.S.C. 3553(a)(1) in imposing a
sentence and they support, along with Toms long history of charitable giving and
excellent character, a sentence of probation in this case. Warner, 792 F.3d at 859; United
States v. Vrdolyak, 593 F.3d 676, 685 (2010) (Hamilton, J., dissenting) (recognizing that
defendants intent not to harm the victim is not inconsistent with defendants guilt and
that defendants intent can be taken into consideration under 3553(a));United States v.
Milne, 384 F. Supp. 2d 1309, 1310-11 (E.D. Wis. 2005) (sentencing defendant below the
advisory guidelines range where defendant did not take the banks money out of greed
or a desire to live a lavish lifestyle, but to keep his sinking business afloat.); United States
v. Ranum, 353 F. Supp. 2d 984, 990 (E.D. Wis. 2005) (Court considered it mitigating that
bank fraud defendant was not motivated solely by personal financial gain); United States
v. Forchette, 220 F. Supp 2d 914, 925 (E.D. Wis. 2002) (a defendants intent in involving
himself in the scheme that is different from the typical intent of a fraud defendant may
be considered).
4. Specific Deterrence Is Not an Issue in This Case
Toms truthful cooperation, acceptance of responsibility, willingness to plead
guilty, lack of a prior criminal history, education, family history, and lack of history of
drug or alcohol abuse demonstrates that there is no need for specific deterrence. Toms
character letters conclusively demonstrate that his remorse is genuine and that he is
unlikely to commit future misconduct or be a danger to the public. The probation officer
agrees, noting that the imposition of a sentence of imprisonment is unnecessary to
65
promote specific deterrence. (Sentencing Rec. at 3). Likewise, the collateral
consequences of this conviction will punish Tom far more seriously, and for a much
longer time, than any sentence of incarceration. No amount of punishment will equal the
shame, guilt, and sadness that Tom feels about his failure to leave the company when he
learned about the corrupt agreement between Gary and Barbara.
5. General Deterrence
Under 18 U.S.C 3553(a)(2)(B), the Court must also consider general deterrence.
We are mindful that general deterrence is an especially significant factor in white collar
criminal cases, but it is not the only factor that the Court must consider. United States v.
Molton, 743 F.3d 479, 486 (7th Cir. 2014) (recognizing that sentencing judges should
consider general deterrence but must also hand down an individualized sentence.)
(Quoting Gall, 522 U.S. at 50); see also United States v. Brubaker, 663 F.2d 764,769 (7th Cir.
1981) (Consideration of general deterrence is proper provided it does not result in a
mechanistic imposition of a sentence.). Moreover, while the effective deterrence of
crimes may generally require a credible threat of imprisonment, that objective does
not necessitate imprisonment in every case. Warner, 792 F.3d at 861.
Here, a sentence of incarceration is not necessary to send individuals like Tom
who is not a public official, who was not the originator or driver of the offense, and who
was not motivated by greed a message to dissuade them from participating in the same
kind of conduct. Toms very public journey through the criminal justice system serves as
a cautionary tale to individuals like Tom that if confronted with the same situation in
their employment, they should leave. There is also no doubt that similarly situated
66
individuals will likely be deterred from engaging in illegal conduct by the negative
business, financial, personal, emotional, and family consequences that Tom brought upon
himself. Id. at 860-61. Likewise, the lifelong collateral consequences Tom will suffer as a
convicted felon, including restrictions on travel, banking, employment, voting, housing
and benefits, also serve as an effective warning to prospective defendants. United States
v. Wachowiak, 496 F.3d 744, 747 (7th Cir. 2007) (substantial deviation from guidelines
appropriate in child pornography case given the collateral consequences suffered by the
defendant, including the loss of his career as a music teacher and his forced resignation
from numerous other jobs). See also United States v. Nesbeth, No. 15-CR-18 (E.D.N.Y. May
25, 2016) (drug defendant sentenced to probation despite guideline range of 33-41
months incarceration based in part on the nearly 50,000 federal and state statutes
regulations that impose penalties, disabilities, or disadvantages on convicted felon).
Finally, the extensive media coverage and Toms candid discussions with others in the
education field, have communicated to the public the certainty of being caught if you
engage in this kind of fraud.
In Gall, the Supreme Court observed that probation, rather than an act of leniency,
is a substantial restriction of freedom. 128 S.Ct. at 593; see also Warner, 792 F.3d 860, citing
Gall, 128 S.Ct. at 593 (same, and affirming two-year term of probation with community
service as a sufficiently serious sentence to promote general deterrence); United States
v. Kappes, 782 F.3d 828, 836 (7th Cir. 2015) (well-tailored supervised release conditions
serve the purposes of deterrence, rehabilitation and protection of the public). Thus, a
sentence of three years probation for Tom, with a lengthy period of home confinement
67
and rigorous community service (discussed below), would more than adequately punish
Tom, reflect the seriousness of his offense, and promote general deterrence. It would also
better serve the public good than a prison term by allowing Tom to continue the
charitable service to which he has dedicated his life. Warner, 792 F.3d 854 (quoting the
district courts finding that society will be better served by allowing [the defendant] to
continue his good works outside of prison).
6. Despite Jail Sentences for Toms Codefendants, Probation is an Appropriate

Sentence for Tom and Would Avoid Unwarranted Sentencing Disparities
with Similarly Situated Defendants
Under 18 U.S.C. 3556(a)(6), district courts must seek to avoid unwarranted
sentencing disparities among defendants with similar records who have been found
guilty of similar conduct. On the flipside, warranted disparities are permitted. United
States v. Pape, 601 F.3d at 743, 750 (7th Cir. 2010). The advisory sentencing regime
mandates that the Court judge each defendant on an individual basis and that such
differences can justify a sentencing disparity. United States v. Turner, 604 F.3d 381, 389
(7th Cir. 2010). The unique personal characteristics and the facts surrounding Toms
offense conduct (discussed above) distinguish Tom from his codefendants and support a
sentence of non-incarceration for Tom.
*** Codefendants ***
The parties agree that while Tom eventually participated in the offense, he was the
least culpable of the three. (Sent. Tr. at 87). Additionally, Toms moral blameworthiness
is distinguishable from that of his codefendants in that Tom did not set out to commit a
crime, Tom was not involved in the corrupt scheme from the beginning (Sent. Tr. at
68
39), Tom did not concoct or come up with the idea for the scheme, (Sent Rec. at 4), and
Tom did not act solely out of greed.
In contrast, Barbara, the public official, and Gary came up with the agreement and
ultimately corrupted Tom Vranas in the process. (Sent. Tr. at 39). Even though there
is no question that Tom willingly participated in the scheme, at the time, Tom felt guilty
about his conduct and understood the gravity of it. Id. at 34. In contrast, Gary felt no
remorse and was casual about committing the crime, telling Tom not to feel guilty
because the scheme was just business as usual. Id.
Toms appreciation for the seriousness of the offense is underscored by his
complete and truthful cooperation. Tom is the only one of the three that came
completely clean with the Government from the beginning of his cooperation. (Sent. Tr.
at 84). Barbara lied to FBI agents when they first approached her in April 2015 and
she also lied and minimized her conduct in her initial proffer with the government.
(Dkt. 91 at 16). Likewise, Gary chose to misrepresent and minimize his own conduct
during his proffers; and he misled the government regarding criminal activity
purportedly committed by others. Id. And, even at sentencing, Gary persisted,
disput[ing] the scope of the scheme and the significance of his role. Id.
In contrast, Tom told the truth from the beginning, never minimized his conduct,
and implicated himself and his codefendants in the full scope of the crime, including the
$20.5 million contract and the obstruction, which no doubt assisted the Government at
69
Garys sentencing.5 Id. (In his proffers, Vranas readily acknowledged his criminal
conduct and truthfully related information regarding Solomon and Byrd-Bennett.)
*** Similarly Situated Defendants ***
We are mindful of the Courts admonition at Garys sentencing that sentencing
by anecdote is dangerous and incomplete. (Sent Tr. at 82). Still, the cases below may
prove instructive in determining a reasonable sentence for Tom. In these cases, the
defendant (s), like Tom, was the least culpable of the codefendants, was not the originator
or mastermind of the offense and was dragged in by a more culpable codefendant. As
such, despite lengthy sentences for the public-officials and/or originators of the scheme,
the Courts imposed sentences of minimal or no jail time.
For example, in United States v. Bills et al., 14 CR 135 (N.D. Ill.), the Court sentenced
Martin OMalley (an employee of the Vendor/bribe payor) to six months in jail, which
was about a 90% deviation from the guidelines, despite a guideline range of 60 months
(the same as Tom) and a 120 months in jail for the public official involved (John Bills).
Like Tom, OMalley (a cooperator) willingly participated in the bribe schemes, but joined
the scheme only after being solicited by others and not necessarily out of greed.
Similarly, in U.S. v. Gloria Harper, No. 11 CR 479 (N.D. Ill.), a bribery case in the
education field involving a decade of fraud, $21 million in vendor contracts and over
$800,000 in kickbacks, the Court sentenced the cooperator vendor defendants to sentences
5
Despite creating the false termination letter and deleting emails in response to the IG
investigation, Gary objected to the obstruction enhancement in his plea agreement.
Gary wisely withdrew his objection at sentencing. (Sent. Tr. at 29).
70
well below the advisory guideline ranges and that of the public officials involved. In
contrast to the 70-month sentence handed to Gloria Harper, the President of the North
Chicago School, the Court imposed a sentence of one day, time considered served, and
six months weekend service in the Bureau of Prisons, for Barret White, a vendor who
faced a guideline range of 188-235 months in prison and a Government recommendation
of 60 months in jail. Another vendor, Tommie Boddie, whose guideline range was 168-
210 months jail time, received a sentence of one day, time considered served, followed
by supervised release with a period of nine months home confinement. Likewise, the
Court sentenced vendor/codefendant Derrick Eubanks, who was apparently one of the
least culpable of the codefendants, to nine months in jail, despite a guideline range of
168-210 months and a Government recommendation of 71 months incarceration.
In United States v. Oropesa, No. 16-CR-71 (N.D. Ga. 2016), the Court sentenced the
defendant, a former executive for the company that runs Chicago parking meters, to six
months home confinement, despite a guideline range of 15-20 months. The defendant
pled guilty to taking $90,000 in bribes in exchange for steering a $20 million contract to
install the privately-owned meters to a company based in Tampa, Florida. Oropesas
conduct was more egregious and widespread than Toms in that he took $90,000 in bribes,
set up a fake company to hide the kickbacks, and recruited others into the offense.
The above cases demonstrate that a sentence far less than the advisory guideline
range, including probation, can reflect the seriousness of Toms offense, promote general
deterrence and provide just punishment.
71
V. CONDITIONS OF PROBATION/SUPERVISED RELEASE
A. Mandatory
Given that these conditions are mandated by statute, Tom does not object to the
conditions recommended by the probation officer. Regarding condition 6, defense
counsel asks for the same modification to the language proposed at Garys sentencing
because Tom does not have a substance abuse problem. (Sent. Tr. at 66).
B. Discretionary
Tom does not generally object to conditions 2, 4, 7, 8, 14, 16, 17, and 18, as
numbered in the PSR (Pages 32-35), but asks that the Court make the same modifications
it did at Garys sentencing. Tom objects to condition 6, because it is unnecessary and
there is no need for specific deterrence. Tom also objects to condition 9, requiring him to
participate in a mental health treatment program since Tom has no history of mental
health issues other than the anxiety and depression associated with this case, (PSR 114).
As such, this condition is not reasonably related to the factors set forth in 18 U.S.C.
3553(a).
C. Special Conditions
Tom does not object to conditions 3, 5, 6, 7, 10, and 11, but again requests the same
modifications to these conditions that were made by the Court at Garys sentencing.
Likewise, condition 8, is unnecessary since this is not a tax case and it is not necessary for
supervision purposes. (Sent. Tr. at 70).
72
VI. CONCLUSION
By all accounts, Tom is a kind, charitable, and caring person who leads an
exemplary life and is an asset to the community. He takes full responsibility for his
conduct and feels terribly sorry that his actions directly contributed to a serious abuse of
the public trust. He will never be before this Court again. He hopes for a sentence that
will allow him to continue his work with The ARK of St. Sabina and to begin restarting
his life. We ask the Court to balance Toms extraordinary cooperation, acceptance of
responsibility, excellent character, the unique nature and circumstances of his offense,
and the collateral consequences suffered by Tom and his family, against his conduct in
this case and sentence him to three years probation with a lengthy period of home
confinement and substantial community service. This sentence is sufficient but not
greater than necessary to achieve the sentencing goals, will serve the administration of
justice, and contribute to the public good.
Respectfully submitted,
Tom Vranas
By: /s/Jacqueline S. Jacobson

One of his attorneys
Dated: April 6, 2017
Michael D. Monico
Jacqueline S. Jacobson
Carly A. Chocron
Monico & Spevack
20 South Clark Street, Suite 700
Chicago, Illinois 60603
312-782-8500
73

Thomas Vranas' Request For Probation

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Case: 1:15-cr-00620 Document #: 111 Filed: 04/06/17 Page 1 of 73 PageID #:2568

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA, )

TOM VRANAS SENTENCING SUBMISSION AND REQUEST FOR A SENTENCE

requesting a sentence of 39 months imprisonment. The U.S. Probation Officer

recommends less - 24 months imprisonment. We believe a sentence of three years

and other volunteer organizations.

participated in the conduct. He is deeply ashamed of himself. He also is profoundly

Government in its investigation.

with the ARK. (Ex. 1). We hope for the same.

II. TOMS PERSONAL BACKGROUND AND CHARACTER

Tom submitted a statement concerning the offense that includes a detailed

A. Personal History, Education and Career

the treatments and start a family soon.

family, education, and religion.

Toms grandparents had a tremendous influence on him. He grew up listening

Public School teacher and then in administration, concentrating on physically and

In 1999, Tom went to Northwestern University, where he studied economics and

elementary school students. He also participated in many volunteer projects throughout

Chicago with the Northwestern Community Development Corps (NCDC) and

locally and globally, through concerts and other performances.

time, which allowed Tom to participate in volunteer work, including environmental

and faith based projects.

B. Gary Solomon and the Supes Entities

family, were active in the Greek Orthodox Church and community.

eventually offering Tom a full-time position to help grow a federally-funded program

school tutoring programs.

Tom to relocate to their corporate headquarters in Massachusetts, he decided to leave

Chicago and hopefully start a family of their own.

ownership in PROACT. Tom jumped at the chance, joining as President in November

SUPES Academy, a company that specialized in leadership and professional

from leaving. Id.

C. Barbara Byrd Bennett

as a part-time consultant. After which, Gary introduced Tom to Barbara at a meeting at

the Supes Entities.

of their senior administrative leaders (Chicago Executive Leadership Academy or CELA),

participants reported being enthralled by Barbaras abilities, skills and experience.

D. The Offense Conduct

Barbara) kept this corrupt arrangement a secret. (Governments Consolidated Sentencing

the Supes Entities to CPS.

which eventually reached a maximum amount of $360,000 to $380,000. As Tom

participated in the scheme. (Def. Version at 7).

Toms decision to participate in the scheme hatched by Gary and Barbara is a

and walk away if confronted with a similar situation.

member of society and making the world a better place. Id. at 9.

III. Toms Letters - A Lifetime of Compassion, Generosity, Integrity and Hard

attached the rest of the letters received as Group Exhibits A-E.

to Toms considerate, kind, compassionate, honest, and giving personality. During

obligations on hold, and missed events.

difference in the world.

system. Likewise, Tom exhibited extraordinary dedication and selflessness at a young

In high school, Tom was a well-rounded student, who excelled academically

comfortable leaving Tom in charge while he honeymooned for three weeks.

from a difficult knee replacement surgery.

to be of value to society again.

witnessed his sons early involvement in numerous charitable organizations, he knew

focused on educational excellence and the development of school leadership. Given

and helpful person like [Tom] by his side.

account in passing sentence on [his] younger brother.

trust in government. As a former prosecutor, Peter understand[s] that Tom faces

Toms mother-in-law, Anastasia Coorlas, also believes that Tom is an

extraordinary young man. (Ex. 8). Anastasia describes Tom as compassionate,

productive, committed to charity and continued to be a wonderful, caring, and loving