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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 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

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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 youthfrom 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

ARK’s 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 Tom’s absence from the ARK

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“would leave a huge void” in the program. It is Ms. Jonesmost 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. TOM’S 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 Tom’s 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 Tom’s rare fertility

disorder, they have no children. (PSR ¶111). With this case and the uncertainty of Tom’s

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. Tom’s

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.

Tom’s 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, Tom’s

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.

Tom’s 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. Tom’s 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.

school boards.

John also served as the leader on two suburban

Annette and John’s 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

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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

Northwestern’s 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 church’s 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 Gary’s in-laws, who like Tom’s

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 didn’t 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 Gary’s lead, you risked being on Gary’s 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 Tom’s 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 Gary’s cars, pay back Gary’s 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 Detroit’s 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 Barbara’s 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 Barbara’s 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 Barbara’s 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 Barbara’s 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 Barbara’s efforts to improve

operations and establish contracts with other schools.

Tom was comforted by his

understanding from Gary that Barbara’s 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

George’s County. It was Tom’s 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 Barbara’s 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 Tom’s 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. (Government’s Consolidated Sentencing

Memorandum, Dkt. #91 at 18).

However, based on Tom’s 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

Tom’s 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 CPS’s 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.

Tom’s 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 Tom’s charitable activities from 1993 to the

present). In addition to his family members, those that have witnessed Tom’s lifetime of

giving and personally benefitted from Tom’s generosity, have written letters to the Court.

Given the large volume of letters received on Tom’s behalf, we have organized the letters

into groups, recognizing that many of the letters sound common themes. For the Court’s

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 Tom’s “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, Tom’s volunteer work with Open Heart Magic, an organization that provides

magic shows to hospitalized children, best reflects Tom’s “charitable spirit and innate

desire to help others.”

Allison marveled at Tom’s 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 Tom’s 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 “Tom’s 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 Tom’s genuine desire to

“blend entrepreneurship and charity.” Tom “really believed in his work” and he put his

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“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 Tom’s 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 Allison’s

subsequent miscarriages, Tom’s rare fertility issues, Tom’s 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 Allison’s 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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Tom’s 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, Tom’s 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 Tom’s 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 mom’s 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 worker’s

permit and worked in a local fast food restaurant, riding his bike to work because he was

18

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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 Annette’s 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 Annette’s 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.”

19

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 Tom’s

“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 children’s

lives.”

Joining the Supes Entities “began as the highlight of [Tom’s] 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 [Annette’s] 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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Tom’s 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 son’s early involvement in numerous charitable organizations, he knew

that “Tom’s 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

Tom’s “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 Tom’s

conduct “was very out of character and that Tom did not participate in the scheme out of

malice or greed.”

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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, Tom’s 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 son’s 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.”

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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 Tom’s genuine remorse and excellent character into

account in “passing sentence on [his] younger brother.”

Peter Coorlas, Tom’s 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 public’s 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

Tom’s conduct “is atypical of his character and an aberrant event in his otherwise

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extraordinary life.” This, coupled with Tom’s “exceptional talents” and his potential to

“benefit society in the future” leads Peter to request leniency from the Court.

Tom’s

extraordinary

mother-in-law,

young

man.”

Anastasia

Coorlas,

also

believes

(Ex.

8).

Anastasia

describes

Tom

that

Tom

“is

an

as

“compassionate,

sympathetic, and extremely sensitive to others’ feelings.” When Anastasia’s mother died

unexpectedly, Tom helped her immeasurably.

Anastasia was “so distraught” that she

could not “bear” to go to her mother’s 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 “Tom’s compassion,

love and sensitivity” that “helped keep [Allison] from going to a very dark place.

Despite this case, “Tom has remained Allison’s rock and bright shining light” in their

family. Anastasia is “so grateful that this dark and frightening time in Tom’s life has not

hindered his kind soul or loving spirit.” While this highly public case has “caused a huge

set back in [Tom’s] 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.”

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Allison’s 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

community.”

of

contributing

to

the

progress

of

individuals,

families,

and

our

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 Peter’s junior year in college, Tom offered him an

internship at PROACT. As an intern, Peter writes, “I had an unfiltered view of Tom’s

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 Tom’s contributions to society.”

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Similarly, Rebecca Petropoulos, Tom’s 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 Tom’s drive and

work ethic, Rebecca hoped that her children would have his “sense of empathy for

others.” In her letter, Rebecca details Tom’s long history of “fighting for a good cause or

the underdog.” She also recalls Tom’s kindness and generosity which directly impacted

her.

When Rebecca’s father (Tom’s 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 (Tom’s mother). He rearranged social events,

without hesitation or complaint, to help Rebecca drive her uncle to dialysis and her

mother (Tom’s grandmother) to chemotherapy. “Most importantly,” Rebecca writes,

Tom kept his frail grandmother’s 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 Rebecca’s

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 Tom’s life-long character traits of selflessness

and compassion.” And, despite this case, “Tom’s 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.”

26

Rebecca hopes that Tom gets this

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“sacred opportunity” and she knows if he does he will continue to serve his family and

the community.

Rebecca’s daughter, Stefanie Petropoulos, confirms that Tom’s 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 Tom’s

influence.” Ten years younger than Tom, but extremely close to him, Stefanie grew up

observing Tom’s “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, Tom’s 19-year-old cousin, Arianna Vranas, tells the Court that Tom

“played a critical role” in her life. (Ex. 13).

Tom became Arianna’s 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 Tom’s “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

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more.”

This case has not changed Arianna’s positive image of Tom.

In fact, Tom’s

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 Tom’s 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 Tom’s compassion and understanding … made an

impact on her life.”

Tom’s generosity towards Elena, and his selfless enthusiasm and

commitment to community service, “leads [her] to conclude that Tom’s 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 Tom’s life-long commitment to religion, family, and

charity, she too is “surprised” by this case and believes that Tom’s conduct is

“uncharacteristic of who Tom is.”

She personally experienced Tom’s “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,

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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 O’Malley,

(Ex. 17), write separately to the Court about events they believe demonstrate Tom’s

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 Tom’s kindness

to her after her mother died just before Easter. Sandy’s 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, Tom’s caring nature was

revealed during a pool party at their house that could have ended in tragedy, if not for

Tom’s “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 Dan’s son, Joseph O’Malley (Allison’s 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 “Tom’s unselfish and

caring nature.” Joseph will “never forget” how Tom made Joe’s 84-year-old grandmother

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so happy when he included her in a surprise birthday celebration for Allison. When Joe’s

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 Tom’s

unselfish and caring attitude towards others.”

These

same

attributes

lead

Tom’s

cousin,

attorney

Georgia

Kyriacou,

to

confidently conclude, like many of his other family members, that Tom’s 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.”

Tom’s 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 Tom’s 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

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generosity with his time and resources and a deep compassion for others.” Lynda’s faith

in Tom’s future is further strengthened by Tom’s 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 grandparent’s highest dreams and aspirations” -

“Intelligent, honest, and hard-working.Michael remembers how shortly before Tom

was getting ready to look at colleges, Tom’s father suffered some financial set-backs that

could have impacted Tom’s choices. As Michael notes, Tom “didn’t 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, Tom’s lack of entitlement and strong worth ethic, in

addition

to

his

extraordinary

generosity

and

community

involvement,

confirms

Michael’s belief that Tom’s 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.

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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

Tom’s “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 Tom’s 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

Tom’s 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 “Tom’s involvement in this case

and the media attention it has drawn will overshadow all of his hard work and passion”

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for education reform. He hopes that the Court will recognize Tom’s 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).

Tom’s “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 Tom’s future abilities

that he “personally vouched” for him to a client of his for a prospective job with the

client’s company.

After hiring Tom, the client “raved about how helpful, honest, and

positive Tom’s impact has been on his company.” Like Joshua’s 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 Tom’s extracurricular

volunteer work with Habitat for Humanity and the church.

After college, Benjamin

observed Tom’s 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 grandmother’s house and that “helping the community tend to the

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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 Tom’s 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

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Tom noticed Brendan’s 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 Tom’s 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 person’s 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 Tom’s 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.

35

John could tell just by

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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 Tom’s commitments and achievements.

But he also learned more

about the core of Tom’s 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 can’t 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 Tom’s 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 I’d like to have at my side

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when bullets start flying. (Ex. 29). John has known Tom for 14 years. They met in 2003

through John’s 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 Tom’s 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 nation’s urban schools, better.”

That is why John was shocked and

deeply saddened when he learned about Tom’s 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 John’s trust and John “would endorse him for the most sensitive of

positions,” including, if necessary, the care of John’s 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.”

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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 Tom’s “punishment will reflect the genuine, honest, and authentic

man that truly is and has always been.”

Even Tom’s primary care physician, Dr. John Revis, has written a letter to the

Court on Tom’s 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, Tom’s 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

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our church’s 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 Tom’s 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 Tom’s 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.

3.

Additional letters from friends are collected at Group Exhibit B.

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 Tom’s 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 Tom’s 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.

39

Dr. Cade recalled

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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. Cade’s “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 Tom’s 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

[Tom’s] 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 Tom’s commitment, Dr. Taylor is certain that “one of

[Tom’s] biggest regrets is comprising the ability to serve the students of urban school

districts.” That is why it is Dr. Taylor’s “sincerest hope that his road to redemption allows

for his talents and skills to be used to continue his service to those students.”

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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 Tom’s 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

Tom’s “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

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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 Tom’s 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

Tom’s

“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 Tom’s character. Of his

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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, Tom’s 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 Tom’s 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.”

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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 Tom’s honesty” when he personally apologized to Jenai for his conduct.

She hopes that the Court will balance Tom’s 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

Julio’s mother got sick and Julio fell behind. Notably, at the time, Julio didn’t even know

Tom that well, revealing to Julio that Tom has “a good heart.” Despite this case, Julio is

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“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 Tom’s 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 Tom’s 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 Tom’s “conduct in this case

is not representative of the person that [he] knows.”

He hopes that Tom’s “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 Tom’s character because they met during the “worst time in

[Tom’s] life.” For Victor, a man’s 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.

45

He was also “honest and

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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 Tom’s work ethic, skill set, and “thoughtful” nature, he “quickly became

a helpful confident” and close friend.

When Victor’s 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.”

Group Exhibit C.

4.

Interns

Additional letters from colleagues are collected at

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 Tom’s 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

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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.”

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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 Tom’s 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

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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 Tom’s “honesty, love for

our faith, sincerity, and motivation,” Reverend Kerhulas enlisted Tom’s 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, “Tom’s 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 Tom’s 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

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“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 “servant’s

heart.” She remembers meeting Tom when she was a freshman in high school. Tom, in

his 20’s, 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’

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experience and relationships with their faith,” which only strengthened Anna’s 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 Brad’s 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 Brad’s “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, Tom’s service to the church is “reflective of

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his core character traits” – giving, caring, and a “person of action.” When Tom and John

discussed this case, John was impressed by Tom’s “level of self-awareness.” Tom was

clearly “heartbroken over his actions” and “made no excuses” for his conduct.

Tom’s

“high level of contrition and remorsefulness” gives him “great hope” for Tom’s 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 Tom’s repentance,

which Father Boznos has “witnessed and am witnessing.” (Ex. 56). For Father Boznos,

Tom’s “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 Tom’s 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, Tom’s compassion, kindness, and generosity, has been

ongoing throughout his entire life in fact, dating back to Tom’s 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

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day) since January 2016 at Habitat for Humanity, Harvest Food Pantry, and the ARK of

St. Sabina on Chicago’s 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 ARK’s

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 ARK’s] 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 Tom’s unique and “impressive

administrative skill-set.She shared with Tom the ARK’s 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

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“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 “agency’s 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 Tom’s 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 Tom’s work” as a component to

his sentence. It is her greatest hope that Tom “will have the opportunity to continue using

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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 Tom’s 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 Tom’s 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

public’s 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 Tom’s 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).

Tom’s 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 Government’s

position

that

Tom

was

“immediately

more

truthful

and

forthcoming

than

his

codefendants.” (Sent. Rec. at 3). Tom met with the Government on three separate

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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. Tom’s 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 Tom’s advisory

guideline range of 108-135 months, is based on a total offense level of 31 and zero criminal

history points). 3 Tom’s 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.

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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 Tom’s 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

statute’s

parsimony

provisionthe

instruction to “impose a sentence

sufficient, but not greater than necessary,” to

accomplish the purposes of sentencing—as its “overarching” command.

Kimbrough v.

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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. Tom’s Personal History and Characteristics Support a Sentence of Probation

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Section 18 U.S.C. 3553(a) directs the sentencing court to consider a defendant’s

“history and characteristics.Warner, 792 F.3d at 857. The outpouring of letters provided

on Tom’s behalf present a true and accurate portrayal of the man beyond the criminal

conduct that brought him before this Court. The letters reveal that Tom’s 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 (defendant’s character

letters were “sincere and credible” evidence of defendant’s 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

Tom’s 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, Tom’s letters also confirm

that Tom’s dedication to charity and good work goes back many years - to high school,

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in fact and goes beyond simply donating money, but involves true sacrifice and time

commitment, making it credible and persuasive evidence of Tom’s character which the

Court can rely upon to justify a sentence of probation. Warner, 792 F.3d at 857

(defendant’s 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, Tom’s

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