Dear Judge Briccetti:

The Government writes to oppose defendant Hamid Reza Hashemi’s April 1, 2016 request for early termination of supervised release (the “Early Termination Request”). The Early Termination Request is principally premised on Hashemi’s desire to return home to Iran. Because the defendant has not satisfied the requirements of 18 U.S.C. § 3583(e)(1), which requires the completion of one year of supervised release before the term may be modified, and for the other reasons stated below, the Government opposes the defendant’s request.

Background

As the Court knows, in July 2013, the defendant pled guilty to an Indictment charging him with violating IEEPA by causing carbon fiber to be exported to Iran without the appropriate license and attempting to procure a carbon fiber winding machine from the United States. The defendant pled guilty to his role in a scheme to illegally export high-grade carbon fiber without a license, which was transshipped through Europe, and into Iran, as well as his attempt to procure a winding machine from the United States.2 In November 2013, the defendant was sentenced to 46 months’ imprisonment, to be followed by one year of supervised release.

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