Unopposed Motion to Continue Deadlines and Trial Date by Donna J. Clark — USA v. Clark (Dkt. 13, E.D. Tenn.)

Record facts

U.S. District Court for the Eastern District of Tennessee · No. 1:21-cr-00069-CEA-CHS · Doc. 13 · 2021-09-13 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF TENNESSEE 
At Chattanooga 
 
UNITED STATES OF AMERICA, 
 
          Plaintiff, 
 
 
 
 
 
 
 
No. 1:21-Cr-069-CAE-CHS 
v. 
 
 
 
 
 
 
 
 
DONNA J. CLARK, 
 
          Defendant. 
 
UNOPPOSED MOTION TO CONTINUE SCHEDULED DATES 
 
 
Defendant Donna J. Clark, through undersigned counsel, respectfully requests that this 
Honorable Court allow an additional 30 days on the dates currently scheduled in this case. The 
pretrial motion and plea deadlines are September 14 and trial is scheduled for October 5, 2021. 
(Doc. No. 6) 
 
A federal grand jury indicted Ms. Clark on charges of fraud, money laundering, and 
unlicensed money transmittal. (Doc. No. 1) On August 31, undersigned counsel received 500 
pages of supplemental discovery, along with many discs containing recorded conversations. 
While undersigned counsel has reviewed much of the original discovery with Ms. Clark, the 
supplemental discovery will take a significant amount of additional time to review and 
summarize. Therefore, Ms. Clark requests more time to complete her discovery review in order 
to enable her to make a fully informed decision as to whether to proceed to trial. This request is 
not made for the purpose of undue delay, but to provide effective assistance of counsel to Ms. 
Clark. Assistant United States Attorney Steve Neff is aware of, and does not oppose, Ms. Clark’s 
request. 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
FEDERAL DEFENDER SERVICES 
 
 
 
 
 
 
 OF EASTERN TENNESSEE, INC. 
 
 
 
 
 
 
 
By:   /s/ Gianna Maio           
Case 1:21-cr-00069-CEA-CHS     Document 13     Filed 09/13/21     Page 1 of 2     PageID
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Gianna Maio 
 
 
 
 
 
 
Assistant Federal Defender                          
 
 
 
 
 
 
835 Georgia Avenue, Suite 600 
 
 
 
 
 
 
Chattanooga, Tennessee 37402 
 
 
 
 
 
 
Gianna_Maio@fd.org 
 
 
 
 
 
 
(423) 756-4349 
 
 
 
 
 
 
BPR # 24579 
Case 1:21-cr-00069-CEA-CHS     Document 13     Filed 09/13/21     Page 2 of 2     PageID
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