Unopposed Motion to Continue Plea Hearing by Donna J. Clark — USA v. Clark (Dkt. 19, E.D. Tenn.)

Summary

Document 19, a one-page Unopposed Motion to Continue Plea Hearing filed 01/04/22 in the Eastern District of Tennessee at Chattanooga, No. 1:21-Cr-069-CAE-CHS, United States v. Donna J. Clark, by Assistant Federal Defender Gianna Maio. It says her change of plea hearing was set for January 5 by an order of December 22 (Doc. No. 17), but a work-related obligation requires counsel to be in Knoxville that day. Clark agrees to the request, and counsel proposes January 19, 26 or another convenient date. Assistant U.S. Attorney Steve Neff does not oppose and is available on January 19 and 26.

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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 PLEA HEARING 
 
 
Defendant Donna Clark, through undersigned counsel, respectfully requests that this 
Honorable Court continue her change of plea hearing. On December 22, this Court issued an 
Order setting Ms. Clark’s change of plea hearing for January 5 after conferring with both parties.  
(Doc. No. 17) Since then, a work-related obligation arose that requires undersigned counsel to be 
in Knoxville on January 5. The obligation cannot be rescheduled. Ms. Clark is aware of 
counsel’s obligation in Knoxville and is in agreement with the request to reschedule the hearing. 
Undersigned counsel respectfully requests that Ms. Clark’s change of plea hearing be 
rescheduled for January 19, 26 or another date that is convenient for the Court’s schedule. 
Undersigned conferred with Assistant United States Attorney Steve Neff, who does not oppose 
this request. In addition, Mr. Neff is available on January 19 and 26. 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
FEDERAL DEFENDER SERVICES 
 
 
 
 
 
 
 OF EASTERN TENNESSEE, INC. 
 
 
 
 
 
 
 
By:   /s/ Gianna Maio           
 
 
 
 
 
 
Gianna Maio 
 
 
 
 
 
 
Assistant Federal Defender                          
 
 
 
 
 
 
835 Georgia Avenue, Suite 600 
 
 
 
 
 
 
Chattanooga, Tennessee 37402 
 
 
 
 
 
 
Gianna_Maio@fd.org 
 
 
 
 
 
 
(423) 756-4349 
 
 
 
 
 
 
TN BPR # 24579 
Case 1:21-cr-00069-CEA-CHS     Document 19     Filed 01/04/22     Page 1 of 1     PageID
#: 85

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