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Home Court filings United States v. Donna J. Clark Addendum to Amended Plea Agreement — U.S. v. Clark (E.D. Tenn.)

Court filing

Addendum to Amended Plea Agreement — U.S. v. Clark (E.D. Tenn.)

One of 10 filings in U.S. v. Donna Clark.

Record facts

CourtU.S. District Court, Eastern District of Tennessee

U.S. District Court, Eastern District of Tennessee · No. 1:21-cr-00069-CEA-CHS · Doc. 35 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
 
EASTERN DISTRICT OF TENNESSEE 
 
At Chattanooga 
 
UNITED STATES OF AMERICA, 
 
          Plaintiff, 
 
 
 
 
 
 
 
No. 1:21-cr-069 
 
 
 
 
 
 
 
Judge Atchley 
v. 
 
 
 
 
 
 
 
 
DONNA J. CLARK, 
 
          Defendant. 
 
 
ADDENDUM TO AMENDED PLEA AGREEMENT 
 
The defendant, Donna Clark, the defendant’s attorney, Gianna Maio, and the United States 
Attorney for the Eastern District of Tennessee have agreed to the following terms set forth below, 
which are intended to replace paragraph 6 of the Amended Plea Agreement, filed December 22, 
2021. (Doc. No. 18)   
An arrest warrant was issued on August 6, 2021, and Ms. Clark turned herself in on August 
9, 2021. (Doc. No. 12) Ms. Clark was detained in the courthouse prior to her initial appearance 
before Magistrate Judge Steger. Judge Steger released Ms. Clark on a $30,000 appearance bond. 
(Doc. Nos. 8, 9, 11) Thus, she has a day of incarceration to her credit. 
On January 19, Ms. Clark entered a plea of guilty to one count of wire fraud in violation 
of 18 U.S.C. §1343. (Doc. No. 21) Ms. Clark entered a guilty plea pursuant to an Amended Plea 
Agreement. (Doc. No. 18). In that plea agreement, the parties agreed upon a sentence of three years 
of probation pursuant to Federal Rule of Criminal Procedure Rule 11(c)(1)(C). (Doc. No. 18, ¶ 6) 
The statutory maximum sentence for wire fraud which impacts a financial institution is 30 
years, which makes it a Class B felony. 18 U.S.C. §1343, 18 U.S.C. §3559. Ms. Clark’s offense 
impacted a financial institution. 18 U.S.C. §3561(a)(1) bars a sentence of probation for individuals 
Case 1:21-cr-00069-CEA-CHS     Document 35     Filed 06/01/22     Page 1 of 2     PageID
#: 244

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convicted of Class A or B felonies. Despite the statutory prohibition, numerous courts have 
authorized sentences of one day time served, followed by a period of supervised release, for 
defendants convicted of Class A and B felonies. See U.S. v. Musgrave, 647 Fed.Appx. 529 (6th 
Cir. 2016)(sentence of one day of imprisonment and five years of supervised release with 24 
months of home confinement upheld for defendant convicted of wire fraud, bank fraud, and 
conspiracy to commit wire and bank fraud and to make false statements to a financial institution); 
U.S. v. Jaradat, 512 Fed.Appx. 612 (7th Cir. 2013)(defendant convicted of wire and mail fraud 
sentenced to one day of imprisonment followed by three years of supervised release, with 12 
months served on home confinement), U.S. v. Pits, 319 Fed.Appx. 207 (4th Cir. 2009)(defendant 
convicted of bank fraud, a class B felony, sentenced to one day of imprisonment followed by five 
years of supervised release). 
Accordingly, Ms. Clark and the United States are in agreement that Ms. Clark should be 
sentenced to time served, followed by three years of supervised release, pursuant to Rule 11 
(c)(1)(C). Additionally, the Court may impose any lawful fine(s) and special assessment fees as 
required by law, and order forfeiture as applicable and restitution as appropriate. In the event that 
the Court declines to accept this agreement, either party will be free to withdraw from the plea 
agreement.    
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 # 024579 
Case 1:21-cr-00069-CEA-CHS     Document 35     Filed 06/01/22     Page 2 of 2     PageID
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