Letter to Judge Gallagher, Gerald C. Ruter — United States of America v. Reginald Davis (D. Md., Dkt. 81)

Summary

Letter dated September 24, 2025 from Gerald C. Ruter to Honorable Stephanie A. Gallagher, filed September 25, 2025 as Document 81, Case 1:23-cr-00269-SAG, United States v. Reginald Davis, District of Maryland, written on behalf of Mr. Davis to assist the Court in determining a sentence. It states that Mr. Davis was charged by Superseding Information with one Count Misdemeanor Bank Theft, in violation of 18 U.S.C. 2113(b), and entered a plea of guilty on June 27, 2025 before Magistrate Judge Erin Aslan. It states that the parties agreed a sentence of time served is the appropriate sentence and that the advisory guidelines were 0 to 6 months. It states that a sentence of time served with a term of six months' probation is reasonable. It is signed /S/ Gerald C. Ruter.

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      Case 1:23-cr-00269-SAG        Document 81    Filed 09/25/25      Page 1 of 11
    The Law Offices Of
GERALD C. RUTER                                            9411 Philadelphia Road, Suite O
PROFESSIONAL CORPORATION                                    Baltimore, Maryland 21237
                                                                 (410) 238-8000
                                                           Fax: (410) 238-0597
                                                           E-Mail: ruterlaw@verizon.net



                                   September 24, 2025



Honorable Stephanie A. Gallagher
United States District Judge
101 W. Lombard Street
Baltimore, Maryland 21201

             Re:         United States of America v. Reginald Davis
                                  Case No. SAG-23-269

Dear Judge Gallagher:

     The Court is scheduled to sentence Mr. Davis in the above
captioned case on October 6, 2024. This letter is written on
behalf of Mr. Davis to assist the Court in its determination of
a reasonable sentence in this case.

                                    Background

     Mr. Davis was charged by Superseding Information with one
Count Misdemeanor Bank Theft, in violation of 18 U.S.C. 2113(b)
on June 27, 2025. It is anticipated that his Indictment returned
on August 3, 2023, charging wire fraud and money laundering will
be dismissed. He was arrested on August 9, 2023, and released
with Pretrial Services supervision. He has remained on release
since that date.

     On June 27, 2025, Mr. Davis appeared before Magistrate
Judge Erin Aslan and entered a plea of guilty to the above
charge. Before entering his plea, the Court advised him of his
right to appear before a district judge pursuant to Fed. Rule
58. Mr. Davis stated on the record that he understood that right
and pursuant to Rule 58(A), he waived that right and consented
to entering his plea before a Magistrate Judge.

      He now appears for sentencing on October 6, 2025.

                                  Plea Agreement

     Mr. Davis stipulated that he was the Interim Chief
Executive Officer of Strong City Baltimore at the time of this
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Honorable Stepahanie A. Gallagher
September 24, 2025



offense. He admitted that with the close assistance of others he
applied for a Payroll Protection Program loan from a federally
insured bank. The application required the applicant to attest
that the monies advanced to Strong City Baltimore would be used
for specified purposes. At the time the application was
executed, Mr. Davis and others were planning to use some of the
money to pay back money it held for other non-profits that had
requested their money be returned to them.

     The parties agreed that USSG 2B1.1 partially determines the
applicable offense level and further agreed that Mr. Davis was
entitled to a two-level downward adjustment pursuant to USSG
3E1.1 and a further downward adjustment of two levels pursuant
to USSG 4C1.1. The plea agreement states no loss amount.

     The parties also agreed that a sentence of time served is
the appropriate sentence to be imposed. The parties agreed the
Court was free to impose a fine or set conditions of supervised
release or probation.

     Mr. Davis has waived his right to appeal his conviction and
any sentence the Court may impose.

     Finally, the Plea Supplement indicates that this is not a
cooperation agreement.

                  The Pre-Sentence Report

     Mr. Davis reviewed the PSR with counsel on September 24,
2025. The changes are of a minor nature and will not alter the
guideline calculations. They are as follows:
     Paragraph 3 – The plea was taken before Magistrate Judge
Erin Aslan;
     Paragraph 14 – The Count of conviction is 1, not 18;
     Paragraph 47 – Although this may not require an addition to
the PSR, Mr. Davis cancer screening continues for one more year
at which time health care providers may opine he is cancer free;
     Paragraph 51 – The counseling center referenced in this
paragraph is Wendt Center for Loss and Healing, located in
Washington, D.C.;
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Honorable Stephanie A. Gallagher
September 24, 2025



     Paragraph 64 – The name of the university where Mr. Davis
received his bachelor’s degree should be University of the
District of Columbia;
     Paragraph 65 – The name of the high school referenced is
George Westing House Career Academy, in Chicago, Illinois.

     The PSR shows a total of 0 criminal history points and a
criminal history category of I at paragraph 28.

     The advisory guidelines were determined to be 0 to 6 months
at paragraph 79. The PSR also noted that pursuant to USSG
5C1.1(b) or (c)(3), a sentence of imprisonment is not
appropriate. See paragraph 80.

                 18 U.S.C. 3553(a) Factors

      The Court should consider: 1) the nature of the offense
and 2) the circumstances of the offense.

     1) Nature of the offense – The count of conviction is a
Class A misdemeanor. The maximum sentence is one year
incarceration. The statement of facts in support of the guilty
plea outlines the nature of the offense. The admitted conduct is
moderately serious when one attempts to quantify the scope of
crime in our criminal justice system.

     2) Circumstances of the offense – The circumstances of the
offense are significant and present the reason this case started
as a 20-year felony and has been resolved as a one-year
misdemeanor. Mr. Davis became employed with Strong City
Baltimore in November of 2019. He knew of Strong City as an
extremely large non-profit organization that manage dozens of
what are called “fiscally sponsored” organizations. Fiscally
sponsored organizations were non-profits that did not wish to
build their own infrastructure of buildings, employees,
communications, accounting and legal, etc. Instead, those
organizations that wished to have a positive impact on their
community, used Strong City to provide all those important
services in exchange for paying a fee to Strong City. For some
fiscal sponsors, Strong City was authorized to use the
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Honorable Stephanie A. Gallagher
September 24, 2025



funds received in any manner Strong City saw fit. In other
instances, the fiscal sponsor gave specific instructions to
Strong City on where the funds given could be used. When Mr.
Davis joined Strong City as Chief of Staff he had no knowledge
of the fiscal position of the organization. His duties were
strictly overseeing the employees of Strong City and assuring
that their assigned work was being done effectively. His
superior and the CEO of Strong City, Karen Stokes, had been the
head of the organization for over 15 years and she resigned with
little notice after Mr. Davis had been on the job for five
months. Several other key and experienced leaders of Strong City
left at the same time as did Ms. Stokes. The Board of Directors
named Mr. Davis Interim CEO in April of 2020. The Board advised
Mr. Davis they wanted an audit of Strong City’s books due to
concerns it had.

     Mr. Davis employed an accounting firm to undertake this
responsibility. Following an evaluation of Strong City’s books,
it was learned that Strong City could not survive fiscally, due
to the simple fact that more money was being spent than income
coming in. It was discovered that fiscal sponsored monies were
not properly separated in such a way that it was difficult, if
not impossible, to discern the status of the fiscal sponsors’
money being held in trust by Strong City. Mr. Davis and the
Board were committed to winding down fiscal sponsorship as a
means by which to serve the Baltimore community and use other
means to do so.

     The situation was exacerbated as COVID-19 halted much of
the work non-profits were able to perform; the money Strong City
was receiving from them; the ill-advised purchase of the
building Strong City acquired; and the money owed to it by
multiple organizations that were not repaid.

     This was the situation Mr. Davis inherited from his
predecessor. It ended when Mr. Davis electronically signed the
application for a PPP loan which brings him before this Court.

     Mr. Davis signed the application while in Chicago, where he
was burying a brother (his third brother murdered) and
stepfather, both of whom were murdered in the streets of Chicago
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Honorable Stephanie A. Gallagher
September 24, 2025



within 10 days of one another and while Mr. Davis was traveling
back and forth to Chicago caring for his terminally ill mother.
His mother died shortly after Mr. Davis eulogized his brother
and stepfather.

     The Court should consider: 1) the history of the defendant
and 2) the characteristics of the defendant.

     1) The history of the defendant – Mr. Davis is 42 years of
age. He was raised primarily by his mother, Judy Kemp. He is one
of three children born to his mother and partner, Mr. Reginald
Davis, and half siblings that he is close to as well. Mr.
Davis’s father suffered from drug abuse and was in jail from
time to time. He lived in public housing in Chicago where he was
born and raised. At age 12, while still living in public
housing, he moved to a better section of Chicago known as Humble
Park. His mother always worked full time in various capacities
to care for her children. He was surrounded by aunts, uncles,
and cousins.

     Mr. Davis graduated from high school in Chicago. He
received his bachelor’s degree from the University of
Washington, D.C. in 2011 and completed a certificate program in
non-profit management in January 2012. From 2013 to 2015, he
attended a public management graduate degree from Johns Hopkins
University in Washington, D.C. He was just four classes away
from finishing the program but stopped when a brother and half-
brother were murdered in Chicago. Recently, while on release in
this case, he has taken two classes in a master’s degree program
at the University of Maryland Global Campus in Eldridge,
Maryland.

     Mr. Davis has been gainfully employed throughout his adult
life. He was employed as Director of Public Policy for the
National Human Services Assembly in Washington, D.C. from 2014
to 2015. He worked for five years at the Bizzell Group in
Lanham, Maryland as a Program Manager from 2015 to 2019. He
worked for Strong City Baltimore from 2019 to 2022. After
leaving Strong City he worked as a driver for DoorDash and
Amazon Flex. He recently opened his own business known as
Mission Advisors, LLC.
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Honorable Stephanie A. Gallagher
September 24, 2025


     Mr. Davis has never married and has no children. He has
much interaction with his siblings and extended family members.

     Mr. Davis was diagnosed with cancer that was discovered
while he was undergoing surgery. A segment of his intestines was
removed and he maintains six-month monitoring of his cancer. At
the end of next year, should there be no evidence of cancer he
will be released from the doctor’s care. Mr. Davis has been in
treatment for grief counseling from 2015 and 2016 following the
murders noted above. Mr. Davis has been a patient of Resonate
Counseling Services since 2021, again mostly following the loss
of his brother, stepfather, and mother earlier in 2021. He still
sees her weekly for psychotherapy. Mr. Davis had a mental health
evaluation at Bright Horizons on September 1, 2023. He was
diagnosed with prolonged grief disorder; depression,
unspecified; pseudo bulbar; and antisocial personality disorder.
Mr. Davis was not advised of the last two diagnoses noted. He
was seen only one time at Bright Horizons.

     Mr. Davis admitted to consuming alcohol only socially and
no more than twice monthly. He used marijuana a few times yearly
and last used it in December of 2023. Bright Horizon also
diagnosed him with “cannabis use, unspecified; and alcohol use,
unspecified.” U.S. Probation has had Mr. Davis counselor at
Resonate combine substance therapy with mental health treatment.

     2) The defendant’s characteristics – Mr. Davis is an
extraordinary person who has accomplished much and whose
character is demonstrated by the letters attached alphabetically
by the writer’s last name. Exhibit 1A is a letter from Jenee
Barnes, a federal employee who writes that she is surprised
about these charges given “Reginald’s reverence for the law and
policy.” She has witnessed first-hand his touching “countless
lives as a mentor, a friend, and a community leader.” Exhibit 1B
is a letter from Anton C. Bizzell, Chairperson and CEO of the
Bizzell Group who wrote he first met Mr. Davis when Mr. Davis
was inducted into the Alpha Phi Alpha Fraternity. Dr. Bizzell
recounted the extraordinary work Mr. Davis did for his company
during his employment that demonstrated his commensurate
leadership who “is a man committed to improving the lives of
others.” Exhibit 1C is a letter from George Anthoney Clarke who
is also a friend and fraternity brother of Mr. Davis. He
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Honorable Stephanie A. Gallagher
September 24, 2025



describes Mr. Davis “as the rock for his family” and explained
why. He states that “Reginald has been a man who is guided by
his love for family, respect for the law and truth, his self-
respect, and his commitment to his community.” Exhibit 1D is a
letter from Danielle Conway, who worked with Mr. Davis who
attests that “I worked closely with Reginald and came to know
him as a leader who exemplifies faith, integrity, and a genuine
commitment to his community.” She said in all things he was
kind, honest, dedicated, generous, devoted, caring and more.
Exhibit 1E is a letter from Lexington Andre Culpepper. He
describes Mr. Davis as “Resilient. Compassionate. Dependable. A
loyal friend. A source of strength.” Dr. Culpepper recounted
some things Mr. Davis does for his present mentee. Exhibit 1F
is a letter from Ashley Davis, Mr. Davis sister. She says that
Mr. Davis is the leader of their family with their mother. She
says, “Reginald has been that shelter, supporter, shoulder,
therapeutic, loving, helping hand I need now, his kindness,
loyalty, devotion to my family.” Exhibit 1G is a letter from
Larry Donnell Davis, a school counselor for 45 years. He has
known Mr. Davis for 12 years and he points to Mr. Davis’s
leadership in his family during the time of the murders of his
stepbrother, stepfather, younger brother and niece where he made
funeral arrangements, cared for his dying mother, and dealt with
the grief of those remaining in the family. Exhibit 1H is a
letter from Karen DeCamp who works for a Baltimore non-profit
and began working for the Greater Homewood Community Corp., in
2007 that later became Strong City Baltimore until she left
Strong City in 2020. She played an integral part in the
education program at Strong City and the after-school program at
the Club at Collington. She recounts that as soon as Mr. Davis
was hired as Chief of Staff, he became immersed in “The Club” by
mentoring the most at-risk boys which continues to this day. She
[pointed that to this day Mr. Davis provides support to three
young men, providing “stability, kindness, meals, an open ear, a
calm demeanor, help at school, and helping with difficult life
situations.” Last year he and Vanessa Williams drove one of Mr.
Davis mentees to college in South Carolina. The young man just
started his sophomore year. Exhibit 1I is a letter from
Marquitta Harris. She shared how years ago she was in a
dangerous relationship with a person; she called Mr. Davis, he
drove with a friend over 300 miles to pick
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Honorable Stephanie A. Gallagher
September 24, 2025



her up, pack her belongings, and move her to a safe place.
Exhibit 1J is a letter from Danista E. Hunte, the president and
CEO of the Maryland Philanthropy Network. She has worked most
her adult life in service of the underprivileged. She worked
closely with him as he was a board member of Child First while
she served as the executive director. Mr. Davis served as a
board member for five years. She recounted the critical role Mr.
Davis played as a member of that board. Exhibit 1K is a letter
from Chad Kee, a brother who is a member of the same fraternity
earlier discussed. He states he has “observed Reginald
consistently lead with honesty, compassion, and dedication…” He
states that Mr. Davis provides “stability, hope, and
consistency” to his family and friends. Exhibit 1L is a letter
from Fr. Joe Muth who is the Chaplain at the University of Notre
Dame of Maryland. He was a volunteer at the after-school program
at the Club at Collington. He saw Mr. Davis “show up” at the
hospital if a child had been injured, “their court cases to give
testimony to the goodness of these students.” Fr. Muth said that
many of the children viewed Mr. Davis as a father figure to them
“and turned to him for comfort, advice, or counsel.” Exhibit 1M
is a letter from Terrance Narcisse, the CEO of the East Harris
County Empowerment Council, a nonprofit from Houston, Texas. He
has known Mr. Davis for 14 years and finds “him as one of the
most selfless and dependable people I have ever met.” Like so
many other writers who have attested to his character he is
aware first-hand of all that Mr. Davis has done for innumerable
families in need of groceries, transportation, clothing, and
encouragement and love. Exhibit 1N is a letter from Shaundrece
Rangel who is a Chicago native and has known Mr. Davis for over
30 years, dating back to high school. She states that Mr. Davis
has always been a positive influence on her and others lives.
Exhibit 1O is a letter from Keith Riley, the CFO of Bizzell US.
He knows Mr. Davis “as a person of loyalty, humility, and quiet
generosity.” He recalled seeing Mr. Davis garner resources for a
person about to lose their house and succeeding in his
endeavors. He has seen Mr. Davis provide countless hours of
mentoring and providing school supplies to students in need.
Exhibit 1P is a letter from Calvin E. Ruffin Jr. He has known
“Mr. Davis for 11 years and has witnessed qualities such as
integrity, compassion, and a willingness to take responsibility
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Honorable Stephanie A. Gallagher
September 24, 2025



for personal actions.” Dr. Ruffin is the Director of Career
Academies at Ballou High School, in Washington, D.C.
He knows Mr. Davis to be “a community advocate, volunteer,
mentor, and organizer.” He says Mr. Davis “is the backbone for
his family, friends, and loved ones…” He acknowledged that “Mr.
Davis is the stability and foundation for many in his life…”
Exhibit 1Q is a letter from Khama A. Sharp who has been an
attorney for over 15 years and now serves as an administrative
law judge for a state commission. He has known Mr. Davis for
over 20 years and knows Mr. Davis to be “one of the most
honorable men I have had the opportunity to engage with in my
life.” He outlined the status Mr. Davis holds in his family as
being “the one responsible for handling the administrative needs
of his family.” He took his younger brother for a time to assist
him in his life. He cared for his mother. He cares for his
sisters. He cares for anyone in need. Exhibit 1R is a letter
from Joshua Thomas who works for the Washington, D.C. government
as a Compliance Manager. He too, is a brother member of the
fraternity as referenced above by others. He recalls Mr. Davis
“honesty, loyalty, and devotion to his family” during the
funeral of Mr. Davis’s mother. He states Mr. Davis always shows
his “unwavering support and quiet wisdom… his kindness,
humility, and a deep commitment to doing what is right by
others.” Exhibit 1S is a letter from Ryan Turner, President and
Justin Morrisette, the vice president of Alpha Phi Alpha,
located in Baltimore. They see Mr. Davis as humble and
compassionate, “friendly and reliable”, “who believes deeply in
both tradition and humanity.” They spoke of the Beautillion
program of which Mr. Davis has held a prominent interest with
huge successes. Mr. Turner and Mr. Morrisette value how Mr.
Davis “has a gift for making people feel seen, valued, and
supported.” Exhibit 1T is a letter from M. Vanesa Williams, a
person with whom Mr. Davis worked while at Strong City. She
states, “I have witnessed firsthand Reginald’s honesty and work
ethic. He treats everyone with respect, no matter what their
background or circumstances.” She adds he is a “role model-
always willing to lend a hand, listen without judgment, and
offer guidance when it is most needed.” Exhibit 1U is a letter
from Shanita Robinson, the older sister of Mr. Davis. She has
“watched him grow into a man of incredible strength, loyalty and
compassion.” She says Mr. Davis “has been a constant source of
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Honorable Stephanie A. Gallagher
September 24, 2025



guidance, support, and love… as well as generosity, kindness,
and unwavering commitment to family…”

     The Court should determine the need for the sentence
imposed to reflect the seriousness of the offense, promote
respect for the law, and to provide just punishment for the
offense.

   A sentence of time served with six months of probation will
not deflect from the fact that this offense is serious. The
Court should find this sentence will promote respect for the law
and it will adequately punish Mr. Davis for his involvement in
this criminal activity.

     The Court should determine the need for a sentence to
afford adequate deterrence to criminal conduct.

     Counsel is of the opinion that it is impossible to ever
argue that a non-jail term or a short jail term would be more
likely to deter criminal conduct than a longer term of
incarceration. However, the statute requires that the sentence
provide adequate deterrence and nothing more. Given the facts
and circumstances of this offense, a total sentence of time
served with a period of probation will represent a sentence
designed to punish Mr. Davis, assure us that others will be
adequately reticent to engage in such activity and deter Mr.
Davis from further criminal activity. The Court should also find
that Mr. Davis is not in a financial position to pay a fine
because he has been unable to pay the necessities of life since
charges were initially brought in 2023.

     The Court should determine the need for a sentence to
protect the public from further crimes of the defendant.

     The Court should find that Mr. Davis poses no danger to the
public and is unlikely to commit any offenses in the future.

     The Court should determine the need for a sentence to
provide the defendant with needed educational or vocational
training, medical care, or other correctional treatment in the
most effective manner.
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Honorable Stephanie A. Gallagher
September 24, 2025



The Court should find that Mr. Davis is not in need of any of
the programs or services the Bureau of Prisons may offer.

     The Court should determine the need for a sentence that
will avoid unwarranted sentence disparities among defendants
with similar records that have been found guilty of similar
conduct.

     It is believed and therefore averred that a sentence of
time served with a term of six months’ probation will not
present disparities among similarly situated defendants with
similar records. The statistical data referenced in the PSR at
page 18 confirms this.

     This sentence adequately accounts for all sentencing
factors set forth in 18 U.S.C 3553(a), is sufficient but not
greater than necessary to accomplish the purposes of sentencing
and represents a reasonable sentence.

     With the Court’s permission, Mr. Davis would like to call
Anton Bizzell, Margaret William, James Davis or Andre Davis and
Fr. Joe Muth to attest to his character. We will request no more
than 15 minutes for this presentation.

                             Respectfully Submitted,

                             /S/ Gerald C. Ruter

                             Gerald C. Ruter


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Copied to: AUSA Ariel Evans and AUSA Joseph Wenner


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