UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TENNESSEE

GREENEVILLE

UNITED STATES OF AMERICA )

)
v. ) 2:17-CR-26
) JUDGE GREER
GAYLE SHAPIRO GREEN )
)

UNITED STATES= SENTENCING MEMORANDUM

Comes the United States of America, by and through the United States Attorney for the

Eastern District of Tennessee and, as directed by the Court, submits the following sentencing

memorandum in compliance with the Court’s Order.

The defendant entered a guilty plea on September 13, 2017, to mail fraud and concealment

money laundering as charged in Counts One and Fifteen of a fifteen count indictment. The statutory

term of imprisonment for the defendant’s offenses is not more than 20 years. The Presentence

Investigative Report (PSR) prepared by U.S. Probation establishes an advisory guideline range of 33

months to 41 months.

The United States recognizes the Court’s duty to impose a sentence sufficient, but not greater

than necessary to comply with all the factors set forth in 18 U.S.C. § 3443(a). The advisory guideline

sentence of 33 to 41 months has taken into account many factors, such as the defendant’s lack of

criminal history, and the fact the defendant stole and converted to her own use over $116,000.00.

In looking at the nature of the offense, several of the circumstances of this case merit noting.

The defendant’s thefts were from victim organizations that had noble goals and intentions. The

Kingsport Kennel Club thought they were funding scholarships to the University of Tennessee, when

in actuality, the defendant stole the money intended to help veterinary students. The defendant also

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stole money from the Tennessee Basketry Association’s efforts to provide “Angel Baskets” to patients

and families at Vanderbilt University Hospital. These were not one-time thefts, but part of a scheme

that spanned a decade. The defendant employed methods, which included skimming cash, diverting

mail, and concealing her thefts in various ways, including forging false financial and audit reports.

The United States understands that the Court must consider the characteristics of the defendant.

Defendant Green is a well-educated woman. The fact she has no prior convictions is already factored

into the advisory range. Given her age, a guideline sentence would statistically result in her spending a

large percentage of the rest of her life in prison.

Some of the letters of support ask for probation. Given the seriousness of the offense, the need

to promote respect for the law, punish the defendant for her criminal actions, and to afford deterrence

to others, the United States believes a substantial prison sentence is required after a full evaluation of

all the statutory factors.

Finally, the defendant’s hypocrisy is worth noting. She volunteered to do something that was

perceived as honorable and selfless, when what she was really doing was stealing from these

organizations whose goals really were honorable and selfless.

Respectfully submitted,

J. DOUGLAS OVERBEY
United States Attorney

By: s/ Robert M. Reeves

ROBERT M. REEVES
Assistant United States Attorney
220 W. Depot St., Ste. 423
Greeneville, TN 37743
(423) 639-6759

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 CERTIFICATE OF SERVICE

I hereby certify that on March 7, 2018, a copy of the foregoing was filed electronically.
Notice of this filing will be sent by operation of the Court’s electronic filing system to all parties
indicated on the electronic filing receipt. Parties may access this filing through the Court's electronic
filing system.

s/ Robert M. Reeves
ROBERT M. REEVES
Assistant U.S. Attorney

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