Christopher J. Schatz, OSB No. 91509 

Assistant Federal Public Defender 

101 SW Main Street, Suite 1700 

Portland, OR 97204 

Tel: (503) 326-2123 

Fax: (503) 326-5524 

Email: Chris_Schatz@fd.org 

Attorney for Defendant 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

vs. 

TIARRE TRA VONNE CHANEY, 

Defendant. 

The defendant represents to the court: 

Case No. 3:15-cr-00324-BR 

PETITION TO ENTER PLEA OF 

GUILTY, CERTIFICATE OF COUNSEL, 

AND ORDER ENTERING PLEA 

1. My name is Tiairre Travonne Chaney. I am 28 years old. I have gone to school up 

to and including obtaining my General Equivalency Diploma (GED). 

2. My attorney is Christopher J. Schatz. 

3. My attorney and I have discussed my case fully. I have received a copy of the 

Indictment or Information. I have read the Indictment or Information, or it has been read to me, 

and I have discussed it with my attorney. My attorney has counseled and advised me concerning 

PAGE 1. PETITION TO ENTER PLEA OF GUILTY 
the nature of each charge, any lesser,included offense(s), and the possible defenses that I might 

have in this case. I have been advised and understand that the elements of the charge( s) alleged 

against me to which I am pleading "GUILTY" are as follows: [Count 1] Whoever, having devised 

or intending to devise any scheme or artifice to defraud, or for obtaining money or property by 

false or fraudulent pretenses, representations, or promises, transmits or causes to be transmitted by 

means of wire, radio, or television communication in interstate commerce, any writings, signs, 

signals, pictures, or sounds for the purpose of executing such scheme or artifice commits wire 

fraud as defined in 18 U. S.C. § 1341. I have had a full and adequate opportunity to disclose to my 

attorney all facts known to me that relate to my case. I understand that the Court may ask whether 

I am satisfied with the advice I have received from my attorney. 

4. I know that ifl plead "GUILTY," I will have to answer any questions that the judge 

asks me about the offense(s) to which I am pleading guilty. I also know that if I answer falsely 

under oath and in the presence of my attorney, my answers could be used against me in a 

prosecution for perjury or false statement. 

5. I am not under the influence of alcohol or drugs. I am not suffering from any injury, 

illness or disability affecting my thinking or my ability to reason except as follows: 

A)owe ~ 

I have not taken any drugs or medications within the past seven (7) days except as follows: 

NOIJE:. ~ 

6. I understand that conviction of a crime can result in consequences in addition to 

imprisonment. Such consequences include dep01tation or removal from the United States or denial 

of naturalization ifl am not a United States citizen;; compliance with federal and state sex offender 

registration requirements, if required by law (see 42 U.S.C. §§ 16911 & 16913 and Or. Rev. Stat. 

PAGE 2. PETITION TO ENTER PLEA OF GUILTY 
§§ 181.595, 181.596, & 181.597); loss of eligibility to receive federal benefits; loss of certain civil 

rights (which may be temporary or permanent depending on applicable state or federal law), such 

as the right to vote, to hold public office, and to possess a firearm; and loss of the privilege to 

engage in certain occupations licensed by the state or federal government. 

7. I know that I may plead "NOT GUILTY" to any crime charged against me and that 

I may persist in that plea if it has already been made. I know that ifl plead "NOT GUILTY," the 

constitution guarantees me: 

a. The right to a speedy and public trial by jury, during which I will be 

presumed to be innocent unless and until I am proven guilty by the government 

beyond a reasonable doubt and by the unanimous vote of twelve jurors; 

b. The right to have the assistance of an attorney at all stages of the 

proceedings; 

c. The right to use the power and process of the court to compel the production 

of evidence, including the attendance of witnesses in my favor; 

d. The right to see, hear, confront, and cross-examine all witnesses called to 

testify against me; 

e. The right to decide for myself whether to take the witness stand and testify, 

and if I decide not to take the witness stand, I understand that no inference of guilt 

may be drawn from this decision; and 

f. The right not to be compelled to incriminate myself. 

8. I know that if I plead "GUILTY," there will be no trial before either a judge or a 

jury and that I will not be able to appeal from the judge's denial of any pretrial motions I may have 

filed concerning matters or issues not related to the Court's jurisdiction. 

9. In this case I am pleading "GUILTY" under Rule 11 ( c )(1 )(C). My attorney has 

explained the effect of my plea under Rule 1 l(c)(l)(C) to be as follows: 

PAGE 3. PETITION TO ENTER PLEA OF GUILTY 
My plea of guilty is under Rule 11 ( c )(I )(C); therefore, at the time of sentencing, 

the judge must either impose the specific sentence agreed upon by the prosecutor 

and me, or allow me to withdraw my plea. 

I 0. I know the maximum sentence which can be imposed upon me for the crime(s) to 

which I am pleading guilty is twenty (20) years' imprisonment and a fine of $250,000 (or twice 

the victim's gross losses, whichever is greater). I also know there is no mandatory minimum 

sentence of imprisonment. 

11. I know that the judge, in addition to any other penalty, will order a special 

assessment as provided by law in the amount of $100 per count of conviction. 

12. I know that ifl am ordered to pay a fine, and I willfully refuse to pay that fine, I can 

be returned to court, where the amount of the unpaid balance owed on the fine can be substantially 

increased by the judge and I can be imprisoned for up to one year. 

13. My attorney has discussed with me the Federal Sentencing Guidelines. I know that 

the judge will consult the Federal Sentencing Guidelines with respect to the sentence to be imposed 

on me in this case, and that the judge will consider the sentence recommended by the Federal 

Sentencing Guidelines along with other factors, such as the seriousness of the offense( s) of which 

I have been convicted, the need to afford adequate deterrence to criminal conduct, the need to 

protect the public from further criminal conduct on my part, and the need to provide me with 

educational and vocational training, medical care, or other correctional treatment in the most 

effective manner. I know that there is no guarantee that my sentence will be within the guideline 

range. If my attorney or any other person has calculated a guideline range for me, I know that this 

is only a prediction and that it is the judge who makes the final decision as to what sentence will 

be imposed. I also know that a judge may not impose a sentence greater than the maximum 

sentence referred to in paragraph 10 above. 

PAGE 4. PETITION TO ENTER PLEA OF GUILTY 
14. I know from discussion with my attorney that if I am sentenced to prison I am not 

entitled to parole. I will have to serve the full sentence imposed except for any credit for good 

behavior that I earn. I can earn credit for good behavior in prison at a rate of up to 54 days for each 

year of imprisonment served. Credit for good behavior does not apply to a sentence of one year or 

less. 

15. I know that if I am sentenced to prison, the judge will impose a term of supervised 

release to follow the prison sentence. During my supervised release term I will be supervised by a 

probation officer according to terms and conditions set by the judge. In my case, a term of 

supervised release can be up to three (3) years. If I violate the conditions of supervised release, 

I may be sent back to prison for up to two (2) years for each such violation. 

16. I know that in addition to or in lieu of any other penalty, the judge can order 

restitution payments to any victim of any offense to which I plead guilty. I am also informed that 

for certain crimes of violence and crimes involving fraud or deceit, it is mandatory that the judge 

impose restitution in the full amount of any financial loss or harm caused by an offense. If imposed, 

the victim can use the order of restitution to obtain a civil judgment lien. A restitution order can 

be enforced by the United States for up to twenty (20) years from the date of my release from 

imprisonment or, ifl am not imprisoned, twenty (20) years from the date of the entry of judgment. 

If I willfully refuse to pay restitution as ordered, a judge may resentence me to any sentence which 

could originally have been imposed. 

17. On any fine or restitution in an amount of $2,500 or more, I know that I will be 

required to pay interest unless that fine or restitution is paid within fifteen (15) days from the date 

of the entry of judgment. 

PAGE 5. PETITION TO ENTER PLEA OF GUILTY 
18. If I am on probation, parole, or supervised release in any other state or federal case, 

I know that by pleading guilty in this court, my probation, parole, or supervised release may be 

revoked and I may be required to serve time in that case, which may be consecutive, that is, in 

addition to any sentence imposed on me in this court. 

19. If I have another case pending in any state or federal court, I know that my petition 

and plea agreement in this case do not, in the absence of an express and written agreement, apply 

to my other case(s) and that I can be faced with consecutive sentences of imprisonment. 

20. My plea of "GUILTY" is based on a plea agreement that I have made with the 

prosecutor. That plea agreement is attached hereto and incorporated herein. I have read or had read 

to me the plea agreement, and I understand the plea agreement. 

21. The plea agreement contains the only agreement between the United States 

government and me. No officer or agent of any branch of government (federal, state, or local) or 

anyone else has promised or suggested that I will receive a lesser term of imprisonment or 

probation or any other form of leniency if I plead "GUILTY," except as stated in the plea 

agreement. I understand that I cannot rely on any promise or suggestion made to me by a 

government agent or officer which is not stated in writing in the plea agreement or which is not 

presented to the judge in my presence in open court at the time of the entry of my plea of guilty. 

22. My plea of "GUILTY" is not the result of force, threat, or intimidation. 

23. I hereby request that the judge accept my plea of"GUILTY" to the following count: 

Count I. 

24. I know that the judge must be satisfied that a crime occurred and that I committed 

that crime before my plea of "GUILTY" can be accepted. With respect to the charge(s) to which 

I am pleading guilty, I represent that I did the following acts and that the following facts are true: 

PAGE 6. PETITION TO ENTER PLEA OF GUILTY 
On February 22, 2011, in the District of Oregon, I knowingly caused to be 

transmitted by means of wire communication in interstate commerce an electronic 

IRS Form 1040A for the year 2010 in the name of federal tax payer "T_H_", 

claiming a fraudulent refund of $6,878. I further acknowledge that this event was 

one of a number of similar events that occurred beginning January, 2011 and 

continuing through April, 2011, and that I undertook this conduct with the intent to 

deceive the IRS and to obtain tax refund funds by way of such deception that was 

not lawfully due to the named tax payer. 

25. I offer my plea of "GUILTY" freely and voluntarily and of my own accord and 

with a full understanding of the allegations set forth in the Indictment or Information and with a 

full understanding of the statements set forth in this petition and in the certificate of my attorney 

that is attached to this petition. 

SIGNED by me in the presence of my attorney after reading (or had having read to 

me) all of the foregoing pages and paragraphs of this petition on this \ '6. \.. day of 

PAGE 7. PETITION TO ENTER PLEA OF GUILTY 
CERTIFICATE OF COUNSEL 

The undersigned, as attorney for defendant Tiairre Travonne Chaney, hereby certifies: 

1. I have fully explained to the defendant the allegations contained in the Indictment 

or Information in this case, any lesser-included offense(s), and the possible defenses which may 

apply in this case. 

2. I have personally examined the attached Petition to Enter Plea of Guilty and Order 

Entering Plea, explained all its provisions to the defendant, and discussed fully with the defendant 

all matters described and referred to in the petition. 

3. I have explained to the defendant the maximum penalty and other consequences of 

entering a plea of guilty described in paragraphs (6)-(20) of the petition, and I have also explained 

to the defendant the applicable Federal Sentencing Guidelines. 

4. I recommend that the Court accept the defendant's plea of"GUILTY." 

SIGNED by me in the presence of the above-named defendant and after full discussion 

with the defendant of the contents of the Petition to Enter Plea of Guilty and any plea agreement 

onthis~\ ___ dayof ~~/ 

PAGE 8. CERTIFICATE OF COUNSEL 

Christopher J. Schatz 

Attorney for Defendant 

'2015. 
ORDER ENTERING PLEA 

I find that the defendant's plea of GUILTY has been made freely and voluntarily and not 

out of ignorance, fear, inadvertence, or coercion. I further find the defendant has admitted facts 

that prove each of the necessary elements of the crime(s) to which the defendant has pied guilty. 

IT IS THEREFORE ORDERED that the defendant's plea of GUILTY be accepted and 

entered as requested in this petition and as recommended in the certificate of defendant's attorney. 

DATED this ,;yyG of Ocfry/)tv . , 2015, in open court. 

The Honorable' 

United States District Court Judge 

PAGE 9. ORDER ENTERING PLEA