IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

 ) 

United States of America ) 

 ) No. 20 CR 280 

 v. ) 

 ) Judge Andrea R. Wood 

Tahkisha Hodge ) 

 ) 

TAHKISHA HODGE’S PLEA DECLARATION

 The defendant, Tahkisha Hodge, after consultation with her attorney, 

Geoffrey M. Meyer, acknowledges and states the following: 

 1. She has been charged by indictment with one count of conspiracy to 

commit an offense against the United States, in violation of Title 18, United 

States Code, Section 371. Specifically, Ms. Hodge is charged with conspiracy to 

take and carry away with the intent to steal money exceeding $1,000 in value 

belonging to, and in the care, custody, control, management, and possession of 

PNC Bank, National Association, in violation of Title 18, United States Code, 

Section 2113(b). 

 2. She has read the charge against her contained in the indictment, and 

that charge has been fully explained to her by her attorney. 

 3. She fully understands the nature and elements of the crime with which 

she has been charged. 

 4. She will enter a voluntary plea of guilty to the indictment in this case. 
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FACTUAL BASIS

 5. Ms. Hodge will plead guilty because she is in fact guilty of the charge 

contained in the indictment. More specifically, Ms. Hodge admits the following 

facts and acknowledges that those facts establish her guilt beyond a 

reasonable doubt: 

 On the night of June 1, 2020, and into the morning of June 2, 2020, the 

City of Chicago was experiencing its third straight night of civil unrest related 

to the murder of George Floyd. Beginning at approximately 1:50 a.m., on 

June 2, 2020, a group of people began to gather outside the PNC Bank branch 

located at 8700 South Cottage Grove, Chicago, Illinois. Over the course of the 

next 40 minutes this group grew from about four people to over a dozen, and 

included Paris Mickle and Tahkisha Hodge. The group agreed to break into the 

PNC Bank ATM located outside the PNC Bank, in order to steal the United 

States currency stored in the ATM. 

 In furtherance of this agreement, multiple people tried to open the ATM by 

pulling it open or prying it open with a crowbar. They were unsuccessful. Then 

Mr. Mickle used a small blow torch to attempt to break into the ATM. This 

attempt was also unsuccessful. Someone then connected one end of a chain to 

a sedan and the other end of the chain to the ATM, and another person drove 

the sedan away in order to attempt to break into the ATM. This, too, was 

unsuccessful. Members of the group then repositioned the chain in the ATM 

and attached the other end of the chain to Ms. Hodge’s SUV. Ms. Hodge drove 
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the SUV away from the ATM in an attempt to open it. This was also 

unsuccessful. The police then arrived and the group scattered. 

 Ms. Hodge acknowledges that at the time of the overt acts of the conspiracy, 

the PNC Bank located at 8700 South Cottage Grove, Chicago, Illinois, was 

insured by the Federal Deposit Insurance Corporation. 

POTENTIAL PENALTIES

 6. Ms. Hodge understands that this charge carries a maximum 

incarceration sentence of five years, a maximum fine of $250,000, and a 

potential term of supervised release of not more than three years. Ms. Hodge 

further understands that there is no mandatory prison sentence for this 

offense and that it may be punished by a period of up to five years of probation. 

 7. Ms. Hodge understands that pursuant to Title 18, United States Code, 

Section 3663A, the Court must order restitution to the victims of the offense in 

an amount to be determined by the Court. 

 8. Ms. Hodge understands that in accord with federal law, Title 18, United 

States Code, Section 3013, upon entry of judgment of conviction, she will be 

assessed $100 on the count to which she has pled guilty, in addition to any 

other penalty imposed. 

 9. Ms. Hodge understands that, at the sentencing hearing, the Court will be 

guided by the United States Sentencing Guidelines. She understands that the 

guidelines are no longer mandatory, but are advisory only, and that this 

Court’s decision as to what sentence constitutes a sentence “sufficient, but not 

greater than necessary” to comply with the purposes set forth in 18 U.S.C. 
4 

§ 3553(a) may result in a sentence either within, greater, or less than the 

applicable sentencing guideline range. Ms. Hodge understands that the 

applicable sentencing guideline range is one factor which this Court is required 

to take into consideration under 18 U.S.C. § 3553(a)(4), along with the other 

required factors under § 3553(a). 

 10. Ms. Hodge and her attorney acknowledge that any guidelines 

calculations they have discussed are preliminary in nature and based on facts 

known to them at the time of this plea declaration. Ms. Hodge understands 

that the probation office and the government will conduct their own 

investigations and that the Court ultimately determines the facts and law 

relevant to sentencing, and that the Court’s determinations govern the final 

Sentencing Guidelines calculations. 

 11. Errors in the calculation or interpretation of any of the guidelines may 

be corrected by Ms. Hodge prior to sentencing. She may correct these errors or 

misinterpretations by submitting a statement to the probation office and/or 

Court, setting forth the disagreement as to the correct guidelines and their 

application. 

 12. Ms. Hodge reserves the right to request a downward departure or 

variance on any grounds she deems appropriate. She understands that any 

decision to depart or vary from the applicable guidelines lies solely with the 

discretion of the Court. 
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TRIAL RIGHTS AND APPELLATE RIGHTS

 13. Ms. Hodge understands that by pleading guilty she surrenders certain 

rights, including the following: 

 (a) If Ms. Hodge persisted in a plea of not guilty to the charges against 

her, she would have the right to a public and speedy trial. The trial could be 

either a jury trial or a trial by the judge sitting without a jury. Ms. Hodge has a 

right to a jury trial. However, in order that the trial be conducted by the judge 

sitting without a jury, Ms. Hodge, the government, and the judge all must agree 

that the trial be conducted by the judge without a jury. 

 (b) If the trial is a jury trial, the jury would be composed of twelve 

laypersons selected at random. Ms. Hodge and her attorney would have a say 

in who the jurors would be by removing prospective jurors for cause where 

actual bias or other disqualification is shown, or without cause by exercising 

so-called peremptory challenges. The jury would have to agree unanimously 

before it could return a verdict of either guilty or not guilty. The jury would be 

instructed that Ms. Hodge is presumed innocent, and that it could not convict 

her unless, after hearing all the evidence, it was persuaded of her guilt beyond 

reasonable doubt. 

 (c) If the trial is held by a judge without a jury, the judge would find the 

facts and determine, after hearing all the evidence, whether or not she was 

persuaded of Ms. Hodge’s guilt beyond a reasonable doubt. 

 (d) At trial, whether by a jury or a judge, the government would be 

required to present its witnesses and other evidence against Ms. Hodge. Ms. 
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Hodge would be able to confront those government witnesses and her attorney 

would be able to cross-examine them. In turn, Ms. Hodge could present 

witnesses and other evidence in her own behalf. She would be under no 

obligation to do so, however, because she is presumed to be innocent and, 

therefore, need not prove her innocence. If the witnesses for Ms. Hodge would 

not appear voluntarily, she could require their attendance through the 

subpoena power of the court. 

 (e) At a trial, Ms. Hodge would have a privilege against self-incrimination 

so that she could decline to testify, and no inference of guilt could be drawn 

from her refusal to testify. If Ms. Hodge desired to do so, she could testify in 

her own behalf. 

 14. Ms. Hodge understands that by pleading guilty she is waiving all the 

rights set forth in the prior paragraph. Ms. Hodge’s attorney has explained 

those rights to her, and the consequence of her waiver of those rights. Ms. 

Hodge further understands that she is waiving all appellate issues that might 

have been available if she had exercised her right to trial, and only may appeal 

the validity of this plea of guilty, the effectiveness of counsel, and the sentence. 

LIMITATIONS AND CONSEQUENCES OF THIS PLEA DECLARATION

 15. Ms. Hodge understands that the United States Attorney’s Office will fully 

apprise the District Court and the United States Probation Office of the nature, 

scope, and extent of her conduct regarding the charges against her, and related 

matters, including all matters in aggravation and mitigation relevant to the 
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issue of sentencing. Ms. Hodge further understands that she and her attorney 

will be able to present evidence in mitigation at sentencing. 

 16. Ms. Hodge understands that at the time of sentencing, she and her 

attorney, and the government, will be free to make their respective 

recommendations to the Court as they believe are appropriate. 

 17. Should the Court refuse to accept Ms. Hodge’s plea of guilty, this Plea 

Declaration shall become null and void and she will not be bound thereto. It is 

Ms. Hodge’s position that, should the Court decline to accept her plea, Ms. 

Hodge withdraws her plea of guilty pursuant to Rule 11 of the Federal Rules of 

Criminal Procedure. Additionally, pursuant to Rule 11(f) and Federal Rule of 

Evidence 410, this Plea Declaration and the ensuing court proceedings would 

be inadmissible in later court proceedings. 

 18. If accepted, Ms. Hodge agrees that this Plea Declaration shall be filed 

and become a part of the record of the case. 

 
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 19. Ms. Hodge and her attorney acknowledge that no threats, promises, or 

representations have been made, nor agreements reached, to induce her to 

plead guilty. Ms. Hodge further acknowledges that she has read this Plea 

Declaration and carefully reviewed each provision with her attorney. 

 Signed this ____ day of __________, 2021 

______________________________________

Tahkisha Hodge 

 Defendant 

Federal Defender Program 

John F. Murphy, 

Executive Director 

By:___________________________________ 

Geoffrey M. Meyer 

Attorney for Tahkisha Hodge 

FEDERAL DEFENDER PROGRAM

55 East Monroe Street, Suite 2800 

Chicago, IL 60603 

(312) 621-8300 

g ____ 14th y July

_______________________

eoffrey M. Meyer