SENTENCING MEMORANDUM as to Christopher Scott — USA v. Brown, et al. (Dkt. 92)

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U.S. District Court for the Northern District of Illinois · No. 1:23-cr-00097 · Doc. 92 · 2025-06-25 · Docket on CourtListener

Summary

The Government's Sentencing Memorandum as to Christopher Scott in United States v. Christopher Scott, No. 23 CR 97-2, in the U.S. District Court for the Northern District of Illinois, filed June 25, 2025 as Document #: 92 in No. 1:23-cr-00097. The memorandum states that Scott pleaded guilty to one count of wire fraud on April 4, 2025, and describes the government's account of PPP and EIDL loan applications he and co-defendant Te Dora Brown submitted. It adopts a total offense level of 22 and criminal history category VI, for an advisory range of 84 to 105 months. The government requests 96 months of imprisonment, three years of supervised release and restitution of $567,333, and suggests a fine may be appropriate. The 11-page memorandum refers to Exhibits 1, 2 and 3 and is signed by an Assistant United States Attorney.

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UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF ILLINOIS 
EASTERN DIVISION 
 
UNITED STATES OF AMERICA 
 
 
v. 
 
CHRISTOPHER SCOTT  
 
 
 
No. 23 CR 97-2 
 
 
Hon. Elaine E. Bucklo 
 
GOVERNMENT’S SENTENCING MEMORANDUM 
Beginning at the end of March 2020 (and likely earlier), during the height of 
the COVID-19 pandemic, defendant Christopher Scott and his co-defendant wife 
illegally took advantage of the U.S. Small Business Administration’s Paycheck 
Protection Program (PPP) and Economic Injury Disaster Loan (EIDL) program meant 
to assist individuals and small businesses ravaged by the economic conditions 
wrought by the pandemic. The defendant and his wife devised, executed, and 
concealed a scheme to defraud the SBA and participant banks out of over half a 
million dollars in funds intended for the financial victims of COVID-19—a sum that 
would have been nearly four times greater had SBA safeguards not flagged and 
declined many of Scott’s fraudulent loan applications. On April 4, 2025, Scott pled 
guilty to one count of wire fraud, and is now before this Court for sentencing. 
With a total offense level calculated by U.S. Probation of 22 and in the highest 
criminal history category of VI, Scott’s advisory Guidelines range is 84 to 105 months 
of imprisonment. For the reasons set forth below, the government respectfully 
requests a within-range Guidelines sentence of 96 months of imprisonment, three 
years of supervised release, and restitution in the amount of $567,333, to be paid 
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along with any jointly liable co-defendant. Such a sentence is sufficient, but not 
greater than necessary, to achieve the goals of sentencing articulated in 18 U.S.C. 
§ 3553(a). 
I. 
THE OFFENSE CONDUCT 
During the course of conduct alleged in the indictment in 2020 and 2021, 
defendant Christopher Scott and his wife, co-defendant Te Dora Brown, submitted 
numerous applications for both PPP and EIDL loans, which, as described in detail in 
the indictment and throughout the record, are forgivable loans authorized by the 
CARES Act to be lent to small businesses and sole proprietors which met certain 
eligibility requirements and who were harmed by the economic effects of the COVID-
19 pandemic. During the fraud scheme, the defendant submitted loan applications to 
BMO Harris Bank, Signature Bank, and the SBA itself on behalf of entities that 
either did not exist, or existed nominally at some point in the past, but which were 
not in operation during (or harmed in any way by) the COVID pandemic. As to 
defendant Scott, those entities included EZ Link Golf LLC, and OLG Financing, Inc., 
neither of which existed at all; and Naper Montessori Academy, Inc., which may have 
been in varying degrees of operation in the past, but shuttered long before the time 
period alleged in the indictment. In those applications, Scott falsely and fraudulently 
represented the purported entities’ number of employees, gross revenues, payroll, 
operating expenses, and very existence as companies with ongoing operations. 
As an example of the egregious nature of Scott’s conduct, in addition to willfully 
filling out materially false information on the PPP and EIDL loan applications in 
order to get free money from the government, on at least one occasion, Scott stole 
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checks from a legitimate entity in order to buttress the legitimacy of one of his fake 
operations. As described in the U.S. Secret Service report attached hereto as Exhibit 
1, Scott likely broke into a locked mailbox of a legitimate company called EZLinks 
Golf Holdings LLC, stole a check issued to this small business by a customer (in this 
case, Eastern Kentucky University), and attempted to deposit (then withdraw) that 
check into his fake EZ Link Golf account at Credit Union One, which promptly flagged 
the check as “altered/fictitious”. 
Bank records reflect that, as was common in the COVID fraud schemes which 
were so pervasive during the pandemic, Scott and Brown spent the PPP and EIDL 
loan proceeds on personal expenses, such as large retail purchases at Tiffany & Co. 
and Jared’s Galleria jewelry stores in Orland Park; high ends stores such as Von 
Maur, Nordstrom, and Saks Fifth Avenue; and to purchase Uber Eats. But primarily, 
the funds were withdrawn in large, frequent ATM withdrawals drawing on the bank 
accounts in the name of the sham businesses Scott listed on the loan papers, and 
through large cash transfers between accounts owned by Scott and his wife. 
As described in the PSR and documented in the spreadsheet addendum to the 
Government’s Version of the Offense (GVO), the “actual loss” amount attributed to 
Scott is $567,333. PSR ¶¶ 16, 17, 30. This loss stems from loans actually funded by 
BMO Harris bank (for PPP loans) and the SBA (for EIDL loans). However, as detailed 
in the GVO and adopted in the PSR, the “intended loss” figure is much greater.1 When 
 
1 Note (A) to Guideline § 2B1.1(b) governing loss amounts states that “loss is the greater of 
actual or intended loss.” This note reflects the Sentencing Commission’s reasoning that 
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accounting for loan applications that Scott either submitted himself or were tied to 
bank accounts he created to perpetuate his fraud scheme that were never funded—
either because they were flagged for fraud or withdrawn—the intended loss amount 
balloons to nearly $1.9 million in funds Scott and his wife attempted to fraudulently 
obtain at the expense of individuals suffering during COVID-19. Id. ¶¶ 17, 31. 
II. 
SENTENCING GUIDELINES CALCULATIONS 
A. 
Offense Level Calculation  
The government agrees with the offense level calculations set forth in the PSR 
recommended by Probation. In that regard, the government notes that the parties’ 
plea agreement did not contemplate a two-level enhancement under Guideline § 
2B1.1(b)(1)(A).2 Indeed, as alleged in the indictment, three of the five entities the 
defendants used to perpetuate their fraud scheme were “educational organizations” 
as contemplated by the § 2B1.1(b)(1)(A) enhancement—Little Shepherd’s Academy, 
Little Shepherd’s Beginners, and Naper Montessori Academy, the last of which is 
noted in the PSR. PSR ¶ 32. See Indictment (R. 1), ¶  3. 
The government additionally notes that, while the parties’ plea agreement did 
not contemplate it and the government inadvertently neglected to include 
information supporting it in its GVO, the Court could arguably also apply an 
additional two-level enhancement for obstruction of justice under Guideline § 3C1.1. 
 
intended loss is as important, if not more important, than actual loss for the purpose of 
fashioning an adequate sentence. 
2 The PSR cites Guideline § 2B1.1(b)(9)(B) (¶ 32) but the government respectfully suggests 
that the correct citation is to subsection (A). 
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In that regard, the government submits herewith as Exhibit 2 an additional law 
enforcement report detailing Scott’s efforts to intimidate the former U.S. Secret 
Service case agent Lydia Sizemore in May 2021, by, among other methods, calling 
her repeatedly and texting her “Hello…Yooooo…Let me do some more 
digging…Secret Service…Lydia Sizemore.” A screenshot from Agent Sizemore’s 
government issued cell phone obtained near the date of the incident is below: 
 
See Ex. 2 at 2. The PSR also refers to this incident. PSR ¶ 23. 
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Adopting the PSR’s recommended enhancements and the loss calculations set 
forth in the PSR and the GVO, the base offense level is 7, there is a 16-level increase 
for a loss amount between $1,500,000 and $3,000,000, another two-level increase 
under Guideline § 2B1.1(b)(1)(A) as described above, and a three-level decrease for 
acceptance of responsibility under Guideline § 3E1.1(a). Id. ¶¶ 29-40. The total 
offense level—without including an enhancement for obstruction of justice—is 
therefore 22. Id. ¶ 41. 
B. 
Criminal History 
The plea agreement and the PSR set forth Scott’s criminal history. PSR ¶¶ 48-
71. He has five scoreable convictions for a total of 13 criminal history points, in 
addition to 16 convictions that do not score. Id. His criminal history category is VI. 
Id. ¶ 69-70.  
C. 
Advisory Guidelines Range 
With a total offense level of 22 and a criminal history category of VI, the 
resulting advisory Guidelines range is 84-105 months of imprisonment. Id. ¶ 141. 
III. 
§ 3553(A) FACTORS AND GOVERNMENT’S RECOMMENDATION 
Considering the factors set forth in 18 U.S.C. § 3553(a), the government 
recommends a sentence a within-Guidelines sentence of 96 months of imprisonment.   
Such a sentence is sufficient, but not greater than necessary, to reflect the seriousness 
of Scott’s offense conduct; to account for his long criminal history and other 
characteristics; and to promote respect for the law, provide just punishment, and 
afford adequate deterrence. 
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A. 
The Nature and Circumstances of the Offense 
The offense conduct in this case is incredibly serious. The defendant and his 
wife took advantage of an emergency federal program intended to help individuals 
and small business owners financially devastated by COVID-19. That is, during what 
was almost certainly one of the most vulnerable periods of their lives. Scott knowingly 
and willfully filled out and submitted numerous loan applications to banks and 
government agencies for emergency funds for companies that he knew did not exist. 
Per the spreadsheet the government submitted along with its GVO, Scott applied for 
no fewer than 20 EIDL loans and 7 PPP loans during the course of the scheme causing 
actual losses to the victims of over half a million dollars, and intended loss of nearly 
$2 million. This offense was not a simple lapse in judgment, or a crime born out of 
economic poverty or necessity. It was, at least, a year-long scheme to fraudulently 
obtain free money from the government. To further the scheme, Scott employed 
tactics like stealing checks and trying to intimidate federal agents investigating him 
by obtaining information from bank insider. Ex. 2, PSR ¶ 23. In short, Scott’s conduct 
was as brazen as it was harmful to the public. The Court should consider all of this 
conduct in fashioning a sentence under § 3553(a). 
B. 
Scott’s History and Characteristics  
The PSR and the Sentencing Recommendation describe in detail the 
defendant’s long and serious criminal history, which includes two federal convictions 
in this same courthouse for fraud, and a third conviction for identity theft in Will 
County. PSR ¶¶ 58, 63, 65. Scott also has multiple convictions for aggravated 
unlawful use of a weapon, battery, and driving under the influence. Id. passim. Scott 
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currently owes restitution of nearly $160,000 and has multiple outstanding liens 
against him, id. ¶¶ 58, 63, 136; and continues to maintain as of the date of the PSR 
that he is employed by a company—Opulent Credit Builders—that by all indicators 
is fraudulent, and, ironically, purports to run credit counseling services—a claim 
which is unverified. Rec. at 2-3; PSR ¶ 129.3 All of these facts are aggravating, and 
the Court should consider them as such. 
In mitigation, the defendant has admitted to his conduct and saved the 
government the time and expense in preparing for trial. Scott sat for two proffer 
sessions with law enforcement, and offered to sit for a third during the course of this 
case. The government respectfully suggests that it does not glean any additional 
mitigation in the defendant’s history and characteristics as described in the PSR. 
 Put simply, Scott’s crime was motivated by greed. He used stolen funds for 
personal expenses and to purchase luxury items; in other words, to enrich himself 
and his wife and the expense of individuals who legitimately needed emergency 
government funds during a global catastrophe. Unfortunately, this egregious conduct 
does not seem to be an aberration for this defendant, but rather the culmination of a 
history rife with white collar, and other, crime. 
 
3 The government notes that defendant has submitted 7 PPP and/or EIDL applications for 
companies using variations of the theme “Opulent”—which is the name of Scott’s purported 
credit repair service. See Addendum to GVO. 
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C. 
The Seriousness of the Offense, Need to Promote Respect for the 
Law, Afford Adequate Deterrence, and Protect the Public 
A within-Guidelines sentence is necessary to reflect the seriousness of the 
offense, promote respect for the law and provide adequate deterrence to prevent 
recidivism.  See 18 U.S.C. § 3553(a)(2)(B).  
The duration of the scheme and the sheer number of false loan applications 
that Scott submitted demonstrate a lack of respect for the law and highlight the 
serious nature of the offense. The Guidelines range of 84-105 months of imprisonment 
appropriately addresses the intended loss amount, the aggravating factors described 
in the PSR and this memorandum, Scott’s criminal history, and his Scott’s assistance 
to the government and acceptance of responsibility. Given Scott’s repeated serious 
criminal violations, see Rec. at 3, the government believes a sentence of 96 months’ 
imprisonment is sufficient, but not greater than necessary, to incapacitate Scott from 
continuing to commit this fraudulent activity, to deter him from further criminal 
activity, and to generally deter the public from engaging future public benefits fraud, 
especially in a time of national need. 
Indeed, a below-Guidelines sentence would not promote a respect for the law, 
adequately reflect the seriousness of the offense, or provide general deterrence.  The 
Seventh Circuit has repeatedly concluded that white-collar criminals often “act 
rationally, calculating and comparing the risks and the rewards before deciding 
whether to engage in criminal activity.” United States v. Brown, 880 F.3d 399, 405 
(7th Cir. 2017) (quoting United States v. Warner, 792 F.3d 847, 860-61 (7th Cir. 
2015)); see also United States v. Schultz, 743 F. App’x 5, 9 (7th Cir. 2018) (finding 
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district court’s consideration of general deterrence in a wire fraud case “entirely 
appropriate”). Because white collar defendants often calculate the costs and benefits 
of their actions, “[t]hey are . . . ‘prime candidates for general deterrence.’” Brown, 880 
F.3d at 405 (quoting Warner, 792 F.3d at 860); see also United States v. Musgrave, 
761 F.3d 602, 609 (6th Cir. 2014) (“Because economic and fraud-based crimes are 
more rational, cool, and calculated than sudden crimes of passion or opportunity, 
these crimes are prime candidates for general deterrence.” (cleaned up).   
D. 
Supervised Release 
Consistent with the Seventh Circuit’s guidance in United States v. Thompson, 
777 F.3d 368 (7th Cir. 2015) and for the reasons set forth in Exhibit 3 hereto, the 
government agrees with the Probation Office’s recommendation for conditions for 
supervised release. See PSR pp. 36-42. The government recommends that the Court 
impose a term of supervised release of three years with the following recommended 
conditions. PSR ¶ 144, Rec. at 1. 
IV. 
FINE AND RESTITUTION 
The government does not disagree with Probation’s assessment of Scott’s 
financial condition, or that Scott likely has liabilities in excess of his assets. PSR ¶¶ 
131-39. However, based on the information available to the government, Scott 
continues to hold himself out as operating legitimate businesses, and as such, may 
possess assets in excess of what he has represented to Probation.4 Given this, the 
 
4 For example, as of the date of this memorandum, Scottland Development Corporation has 
a fully functional website and, as noted, is an incorporated state entity. See 
https://scottlanddevelopment.com/about/ (last accessed June 25, 2025). 
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government suggests that a fine may be appropriate. Id. ¶ 139. The government also 
believes that restitution in the amount of $567,000, or the total actual loss, is 
appropriate. As described in the plea agreement and provided for in 18 U.S.C. 
§ 3663A, this amount will be joint and several with any co-defendant found to be 
liable. Plea Agreement (R. 85) ¶ 13. 
V. 
CONCLUSION 
For the reasons above, the government respectfully requests that this Court 
impose a within-Guidelines sentence of 96 months of imprisonment and order a 
period of three years’ supervised release with the conditions proposed in the PSR. 
 
 
 
 
 
 
 
 
 
 
Respectfully Submitted, 
 
 
 
 
 
 
ANDREW S. BOUTROS 
 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
By: 
/s/Alejandro G. Ortega   
 
 
 
 
 
 
 
ALEJANDRO G. ORTEGA  
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
 
 
 
United States Attorney’s Office 
 
 
 
 
 
 
219 South Dearborn, 5th Floor 
 
 
 
 
 
 
Chicago, Illinois 60604 
 
 
 
 
 
 
(312) 353-4129 
 
 
 
 
 
 
 
 
Dated: June 25, 2025 
Case: 1:23-cr-00097 Document #: 92 Filed: 06/25/25 Page 11 of 11 PageID #:325

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