Sentencing Memorandum as to Darrell Thomas filed by USA — USA v. Thomas et al. (Dkt. 464, N.D. Ga.)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 464 · 2022-05-04 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
v. 
DARRELL THOMAS 
 
Criminal Action No. 
1:20-CR-296-JPB 
 
United States’ Sentencing Memorandum 
The United States of America, by Ryan K. Buchanan, United States Attorney, 
and Tal C. Chaiken and Nathan P. Kitchens, Assistant United States Attorneys for 
the Northern District of Georgia, and Babasijibomi Moore, Trial Attorney for the 
United States Department of Justice, respectfully files this Sentencing 
Memorandum in advance of Defendant Darrell Thomas’s sentencing, which is set 
for May 9, 2022.  Defendant pleaded guilty to conspiracy to commit bank fraud 
and wire fraud in violation of Title 18, United States Code, Section 1349, and 
money laundering in violation of Title 18, United States Code, Section 1956.  As set 
forth below, the United States submits that a low-end Guidelines sentence of 235 
months is sufficient, but not greater than necessary, to comply with the purposes 
set forth in Title 18, United States Code, Section 3553(a). 
Unresolved Guidelines Issue – Aggravating Role 
 
 
For a four-level enhancement to apply, “‘section 3B1.1 requires the exercise 
of some authority in the organization, the exertion of some degree of control, 
influence, or leadership.’”  United States v. Robaina, 815 F. App’x 392, 397 (11th Cir. 
2020), quoting United States v. Martinez, 584 F.3d 1022, 1026 (11th Cir. 2009).  
Factors that courts consider in analyzing whether a defendant was an organizer or 
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leader include (1) the defendant’s exercise of decision-making authority, (2) the 
nature of the defendant’s participation in the commission of the offense, (3) the 
defendant’s recruitment of accomplices, (4) the defendant’s claimed right to a 
larger share of the fruits of the crime, (5) the degree of the defendants’ participation 
in the planning or organization of the offense, (6) the nature and scope of the illegal 
activity, and (7) the degree of control and authority the defendant exercised over 
others.  United States v. Shabazz, 887 F.3d 1204, 1222 (11th Cir. 2018).  “The 
leadership enhancement in § 3B1.1(a) applies even if the defendant led or 
organized only one person.”  United States v. Brackins, 711 F. App’x 491, 493–94 
(11th Cir. 2017). 
 
 
While Defendant objects to the PSR’s characterization that he “orchestrated” 
the Paycheck Protection Program (“PPP”) fraud scheme, he does not object to the 
underlying facts that establish his leadership role.  Specifically, the undisputed 
facts in the PSR show that: 
(1) 
Defendant is accountable for fourteen fraudulent loans (PSR, ¶ 147); 
(2) 
Defendant participated in the fabrication of supporting documents 
for each of the fraudulent PPP loans (see, e.g., PSR ¶¶ 92, 96, 104, 108, 
121, 125, 134, 138, 142, 145); and 
(3) 
A significant portion of the proceeds from every fraudulent PPP loan 
that received funding was sent to accounts that Defendant controlled 
(see, e.g., PSR, ¶¶ 88, 97, 101, 105, 109, 113–114, 118, 122, 126, 131, 135, 
139). 
These facts show Defendant’s involvement in the planning, organization, and 
commission of the offense, his claimed right to the largest share of the fruits of the 
crime, and the scope of his illegal activity. 
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Indeed, the evidence of Defendant’s leadership role is overwhelming.  First, 
Defendant directly or indirectly controlled and directed the other participants in 
the criminal activity.  For example, on April 25, 2020, Defendant emailed co-
defendant Ricky Dixon with the subject “Re: DParker Holdings Documents” and 
said “Have the February statement reflect 324k per month payroll.”  (Ex. 1 at 1.)  
Dixon responded, “Ok.”  (Id.)  Several weeks later, Dixon sent Defendant a 
fabricated February 2020 bank statement for D Parker Holdings, one of the 
businesses that obtained a fraudulent PPP loan.  (Id. at 3.)  Per Defendant’s 
instructions, the fabricated bank statement reflected two payroll payments for 
$162,440.38 each, for a total of $324,880.76 in payroll costs.  (Id. at 5.)  Defendant 
also directed co-defendant John Gaines to obtain fabricated bank statements for 
Gaines Reservation and Travel.  (See Ex. 2 (“I need 6 months states for gaines travel 
and mrs can you do it just like this one”).)  Further, Defendant directed an 
individual who has not been charged to recruit fake employees as part of the 
scheme.  (See Ex. 3 at 1 (“I need bodies also doing 1099 for employees and paying 
10k once loan closes looking for 100 people they have to be legit.”).     
 
 
Second, Defendant controlled and used fake email addresses to 
communicate with lenders regarding the fabricated PPP loans that were part of 
the scheme.  Records provided by Google show that various fake email addresses 
were linked by cookies to Defendant’s email address, meaning that those fake 
email addresses were accessed by the same device(s) as Defendant’s email 
address.  (See Ex. 4.)  Google records also show that several fake email addresses 
were “users” of Defendant’s Android device.  (See Ex. 5 at 1.)  Email records also 
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show instances where the fake email addresses received communications from 
lenders and forwarded them to Defendant.  (See, e.g., Ex. 6 at 1–2.)   
 
 
Third, each business that obtained a fraudulent PPP loan sent business 
documentation to Defendant.  (See, e.g., Ex. 7 (examples of business-related 
information sent to Defendant for three business).)  Defendant then fabricated 
documents to be submitted with each business’s PPP loan application, working 
with co-conspirators, including Teldrin Foster and Jesika Blakely, who sent the 
fabricated documentation to Defendant when it was complete.  (See, e.g., Ex. 8 
(examples of emails to Defendant that attached fabricated documents for various 
businesses).) 
That is, the evidence shows that Defendant was the mastermind of and 
central figure in this criminal scheme, which he does not dispute involved at least 
five participants.  He exercised decision-making authority over all aspects of the 
scheme, including the fabrication of documents, the submission of information to 
lenders, and the concealment of the proceeds.  These are precisely the 
circumstances to which a four-level enhancement applies.  See, e.g., United States v. 
Galindo, 798 F. App’x 524, 527 (11th Cir. 2020) (four-level enhancement applied 
where the defendant “exercised decision-making authority, recruited accomplices, 
claimed the largest share of fraud proceeds, and organized the offense”); United 
States v. Stinfort, 749 F. App’x 860, 863 (11th Cir. 2018) (four-level enhancement 
applied where the defendant recruited co-conspirators, organized their activities, 
and received a large portion of the fruits of the crime); Brackins, 711 F. App’x at 494 
(four-level enhancement applied where the defendant recruited individuals into 
the scheme and ordered individuals to create false affidavits, email accounts, and 
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fake cell phone bills and where the defendant “enjoyed a large share of the illicit 
gains from the conspiracy”).  The evidence flatly contradicts Defendant’s position 
that he was merely a participant in the criminal activity.  (See DE 462 at 1.)1 
A Guidelines Sentence is Necessary and Appropriate Under Section 3553(a) 
 
 
Contrary to Defendant’s argument, a sentence of 48 months’ imprisonment 
would not serve the purposes of Section 3553(a).  It would not reflect the 
seriousness of the offense or Defendant’s history and characteristics; would not 
provide sufficient specific or general deterrence; and would create unwarranted 
sentencing disparities.  The Court should impose a low-end Guidelines sentence 
of 235 months’ imprisonment.  
1. 
The Nature and Circumstances of the Offense. 
Defendant’s offense was serious, motivated by personal greed during an 
unprecedented global crisis.  In early 2020, the COVID-19 pandemic sent stock 
markets crashing and unemployment rates skyrocketing, while nationwide 
lockdowns ground the economy to a halt.  Many American businesses – and in 
particular, small businesses – struggled to stay afloat as consumer demand 
plummeted, creating daunting uncertainty for the businesses, their employees, 
and the families who rely on them.  Against that backdrop, Congress passed the 
PPP as one of the mechanisms for providing relief to small businesses and their 
 
1 Defendant’s argument raises serious concerns as to whether he fully accepts 
responsibility for his criminal conduct.  See, e.g., United States v. Tejas, 868 F.3d 
1242, 1248 (11th Cir. 2017) (“[A] defendant who falsely denies relevant conduct 
that the court determines to be true has acted in a manner inconsistent with 
acceptance of responsibility”); United States v. Gonzalez, 524 F. App’x 557, 562–63 
(11th Cir. 2013) (district court properly denied reduction for acceptance where the 
defendant “failed to truthfully admit his role in the . . . scheme”).   
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employees.  To obtain a loan, a business had to certify that the loan would be used 
to pay for payroll, lease or mortgage interest, or utilities, and the loan was 
forgivable if the business spent a certain percentage of the loan on payroll costs.   
Because Congress’s intent was to “provide relief to America’s small 
businesses 
expeditiously,” 
the 
PPP 
streamlined 
the 
Small 
Business 
Administration’s typical lending requirements.  Business Loan Program 
Temporary Changes; Paycheck Protection Program, 85 Fed. Reg. 20811-01 (Apr. 
15, 2020).  For example, the PPP “allow[ed] lenders to rely on certifications of the 
borrower in order to determine eligibility of the borrower and use of loan proceeds 
and to rely on specified documents provided by the borrower to determine 
qualifying loan amount and eligibility for loan forgiveness.”  Id.  These procedures 
were designed to quickly get much-needed funds to small businesses so they could 
keep their workers employed during an economic and public health crisis that 
threatened the viability of many small businesses and their ability to keep their 
employees on the payroll. 
Defendant sought to take advantage of the PPP’s streamlined procedures to 
line his own pockets.  Defendant was not a small business owner worried about 
his employees and the mouths they were responsible for feeding.  Rather, he saw 
in the PPP an opportunity to get free money to use for personal expenses.  And he 
did not just do so on behalf of his own business: Defendant convinced nearly two 
dozen others – most of whom had never been convicted of a crime – to join his 
fraudulent scheme.  While Defendant enabled these individuals to get free funding 
for themselves, he also required them to pay him significant sums for his 
“services,” further profiting at others’ expense.  In addition, not only did 
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Defendant’s actions result in the theft of taxpayer funds administered by the SBA, 
it also deprived legitimate business owners of the opportunity to obtain funding 
they desperately needed.     
There are several other aspects of Defendant’s offense that highlight its 
seriousness.  First, Defendant’s spending of the fraudulent proceeds he obtained 
reveals that his motive for committing the crime was greed.  For example, he used 
the stolen funds to purchase multiple luxury vehicles and jewelry.  (PSR, ¶¶ 81(S), 
93.)  Though he now claims that his “intent was to build a property” (PSR, ¶ 154), 
his spending shows otherwise.    
Second, Defendant’s fraud included at least fourteen fraudulent PPP loans 
submitted over the course of several months, and still other loan applications that 
were submitted but not approved.  Defendant’s offense did not result from a 
momentary lapse in judgment or a split-second decision made in the heat of the 
moment.  Rather, it was a calculated, methodical offense committed over a period 
of time.   
Third, Defendant displayed a significant degree of sophistication in 
executing the scheme.  For example, he used a legitimate payroll company – Rapid 
Pay Card – to launder the proceeds of the fraudulent PPP loans.  By doing so, he 
created the appearance that the businesses were legitimately spending the loan 
proceeds on payroll (an approved expense) such that they could attempt to obtain 
forgiveness of the loan.   
Fourth, Defendant’s offense involved the use of personal identifying 
information (including names, addresses, social security numbers, and dates of 
birth) of more than 100 individuals who served as purported “employees” of the 
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businesses and whose names were registered to payroll cards used to launder the 
fraud proceeds.  While it is likely that some of these individuals consented to their 
personal information being used for some purpose, the FBI interviewed one such 
individual who had not provided his personal information to anyone and had not 
consented to his personal information being used.             
2. 
The Defendant’s History and Characteristics. 
The Defendant’s history and characteristics support a Guidelines sentence.  
This is not the first time Defendant has committed a massive fraud; it is just the 
first time he was caught.  Specifically, before Defendant orchestrated his PPP fraud 
scheme, he committed a several million-dollar fraud scheme involving automobile 
loans, for which he has accepted responsibility as part of his plea in this case.  
Defendant’s years-long involvement in different fraud schemes is a significant 
factor for the Court’s consideration.   
The evidence in this case and in the PSR also shows that Defendant had 
every opportunity to avoid committing this offense and to instead choose the 
straight-and-narrow path.  He is educated, was raised in a loving home devoid of 
any kind of abuse, and had a supportive family.  Defendant’s background makes 
his choice to commit this offense – especially at this scale – inexplicable.  
Defendant’s apparent remorse and acceptance of responsibility do not 
warrant a downward variance.  Indeed, the Eleventh Circuit has recognized 
genuine remorse and low likelihood of reoffending as factors that “are usually 
present in most white-collar cases resulting in a guilty plea.”  United States v. Hayes, 
762 F.3d 1300, 1308 (11th Cir. 2014).  The Circuit warned, however, that those facts 
“cannot be seen in a vacuum and must be balanced against the other applicable 
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§ 3553(a) factors.”  Id. (vacating probationary sentence for white-collar offense as 
substantively unreasonable).  When considered in conjunction with the other 
Section 3553(a) factors – in particular, the nature and circumstances of the offense 
and the need to provide just punishment and afford adequate deterrence – 
Defendant’s history and characteristics do not support a non-Guidelines sentence.    
Defendant’s lack of criminal history likewise does not support a downward 
variance.  As the Sentencing Commission explains, “the lower limit of the 
guideline range for Criminal History Category I is set for a first offender with the 
lowest risk of recidivism.”  U.S.S.G. § 4A1.3, comment. (n.3).  Thus, a sentence at 
the low end of the Guidelines range – which is what the United States recommends 
in this case – already accounts for Defendant’s lack of criminal history and his lower 
risk of recidivism.  Indeed, for that reason, the Guidelines expressly prohibit “[a] 
departure below the lower limit of the applicable guideline range for Criminal 
History Category I.”  U.S.S.G. § 4A1.3(b)(2)(A) & comment. (n.3).  While the Court 
retains discretion to grant a variance (as opposed to a departure), a downward 
variance based on lack of criminal history is not appropriate for the same reasons 
that a downward departure is prohibited.   
3. 
The Need for Adequate Deterrence. 
A sentence within the Guidelines range is necessary to afford adequate 
deterrence – both specific and general – and to reflect the seriousness of the 
offense, promote respect for the law, and provide just punishment for the offense.  
18 U.S.C. § 3553(a)(2).   
Defendant’s conduct in this case reflects the need for specific deterrence.  As 
the facts in the PSR establish, Defendant continued engaging in money laundering 
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activities after his arrest in this case.  Indeed, Defendant laundered more than $2.48 
million through the Rapid Pay Card account after he had been released on bond, 
leading to the revocation of his bond.  (PSR, ¶ 151.)  That Defendant continued his 
criminal activities after being charged with very serious federal offenses and while 
under Court order not to commit additional crimes shows that a significant 
sentence is needed to deter him from engaging in criminal activity in the future.    
Moreover, the Eleventh Circuit has identified general deterrence as “an 
important goal of sentencing in a white-collar crime prosecution.”  United States v. 
Kuhlman, 711 F.3d 1321, 1328 (11th Cir. 2013); see also United States v. Howard, 28 
F.4th 180, 209 (11th Cir. 2022) (“General deterrence is more apt, not less apt, in 
white collar crime cases.”); United States v. McQueen, 727 F.3d 1144, 1158 (11th Cir. 
2013) (recognizing that general deterrence is one of the “‘key purposes of 
sentencing’”) (citation omitted).   
A sentence of 48 months would do little to dissuade Defendant or others 
from committing a similar crime in the future.  To the contrary, a lenient sentence 
would encourage would-be white-collar offenders to view a prison sentence as 
part of the cost of doing business.  This is especially so where, as is the case here, 
a significant portion of the fraudulent proceeds is unaccounted for and may be 
waiting for Defendant to enjoy after he completes his sentence.  Nor would a 
lenient sentence reflect the seriousness of fraudulently obtaining for personal gain 
more than $11 million intended for struggling small businesses and their 
employees in the midst of a global crisis.  Hayes, 762 F.3d at 1308 (collecting cases 
where the Eleventh Circuit has “set aside sentences of little to no imprisonment” 
in white collar cases “because they do not constitute just punishment for the 
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offense, do not promote respect for the law, and will not do much to deter similar 
activity by others”); see also United States v. Shah, 476 F. Supp. 3d 619, 623 (E.D. 
Mich. Aug. 4, 2020) (noting the seriousness of an offense that involved “bilk[ing] 
the government out of . . . funds that were earmarked to pay for the medical 
expenses of vulnerable and needy individuals”). 
As the Eleventh Circuit has recognized, deterrence is especially important 
in the context of crimes, like Defendant’s crime in this case, that “may easily go 
undetected and unpunished.”  See McQueen, 727 F.3d at 1158–59 (reversing the 
district court’s lenient sentence because it “sap[ped] the goal of general 
deterrence”); see also United States v. Engle, 592 F.3d 495, 502 (4th Cir. 2010) 
(explaining that because tax evasion offenses are infrequently prosecuted, 
“[w]ithout a real possibility of imprisonment, there would be little incentive for a 
wavering would-be evader to choose the straight-and-narrow over the wayward 
path); United States v. Heffernan, 43 F.3d 1144, 1149 (7th Cir. 1994) (“Considerations 
of (general) deterrence argue for punishing more heavily those offenses that either 
are lucrative or are difficult to detect and punish, since both attributes go to 
increase the expected benefits of a crime and hence the punishment required to 
deter it.”). 
A recent analysis found that approximately 12.3% of the PPP loans granted 
to small businesses, totaling $64.2 billion, have at least one indicator of potential 
fraud.  See John M. Griffin et al., Did FinTech Lenders Facilitate PPP Fraud? (Mar. 15, 
2022), available online at https://ssrn.com/abstract=3906395 (last visited May 4, 
2022).  And because of the sheer number of PPP loans as well as the streamlined 
documentation necessary to obtain them, the United States is unlikely to detect 
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and/or to prosecute most individuals who obtained fraudulent PPP loans.  The 
need for general deterrence is therefore significant in this case.   Simply put, the 
sentence that Defendant asks the Court to impose would signal to others 
considering engaging in white-collar crime that there is a significant benefit to be 
gained and little to be lost by committing the offense.  A below-Guidelines 
sentence would undermine, rather than promote, Section 3553(a)’s purposes.     
4. 
The Sentencing Commission’s Policy Statement. 
“In deciding a sentence, district courts should consider the policies behind 
the applicable guidelines provision.”  United States v. Crisp, 454 F.3d 1285, 1291 
(11th Cir. 2006); see also 18 U.S.C. § 3553(a)(5) (directing district courts to consider 
the Sentencing Commission’s policy statements).  For fraud-related offenses, the 
Sentencing Commission has explained that “along with other relevant factors 
under the guidelines, loss serves as a measure of the seriousness of the offense and 
the defendant’s relative culpability and is a principal factor in determining the 
offense level under [U.S.S.G. § 2B1.1].”  U.S.S.G. § 2B.1.1, comment. backg’d.  The 
Sentencing Commission’s policy statement supports imposing a Guidelines 
sentence in this case, where Defendant’s Guidelines are based largely on the 
amount of loss attributable to his offense and on sentencing enhancements that 
indisputably apply to his conduct.        
5. 
Unwarranted Sentencing Disparities. 
A Guidelines sentence would not create unwarranted sentencing 
disparities.  No other defendants who the Court has sentenced were similarly 
situated to Defendant.  Each of the defendants who have been sentenced were 
individual businessowners who obtained loans for their businesses, or recruiters 
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who recruited a businessowner to participate in the scheme.  None of those 
defendants played the role that Defendant played in the scheme, as described 
above.  While it is true that Defendant’s Guidelines range is “drastically higher 
than any other sentence received thus far by [Defendant’s] co-defendants” (see DE 
462 at 3), those co-defendants were each responsible for participating in one 
fraudulent PPP loan.  Defendant, on the other hand, orchestrated the entire scheme 
and is responsible for fourteen fraudulent PPP loans.  Where the Court has 
generally sentenced other defendants to the low-end of their applicable Guidelines 
ranges,2 a downward variance of 187 months for Defendant would create 
unwarranted sentencing disparities.   
6. 
The Need to Provide Restitution.   
The need to provide restitution does not weigh against imposing a 
Guidelines sentence.  As an initial matter, the Eleventh Circuit has rejected the 
argument that a large restitution award warrants a shorter custodial sentence.  See 
Crisp, 454 F.3d at 1291 (explaining that shortening a defendant’s sentence “in order 
to increase the time for the defendant to earn money to pay restitution” would 
turn the Sentencing Commission’s policy on its head because it would mean that 
the more loss a defendant inflicts, the shorter their sentence).  Moreover, the 
evidence shows that Defendant is unlikely to pay restitution because Defendant 
has engaged in a pattern of putting assets in others’ names, presumably to avoid 
their seizure or collection from him.  While Defendant’s restitution obligation is 
significant, the need to provide restitution does not outweigh Section 3553(a)’s 
other considerations – especially when considered in the context of the 
 
2 Defendant Charles Hill received a sentence of five years’ probation, with 27 
months of home confinement, because of his rare and incurable medical condition.  
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unlikelihood that Defendant will pay restitution – and does not warrant a 
downward variance.  
Conclusion 
 
 
For these reasons, the United States respectfully requests that the Court 
deny Defendant’s request for a downward variance and impose a sentence at the 
low end of the applicable Guidelines range. 
 
 
Dated: May 4, 2022.  
 
 
 
 
 
Respectfully submitted, 
 
RYAN K. BUCHANAN 
   United States Attorney 
 
 
TAL C. CHAIKEN 
Assistant United States Attorney 
Georgia Bar No. 273949 
 
NATHAN P. KITCHENS 
Assistant United States Attorney 
Georgia Bar No. 263930 
 
600 U.S. Courthouse 
75 Ted Turner Drive SW 
Atlanta, GA 30303 
404-581-6000; Fax: 404-581-6181 
 
SIJI MOORE 
  Trial Attorney, Fraud Section 
  U.S. Department of Justice 
Case 1:20-cr-00296-JPB-CMS     Document 464     Filed 05/04/22     Page 14 of 15

 
 
Certificate of Service 
The United States Attorney’s Office served this document today by filing it 
using the Court’s CM/ECF system, which automatically notifies the parties 
and counsel of record. 
 
May 4, 2022 
 
/s/ TAL C. CHAIKEN 
 
 
TAL CHAIKEN 
 
Assistant United States Attorney 
 
 
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