Sentencing Memorandum by USA as to Denise Sanders — USA v. Sanders et al. (Dkt. 253)

Record facts

U.S. District Court records for the Western District of Missouri and Western District of Washington · No. 4:24-cr-00029-BP · Doc. 253 · 2025-03-27 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA, 
 
 
 
 
 
Plaintiff, 
 
 
v. 
 
DENISE SANDERS, 
 
 
 
 
 
Defendant. 
 
 
 
 
Case No.  24-00029-03-CR-W-BP 
 
GOVERNMENT’S SENTENCING MEMORANDUM 
 
The United States of America, by and through its undersigned counsel, files its sentencing 
memorandum in this case. The presentence report calculated the sentencing range from zero to 
6 months and mandatory restitution of $20,833. (PSR ¶¶ 64 & 76) The government recommends 
a sentence of three years’ probation. 
PROCEDURAL AND FACTUAL BACKGROUND 
On December 17, 2024, Defendant Denise Sanders entered a plea of guilty to Count 1 
of the indictment, conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349, before 
Chief U.S. District Judge Phillips. (PSR ¶ 1.) The maximum possible penalty for conspiracy to 
commit wire fraud is 20 years’ imprisonment. The defendant’s offense conduct is outlined in 
paragraphs 4 through 9, and 12 of the PSR. 
The defendant was part of a group of individuals organized by her daughter, 
Daisha Sanders, 
to submit 
fraudulent 
Paycheck 
Protection 
Program 
(PPP) 
loans. 
Ms. Denise Sanders, aided by Daisha Sanders, submitted an application which claimed she was 
the sole proprietor of a business that had gross revenues of $144,080 and net income of $99,982 
in 2019. In fact, the defendant did not have such a business, and it did not have any revenues in 
Case 4:24-cr-00029-BP     Document 253     Filed 03/27/25     Page 1 of 3

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the year prior to the pandemic. On June 25, 2021, the defendant received a $20,832 PPP loan. 
On June 25 and 28, 2021, the defendant made wire transfers totally $4,000 transfer to 
Daisha Sanders. The defendant spent the remaining proceeds on personal expenses. 
DISCUSSION 
I. 
Sentencing Analysis 
There are no outstanding objections to the presentence report and, therefore, the offense 
level would be 7, Criminal History Category I, resulting in a guideline range of zero to 6 months. 
As this Court is aware, 18 U.S.C. § 3553(a) sets forth the factors to be considered in determining an 
appropriate sentence. In evaluating the appropriate sentence for this defendant, the United 
States notes the following: 
Nature of the offense: 
The defendant falsely applied for and received a $20,832 pandemic relief loan. These funds 
were intended to assist businesses that were impacted by the pandemic. While this amount is small 
compared to other pandemic relief fraud, the defendant should have been aware that this scheme 
was unlawful. 
The history and characteristics of the defendant: 
The defendant has no criminal history, no pending charges, and no “Other Arrests”. 
(PSR ¶¶ 36-42.) The defendant has a nursing degree and is employed at a rehabilitation center. 
Seriousness of the Offense, Deterrence, Protection, and Rehabilitation: 
This was a serious offense and there is a need to deter the defendant and others from 
fraudulently taking advantage of emergency relief funds. 
The issue presented to the Court then is what sentence is reasonable given the need to deter 
others who would engage in such illegal misappropriation of government emergency monies. 
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The United States suggests that a reasonable sentence would be a sentence of three years’ 
probation. 
A sentence within the guideline range would deter the defendant and send a message to 
others that such fraud schemes are unlawful and will be dealt with seriously by the United States 
District Court. 
Respectfully submitted, 
 
 
 
 
 
 
 
 
Jeffery P. Ray 
 
 
 
 
 
 
 
Acting United States Attorney 
 
 
 
 
 
 
 
By: 
/s/ Paul S. Becker 
 
Paul S. Becker 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
Fraud and Corruption Unit 
 
Charles Evans Whittaker Courthouse 
 
400 E. 9th Street, Suite 5510 
 
Kansas City, Missouri 64106  
 
CERTIFICATE OF SERVICE 
 
The undersigned hereby certifies that a copy of the foregoing was delivered on March 27, 
2025, to the Electronic Case Filing (CM-ECF) system of the United States District Court for the 
Western District of Missouri for electronic delivery to all counsel of record. 
 
 
 
 
 
 
 
 
/s/ Paul S Becker 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Paul S. Becker 
 
 
 
 
 
 
 
Assistant United States Attorney 
Case 4:24-cr-00029-BP     Document 253     Filed 03/27/25     Page 3 of 3

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