Sentencing Memorandum by USA as to Jeffery Chillis, II — USA v. Sanders et al. (Dkt. 265)

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. 265 · 2025-04-04 · 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. 
 
JEFFERY CHILLIS II, 
 
 
 
 
 
Defendant. 
 
 
 
 
Case No.  24-00029-07-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. On February 27, 2025, the defendant was arrested based 
upon his use of controlled substances in violation of his bond conditions. (Doc. 205 & 248.) The 
defendant has remained in custody since his arrest. The government recommends a sentence of 
time served with three years’ supervised release. The presentence report calculated the sentencing 
range from 4 to 10 months and restitution of $20,833. (PSR¶¶ 64 & 77.) 
PROCEDURAL AND FACTUAL BACKGROUND 
On November 21, 2024, Defendant Jeffery Chillis II pled guilty to Count One of the 
indictment, conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349. (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 5 - 10, and 17 of the PSR. 
The defendant was part of a group of individuals organized by Daisha Sanders to submit 
fraudulent Paycheck Protection Program (PPP) loans. Mr. Chillis, aided by Ms. Sanders, submitted 
an application which claimed he 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, 
Case 4:24-cr-00029-BP     Document 265     Filed 04/04/25     Page 1 of 4

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and it did not have any revenue in the year prior to the pandemic. On April 8, 2021, the defendant 
received a $20,832.50 PPP loan. On the same date, Mr. Nichols transferred $5,000 to Joel Wright, 
Daisha Sanders’ husband. 
DISCUSSION 
I. 
Sentencing Analysis 
The defendant has objected to the denial of a reduction for acceptance of responsibility. 
The defendant stated that he “has a written plea (sic) with the Government and has accepted 
responsibility by pleading guilty.” The plea agreement stated that the Government will recommend 
a two-level reduction for acceptance of responsibility “unless the defendant (1) fails to abide by 
all of the terms and conditions of this plea agreement and his pretrial release”. The defendant 
violated the conditions of his pretrial release after assuring the Court at the plea hearing that he 
would not use drugs. The defendant’s actions after the guilty plea support the denial of the 
reduction for acceptance of responsibility. Therefore, the offense level would be 9, Criminal 
History Category I, resulting in a guideline range of 4 to 10 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 $20,833 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. 
 
 
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The history and characteristics of the defendant: 
The defendant has no criminal record and appears to have been self-employed at the time 
of his arrest. (PSR ¶ 56.) 
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 is what sentence is reasonable given the need to deter 
others who would engage in such illegal misappropriation of government emergency monies and 
adequately punish the defendant considering his criminal record. 
A sentence of time served, approximately 2 months, with three years’ supervised release, 
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, 
 
 
 
 
 
 
 
 
Jeffrey 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 
 
 
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CERTIFICATE OF SERVICE 
 
The undersigned hereby certifies that a copy of the foregoing was delivered on April 4, 
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 
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