Docket 1:24-cr-00017-RSB-PMS-2 — Doc 628-0

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U.S. District Court for the Western District of Virginia · No. 1:24-cr-00017-RSB-PMS · Doc. 628 · 2025-05-01 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF VIRGINIA 
ABINGDON DIVISION 
UNITED STATES OF AMERICA 
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  Case No.: 1:24-CR-00017-002 
V. 
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CRYSTAL SAMANTHA SHAW 
) 
 
GOVERNMENT’S SENTENCING MEMORANDUM 
 
 
The United States of America, by counsel, having considered the facts and 
circumstances of this case, and the sentencing factors set forth in 18 U.S.C. §3553(a), 
respectfully recommends that Crystal Samantha Shaw (“Shaw”) be sentenced to a term of 
incarceration of 60 months, followed by three years of supervised release.  
 
At this time, the government does not intend to call any witnesses or present any 
exhibits. The Presentence Investigation Report (“PSR”) and Agreed Statement of Facts 
accurately describe Shaw’s conduct and central role in the conspiracy to defraud the 
United States. See ECF No. 389; ECF No. 627 ¶¶ 3–78. This conduct resulted in the 
payment of $34,650 in unemployment benefits that Shaw was ineligible to receive. ECF 
No. 627 ¶ 77. Shaw is also responsible for $262,507 in benefits collectively received by 
codefendants Josef Brown, Jonathan Webb, Brian Addair, Josef Brown, Jeramy Farmer, 
Daniel Horton, Justin Meadows, Jason Worley, Christopher Webb, Jeramy Farmer, Cara 
Bailey, Jessica Lester, Russell Stiltner, Joseph Hass, Clinton Altizer, and Terrence 
Vilacha, for a total loss amount attributable to Shaw of $297,157. Id. ¶¶ 78. 
 
The PSR calculates Crystal Shaw’s total offense level of 22 and criminal history 
Case 1:24-cr-00017-RSB-PMS     Document 628     Filed 05/01/25     Page 1 of 3 
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category of V. Id.  ¶¶ 367, 386. While the government failed to file an objection to the 
initial PSR, at the sentencing hearing the government intends to object to the PSR’s 
application of the Base Offense Level of 7, rather than 6 as stipulated in the parties’ plea 
agreement. See ECF No. 390. Application of the parties’ stipulated Base Offense Level of 
6 results in a Total Offense Level of 21, rather than 22. In either event, Shaw’s guideline 
imprisonment range is 60 months because the statutorily authorized maximum sentence 
of 5 years is less than the minimum of the applicable guideline range as calculated in the 
PSR or as calculated based upon the parties’ stipulation. ECF No. 627 ¶ 419.  The 
guideline range for a term of supervised release is 1 year to 3 years. Id. ¶ 422. 
 
Shaw’s offense is a serious offen. According to the United States Department of 
Labor, Virginia paid approximately $1.1 billion in fraudulent unemployment claims 
between April 1, 2020, and March 31, 2021.1 By participating and playing a central role 
in this conspiracy to defraud the United States, Shaw contributed to the rampant and 
costly fraud that occurred during the COVID pandemic.  
Shaw is 40 years old and his criminal history spans his entire adulthood, starting at 
age 23, and includes multiple drug and theft-related convictions. Id. ¶¶ 370-383. Shaw 
was primarily raised by her paternal grandparents as an only child. Id. ¶¶  401-402. She 
has two children with co-defendant Jonathan Webb. Id. ¶ 403. She is in good health but 
reports an extensive substance abuse history starting at age 18, including marijuana, 
 
1 Unemployment Insurance Payment Accuracy Datasets, U.S. Department of Labor, 
https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy/data (last 
visited Dec. 23, 2024).   
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methamphetamine, powder and crack cocaine, heroin, Vicodin, and fentanyl. She has 
received suboxone and methadone treatment for his substance abuse in the past. Id. ¶¶ 
406-413. Shaw graduated high school in 2003 and has worked in the past transporting 
individuals to their doctor’s appointments and as a pet groomer.  Id. ¶¶ 414-415.  
A sentence of 60 months would provide just punishment, promote respect for the 
law, deter Shaw and others from future criminal activity, and protect the public from future 
crimes of this defendant. Accordingly, the government submits that a sentence of 41 to 51 
months is sufficient but not greater than necessary and would serve the factors in § 3553(a). 
Respectfully submitted, 
 
 
 
 
 
ZACHARY T. LEE 
Acting United States Attorney 
 
 /s/ Danielle Stone  
Danielle Stone 
Assistant United States Attorney 
VA Bar No.: 84503 
United States Attorney's Office 
180 W. Main Street, Suite B-19 
Abingdon, VA 24210 
Telephone: (276) 628-4161 
  Facsimile: (276)628-7399      
  USAVAW.ECFAbingdon@usdoj.gov 
 
CERTIFICATE OF SERVICE 
I certify that on May 1, 2025, I electronically filed the foregoing Sentencing 
Memorandum with the Clerk of Court via the CM/ECF system, which will send 
notification of the filing to all counsel of record in this matter. 
/s/ Danielle Stone, VSB # 84503 
 
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