Docket 1:24-cr-00017-RSB-PMS-3 — Doc 496-0

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U.S. District Court for the Western District of Virginia · No. 1:24-cr-00017-RSB-PMS · Doc. 496 · 2024-12-26 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF VIRGINIA 
ABINGDON DIVISION 
UNITED STATES OF AMERICA 
) 
) 
) 
  Case No.: 1:24-CR-00017-003 
V. 
) 
) 
JONATHAN SCOTT WEBB 
) 
 
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 Jonathan Scott Webb (“J. Webb”) be sentenced to a term of 
incarceration of 41 to 51 months, followed by two 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 J. Webb’s conduct and role in the conspiracy to defraud the United 
States. See ECF No. 377; ECF No. 489 ¶¶ 7–21 & 104–130. This conduct resulted in the 
payment of $32,589 in unemployment benefits that J. Webb was ineligible to receive. 
ECF No. 489 ¶ 130. J. Webb is also responsible for $158,974 in benefits collectively 
received by codefendants Brian Addair, Josef Brown, Jeramy Farmer, Daniel Horton, 
Justin Meadows, Crytal Shaw (J. Webb’s girlfriend), Christopher Webb (J. Webb’s 
brother), and Terrence Vilacha, for a total loss amount attributable to J. Webb of 
$191,563. Id. ¶¶ 115, 130. 
 
The PSR correctly calculates J. Webb’s total offense level of 15 and criminal 
Case 1:24-cr-00017-RSB-PMS     Document 496     Filed 12/26/24     Page 1 of 3 
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history category of VI. Id.  ¶¶ 363, 378. J. Webb’s guideline imprisonment range is 41 
months to 51 months and the guideline range for a term of supervised release is 1 year to 
3 years. Id. ¶¶ 403, 406. 
 
J. Webb’s offense is a serious offense. 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, J. Webb contributed to the rampant and 
costly fraud that occurred during the COVID pandemic.  
J. Webb is 41 years old and his criminal history spans his entire adulthood, starting 
at age 19, and includes a drug distribution charge; burglary, larceny, and related crimes; 
assault and battery; and various other crimes. Id. ¶¶ 366-375. J. Webb and his brother, a 
co-defendant in this case, were raised by their parents in a stable domestic environment. 
His only health issues are anxiety and depression, for which he is prescribed medication. 
Id. 388-390. He has a history of abusing substances, including marijuana, opiates, 
benzodiazepines, cocaine, heroin, methamphetamine, and fentanyl. He has received 
suboxone and methadone treatment for his substance abuse in the past. Id. ¶¶ 391-398. J. 
Webb left high school in the tenth grade due to drug use, but eventually obtained his 
GED. He is skilled in masonry work. He previously owned a lawn care company and was 
a truck driver with a Class A Commercial Driver’s License until he lost that license after 
 
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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receiving a drug charge.  Id. ¶¶ 399-400.  
A sentence within the guideline range of 41 to 51 months would provide just 
punishment, promote respect for the law, deter J. Webb 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 December 26, 2024, 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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