Government's Sentencing Memorandum — United States v. Damisha Brown (S.D. W. Va.)

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U.S. District Court, Southern District of West Virginia (Charleston) · No. 2:24-cr-00192 · Doc. 379 · 2025-08-28 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF WEST VIRGINIA 
CHARLESTON 
 
 
UNITED STATES OF AMERICA 
 
 
v. 
 
 
 
 
 
 
CRIMINAL NO. 2:24-CR-00192-6 
 
 
DAMISHA BROWN 
 
 
GOVERNMENT’S SENTENCING MEMORANDUM 
 
Comes now the United States of America, by Jonathan T. 
Storage, Assistant United States Attorney for the Southern 
District of West Virginia and submits this Sentencing Memorandum 
in aid of sentencing.  
I. 
SENTENCING FACTORS 
 
The United States offers the following analysis relating to 
the application of the sentencing factors enumerated in 18 U.S.C. 
§ 3553(a). As discussed below, the government requests that the 
Court impose a sentence of “time served,” to be followed by a term 
of supervised release.  
A. History and Characteristics of the Offender 
The defendant was born in New Jersey and is 32 years old. Her 
father resides in New Jersey and is employed in the construction 
industry. The defendant has had no contact with her mother in 
several years, and she rarely communicates with her brother and 
only sibling, who is 29 years old and is imprisoned.  
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The defendant was raised by her mother and stepfather until 
she was 15 years old. He father was imprisoned until that time, 
and the defendant went to live with her father and stepmother upon 
his release from prison.  
For several years, the defendant lived in the Southern 
District of West Virginia with her father. She is a graduate of 
South Charleston High School in Kanawha County, West Virginia.  
The defendant is single and has never been married. The 
defendant has 3 children, ages 13, 11, and 5.  
The defendant is healthy and reported no history of substance 
abuse. 
She obtained some college education, and she completed 
commercial drive license (“CDL”). The defendant did not complete 
her CDL exam.  
The defendant reported working nearly every day of the week: 
she is a bartender, assisted living aid, and ride share driver.  
B. Nature and Circumstances of the Offense 
 
During the spring of 2021, the defendant aided and abetted 
Kisha Sutton to obtain a fraudulent Paycheck Protection Program 
(“PPP”) 
loan 
through 
a 
federal 
COVID-19 
relief 
program 
administered by the U.S. Small Business Administration.  
The defendant supplied her personal information to her 
sister, who then passed it on to Kisha Sutton. At the time, Kisha 
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II. 
CONCLUSION  
 
The government submits that a sentence of “time served,” to 
be followed by a period of supervised release, would be sufficient 
but not greater than necessary to meet the purposes of sentencing. 
 
Respectfully submitted, 
 
LISA G. JOHNSTON 
Acting United States Attorney 
 
 
 
 
 
By: 
s/Jonathan T. Storage            
JONATHAN T. STORAGE 
Assistant United States Attorney 
WV State Bar No. 12279 
300 Virginia Street, East 
Room 4000 
Charleston, WV 25301 
Telephone: 304-345-2200 
Fax: 304-347-5104 
E-mail: Jonathan.Storage@usdoj.gov  
 
 
 
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CERTIFICATE OF SERVICE 
 
It is hereby certified that the foregoing “GOVERNMENT’S 
SENTENCING MEMORANDUM” has been electronically filed and service 
has been made on opposing counsel by virtue of electronic mail 
this the 28th day of August, 2025, to: 
 
Clayton T. Harkins, Esq. 
DINSMORE & SHOHL 
P.O. Box 11887 
Charleston, WV 25339 
Email: clayton.harkins@dinsmore.com 
 
 
 
 
s/Jonathan T. Storage            
JONATHAN T. STORAGE 
Assistant United States Attorney 
WV State Bar No. 12279 
300 Virginia Street, East 
Room 4000 
Charleston, WV 25301 
Telephone: 304-345-2200 
Fax: 304-347-5104 
E-mail: Jonathan.Storage@usdoj.gov  
 
 
Case 2:24-cr-00192     Document 379     Filed 08/28/25     Page 5 of 5 PageID #: 2488

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