Government's Sentencing Memorandum — Cameron P. Henderson — United States v. Renetta Golden-Larimore, et al. (W.D. Mo.)

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The government's sentencing memorandum for Cameron Henderson in Case No. 23-00098-04-CR-W-BCW, U.S. District Court for the Western District of Missouri, Western Division, filed 06/17/24 as Document 300 and signed /s/ Paul S. Becker, Assistant United States Attorney. It says Henderson pleaded guilty on January 4, 2024 to Count 5, wire fraud under 18 U.S.C. § 1343, as part of a group organized by Renetta Golden-Larimore to submit fraudulent PPP loan applications. According to the memo, his application claimed a sole proprietorship with gross revenues of $144,080 in 2019 that did not exist; he received a $20,832 PPP loan on June 11, 2021 and paid $2000 to Golden-Larimore. With a guideline range of 4 to 10 months and restitution of $20,832, the government recommends probation with a period of home confinement.

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IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA, 
 
 
 
 
 
Plaintiff, 
 
 
v. 
 
CAMERON HENDERSON, 
 
 
 
 
 
Defendant. 
 
 
 
 
Case No.  23-00098-04-CR-W-BCW 
 
GOVERNMENT’S SENTENCING MEMORANDUM 
 
The United States of America, by and through its undersigned counsel, files its sentencing 
memorandum in this case. The government recommends a sentence of probation with a period of 
home confinement. The presentence report calculated the sentencing range from 4 to 10 months 
and mandatory restitution of $20,832. 
PROCEDURAL AND FACTUAL BACKGROUND 
On January 4, 2024, Defendant Cameron Henderson entered a plea of guilty to Count 5 of 
the indictment, wire fraud, in violation of 18 U.S.C. § 1343, before U.S. Magistrate Judge Counts.  
On January 19, 2024, the district court accepted the defendant’s plea of guilty. (PSR ¶¶ 1&2.) The 
maximum possible penalty for wire fraud is 20 years’ imprisonment. The defendant’s offense 
conduct is outlined in paragraphs 4 through 20 of the PSR. 
The defendant was part of a group of individuals organized by Renetta Golden-Larimore 
to submit fraudulent Paycheck Protection Program (PPP) loans. Mr. Henderson, aided by 
Renetta Golden-Larimore, 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, and it did not have any revenues in the year prior to the 
Case 4:23-cr-00098-BCW     Document 300     Filed 06/17/24     Page 1 of 4

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pandemic. On June 11, 2021, the defendant received a $20,832 PPP loan.  On June 14, 2021, the 
defendant made a Zelle $2000 payment to Renetta Golden-Larimore, and 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 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 $20,832 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 one criminal history point for possession of marijuana, which continues 
to be an issue for the defendant.  
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.  
 
 
Case 4:23-cr-00098-BCW     Document 300     Filed 06/17/24     Page 2 of 4

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Sentencing: 
As noted by the Court in United States v. Anderson, 664 F.3d 758, 764-765 (8th Cir. 2012), 
the analysis for reviewing the reasonableness of a sentence is well-settled: 
We review substantive reasonableness for an abuse of discretion, “‘tak[ing] 
into account the totality of the circumstances, including the extent of any 
variance from the Guidelines range.’” United States v. Feemster, 572 F.3d 
455, 461 (8th Cir. 2009) (en banc) (quoting Gall v. United States, 552 U.S. 
38, 51, 128 S. Ct. 586, 169 L.Ed.2d 445 (2007)). If a sentence is outside of 
the Guidelines range, “we ‘may consider the extent of the deviation, but 
must give due deference to the district court’s decision that the § 3553(a) 
factors, on a whole, justify the extent of the variance.’” Id. at 461–62 
(quoting Gall, 552 U.S. at 51, 128 S. Ct. 586) “Just because we ‘might 
reasonably have concluded that a different sentence was appropriate is 
insufficient to justify reversal of the district court.’” Id. at 462 
(quoting Gall, 552 U.S. at 51, 128 S. Ct. 586). “‘[I]t will be the unusual 
case when we reverse a district court sentence ... as substantively 
unreasonable.’” Id at 464 (quoting United States v. Gardellini, 545 F.3d 
1089, 1090 (D.C. Cir. 2008)). 
 
As noted by Judge Colloton in his concurrence in United States v. Burman, 666 F.3d 
1113, 1120 (8th Cir. 2012) citing, Gall v. United States, 552 U.S. 38, 50-51, 128 S. Ct. 586 
(2007), the “proper measure of reasonableness under § 3553(a) is not whether the variance from 
an advisory guideline range is reasonable, but whether the ultimate sentence is reasonable in light 
of the § 3553(a) factors taken as a whole.” 
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. 
The United States suggests that a reasonable sentence would be probation with a period of home 
detention. 
 
 
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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, 
 
 
 
 
 
 
 
 
Teresa A. Moore 
 
 
 
 
 
 
 
United States Attorney 
 
 
 
 
 
 
 
By: 
/s/ Paul S. Becker 
 
Paul S. Becker 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
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 June 17, 
2024, 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 4:23-cr-00098-BCW     Document 300     Filed 06/17/24     Page 4 of 4

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