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Government's Sentencing Memorandum — United States v. Damisha Brown (Southern District of West Virginia)

Summary

The government's sentencing memorandum in United States of America v. Damisha Brown, Criminal No. 2:24-CR-00192-6, in the United States District Court for the Southern District of West Virginia, filed August 28, 2025 as Document 379. Submitted by Assistant United States Attorney Jonathan T. Storage under 18 U.S.C. § 3553(a), it asks the Court to impose a sentence of time served followed by a term of supervised release. It describes the defendant's history and characteristics, including education and work as a bartender, assisted living aid and ride share driver. It states that during the spring of 2021 the defendant aided and abetted Kisha Sutton to obtain a fraudulent Paycheck Protection Program loan by supplying personal information. The memorandum is signed s/Jonathan T. Storage.

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“Government's Sentencing Memorandum — United States v. Damisha Brown (Southern District of West Virginia).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/379-redacted-sentencing-memorandum-by-united-states-cc4ef6b8d8/, SHA-256 2ff22356dfdb2a61963ad765f34a3d67ccc27845a7c9d9fd03e0ec9945be1961.

Full text

Case 2:24-cr-00192     Document 379    Filed 08/28/25   Page 1 of 5 PageID #: 2484



                        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.
Case 2:24-cr-00192    Document 379     Filed 08/28/25    Page 2 of 5 PageID #: 2485



     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
                                        2
Case 2:24-cr-00192   Document 379   Filed 08/28/25   Page 3 of 5 PageID #: 2486
Case 2:24-cr-00192   Document 379   Filed 08/28/25   Page 4 of 5 PageID #: 2487




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




                                      4
Case 2:24-cr-00192   Document 379   Filed 08/28/25   Page 5 of 5 PageID #: 2488



                         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




                                     5


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