Factual Basis — United States v. Ransome (Dkt. 4, W.D.N.C.)

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The government's factual basis supporting the plea agreement of Joseph Ransome in United States v. Joseph Ransome, Docket No. 3:21-CR-00022-RJC-DSC, in the U.S. District Court for the Western District of North Carolina, filed January 26, 2021 as Document 4. It states that from in or about March 2020 until in or about July 2020, in relation to a benefit paid in connection with a presidentially declared major emergency, Ransome took part in a plan to defraud. It states that he applied over the Internet for fraudulent UI benefits in ten states, including North Carolina, New Jersey and Connecticut, and filed claims in his own name claiming non-existent employment and false reasons for termination. Defense counsel signs that the defendant does not dispute the factual basis.

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UNITED STATES DISTRICT COURT
                       WESTERN DISTRICT OF NORTH CAROLINA
                                  CHARLOTTE DIVISION

UNITED STATES OF AMERICA                   )
                                           )        DOCKET NO. 3:21-CR-00022-RJC-DSC
           V.                              )
                                           )        FACTUAL BASIS
JOSEPH RANSOME                             )
                                           )

       NOW COMES the United States of America, by and through R. Andrew Murray, United
States Attorney for the Western District of North Carolina, and hereby files this Factual Basis in
support of the plea agreement filed simultaneously in this matter.

       This Factual Basis is filed pursuant to Local Criminal Rule 11.2 and does not attempt to
set forth all of the facts known to the United States at this time. By their signatures below, the
parties expressly agree that there is a factual basis for the guilty plea(s) that the defendant will
tender pursuant to the plea agreement, and that the facts set forth in this Factual Basis are sufficient
to establish all of the elements of the crime(s). The parties agree not to object to or otherwise
contradict the facts set forth in this Factual Basis.

       Upon acceptance of the plea, the United States will submit to the Probation Office a
“Statement of Relevant Conduct” pursuant to Local Criminal Rule 32.4. The defendant may
submit (but is not required to submit) a response to the Government’s “Statement of Relevant
Conduct” within seven days of its submission. The parties understand and agree that this Factual
Basis does not necessarily represent all conduct relevant to sentencing. The parties agree that they
have the right to object to facts set forth in the presentence report that are not contained in this
Factual Basis. Either party may present to the Court additional relevant facts that do not contradict
facts set forth in this Factual Basis.

       1.     The defendant, JOSEPH RANSOME was a resident of Indian Trail, North
Carolina.

       2.     From in or about March 2020 and continuing until in or about July 2020, in the
Western District of North Carolina, and elsewhere, and in relation to and involving a benefit
authorized, transported, transmitted, transferred, disbursed, and paid in connection with, a
presidentially declared major emergency (as those terms are defined in section 102 of the Robert
T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5122), defendant JOSEPH
RANSOME did voluntarily and intentionally (1) participate in a scheme and artifice to defraud
with knowledge of its fraudulent nature and (2) obtain the money and property by means of false
and fraudulent pretenses, representations, and promises (collectively, “the scheme to defraud”).

        Case 3:21-cr-00022-RJC-DSC Document 4 Filed 01/26/21 Page 1 of 3

3. It was part of the scheme to defraud that RANSOME applied for fraudulent Ul
benefits in the States of North Carolina, New Jersey, Connecticut, Florida, Minnesota, New York,
Massachusetts, Maine, Washington, and Illinois, over the Internet.

4, It was further part of the scheme to defraud that RANSOME filed fraudulent claims
for unemployment insurance (UI) benefits in his own name claiming non-existent employment
and false reasons for termination, among other falsities.

a. For example, RANSOME falsely claimed to have been laid off from
Walmart in North Carolina due to COVID, when in truth he was laid off for misconduct.
RANSOME claimed prior employment at Target, BestBuy, Lowe’s, and Hobby Lobby,
among others, when he did not work for those companies. Further, RANSOME falsely
claimed he was laid off from some of these companies because he had been diagnosed
with COVID or due to lack of work because of COVID-19,. On some occasions,
RANSOME used a social security number and mailing address that did not belong to
him.

5. It was further part of the scheme to defraud that RANSOME directed that payments
of the fraudulent UI benefits be made to bank accounts or Green Dot cards under his control. For
example:

a. On or about March 26, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of North Carolina in his name falsely
claiming that he had been laid off from Walmart in North Carolina because of a diagnosis
of COVID-19. The fraudulent UI benefit claim directed that payments be made to a
NASA Federal Credit Union (NASA FCU) account ending *3832.

b. On or about March 28, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of New York in his name falsely
claiming prior employment at Walmart in that state. The fraudulent UI benefit claim
directed that payments be made to a NASA FCU account ending *3832 and a Wells
Fargo Bank (Wells Fargo) account ending *6251.

c. On or about March 29, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Illinois in his name falsely
claiming prior employment at Hobby Lobby in that state and that he had been laid off
because of a diagnosis of COVID-19. The fraudulent UI benefit claim directed that
payments be made to a NASA FCU account ending in *3832.,

d, On or about April 4, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Massachusetts in his name falsely
claiming prior employment at Walmart in that state. The fraudulent UI benefit claim
directed that payments be made to a NASA FCU account ending in *3832.

e, On or about April 5, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of New Jersey in his name falsely

Case 3:21-cr-00022-RJC-DSC Document 4 Filed 01/26/21 Page 2 of 3


claiming prior employment at Target in that state and that he had been laid off because of
a diagnosis of COVID-19. The fraudulent UI benefit claim directed that payments be
made to a NASA FCU account ending *3832 and a SunTrust account ending *2364.

f, On or about April 7, 2020, RANSOM submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Minnesota in his name falsely
claiming prior employment at Lowe’s in that state. The fraudulent UI benefit claim
directed that payments be made to a NASA FCU account ending *3832.

g. On or about April 30, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Washington in his name falsely
claiming prior employment at Costco Wholesale Corporation in that state. The fraudulent
UI benefit claim directed that payments be made to a NASA FCU account ending in
*3832 and a Wells Fargo account ending *6251.

h. On or about May 10, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Connecticut in his name falsely
claiming prior employment at Best Buy and that he had laid off because of a diagnosis of
COVID-19, The fraudulent UI benefit claim directed that payments be made to a NASA
FCU account ending in *3832 and a Wells Fargo account ending *6251.

6. RANSOME acted willfully and with the intent to defraud.

R. ANDREW MURRAY
UNITED STATES ATTORNEY

Caryn Finley f
ASSISTANT UNITED STA'PES ATTORNEY

Defendant’s Counsel’s Signature and Acknowledgment

I have read this Factual Basis, the Bill of Information, and the plea agreement in this case,
and have discussed them with the defendant. Based on those discussions, I am satisfied that the
defendant understands the Factual Basis, the Bill of Information, and the plea agreement. I hereby
certify that the defendant does not dispute this Factual Basis.

Mark Foster, Attorney forDefendant

Case 3:21-cr-00022-RJC-DSC Document 4 Filed 01/26/21 Page 3 of 3

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