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

Record facts

U.S. District Court for the Western District of Virginia · No. 1:24-cr-00017-RSB-PMS · Doc. 3 · 2024-05-21 · Docket on CourtListener

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CLERK'S OFFICE U.S. DISTRICT COURT 
AT ABINGDON, VA 
FILED 
UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF VIRGINIA 
ABINGDON DIVISION 
MAY 2 1 2024 
. ~'ff!Jjl'Jbfn~RK 
BY."U,_a 
DEPUTY CLERK 
UNITED STATES OF.AMERICA 
v. 
JOSEF LUDWIG BROWN 
CRYSTAL SAMANTHA SHAW 
JONATHAN SCOTT WEBB 
CHRISTOPHER KIRK WEBB 
STEPHANIE AMBER BARTON 
HALEIGH MCKENZIE WOLFE 
TERRENCEBROOKSVILACHA 
CARA CAMILLE BAILEY 
JESSICA DAWN LESTER 
BRIAN EDWARD ADDAIR 
RUSSELL ERIC STILTNER 
JOSEPH FREDERICK HASS 
DANIEL WAYNE HORTON 
JUSTIN WARREN MEADOWS 
JASON DALE WORLEY 
JERAMY BLAKE FARMER 
CLINTON MICHAEL ALTIZER 
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INDICTMENT 
INTRODUCTION 
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The Grand Jury charges that: 
Case No. /:,2L/,c.,- 11 
Violations: 
18 u.s.c. § 371 
18 U.S.C. § 1040(a) 
1 
18 u.s.c. § 1349 
CARES Act and Pandemic Unemployment Benefits 
1. Unemployment Insurance (UI) is a state-federal program that provides 
monetary benefits to eligible lawful workers. Although state workforce agencies 
administer their respective UI programs, they must do so in accordance with federal laws 
and regulations. UI payments (benefits) are intended to provide temporary financial 
assistance to lawful workers who are unemployed through no fault of their own. Each 
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state sets its own additional requirements for eligibility, benefit amounts, and length of 
time benefi~s can be paid. Gener~lly, UI weekly benefit amounts are based on a 
percentage of e·amings over a base period. In the Commonwealth of Virginia, the 
Virginia Employment Commission ("VEC") administers the UI program. 
2. On March 13, 2020, the President of the United States declared the ongoing 
Coronavirus Disease (COVID-19) pandemic to be an emergency under §501(b) of the 
Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C §§ 5121-
5207). • 
3. On March 18, 2020, the President signed the Families First Coronavirus 
Response Act ("FFCRA") into law. The FFCRA provided additional .flexibility for state 
UI agencies and additional administrative funding to respond to the COVID-19 
pandemic. Then, the Coronavirus Aid, Relief, and Economic Security ("CARES") Act 
was signed into law on March 27, 2020. The CARES Act expanded states' ability to • 
provide assistance to many workers impacted by COVID-19, including for workers who 
are not ordinarily eligible for UI benefits. The CARES Act provided for three new 
temporary UI programs, including Pandemic Unemployment Assistance ("PUA"), 
Pandemic Emergency Unemployment Compensations ("PEUC"), and Federal Pandemic 
Unemployment Compensation ("FPUC"). 
4. The first program, PUA, provided for up to 39 weeks of benefits to individuals 
who are: (I) self-employed, seeking part-time employment, or otherwise would not 
qualify for regular UI or extended benefits under state or federal law or PEUC under 
section 2107 of the CARES Act; and (2) unemployed, partially unemployed, unable to 
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work, or unavailable to work due to specific COVID-19 related reasons(s). Coverage 
' includes individuals who have exhausted all rights to regular UC or extended benefits 
under state or federal law or under PEUC. Under the PUA provisions of the CARES Act, 
a person who is a business owner, self-employed worker, independent contractor, or gig 
worker can qualify for pandemic unemployment benefits administered by the VEC if 
he/she previously performed such work in Virginia and is unemployed, partially 
unemployed, unable to work, or unavailable to work due to a COVID-19 related reason. 
PUA claimants must answer specific questions to establish their eligibility for PUA 
benefits. Claimants must provide their name, Social Security Number, and mailing 
address and self-certify that they meet one of the CO VID-19 related reasons for being 
unemployed, partially unemployed, or unable or unavailable to work. Initially, the 
eligible timeframe to receive PUA was from weeks of employment beginning on or after 
January 27, 2020, through December 31, 2020. The second program, PEUC, initially 
provided for up to 13 times the individual's average weekly benefit amount to individuals 
who ha~e exhausted regular UI under state or federal law, have no rights to regular UI 
under any other state or federal law, are not receiving UI under the UI laws of Canada, 
and are able to work, available for work, and actively seeking work. However, states 
must offer flexibility in meeting the."actively seeking work" requirement if individuals 
are unable to search for work because of COVID-19, including because of illness, 
quarantine, or movement restriction. The eligible timeframe to receive PEUC was from 
weeks of unemployment beginning after the respective state has an established agreement 
with the federal government through December 31, 2020. The earliest being April 5, 
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2020. 
5. The third program, FPUC, provide individuals who were collecting regular UI, 
PEUC, PUA, and several other forms of benefits with an additional $600 per week. The 
eligible timeframe to receive FPUC was from weeks of unemployment beginning after· 
April 5, 2020, or the date the respective state had an established agreement with the 
federal government, whichever was later, through July 31, 2020. 
6. On August 8, 2020, after FPUC expired, the President signed a Presidential 
Memorandum author.izing FEMA to use disaster relief funds pursuant to Section 408, 
Other Needs Assistance, of the Robert T. Stafford Relief and Emergency Assistance Act, 
42 U.S.C. §§ 5121-5207, to provide supplemental payments,for lost wages to help ease 
the financial burden on individuals who were unemployed as a result of COVID-19. The 
"Lost Wages Assistance Program" ("L W AP") served as a temporary measure to provide 
an additional $300 per week via a total of$44 billion in FEMA funds. The period of 
assistance for LWAP was August 1, 2020,. to December 27, 2020, or termination of the 
program, whichever was sooner. 
7. Then, on December 27, 2020, the Consolidated Appropriations Act, 2021-an 
omnibus spending bill that included an estimated additional $200 billion in funding for 
pandemic related UI programs-was signed into law. Through a section titled the 
Continued Assi.stance for Unemployed Workers Act of 2020 ("Continued Assistance 
. Act"), Congress extended and modified the three temporary UI programs created by the 
CARES Act and created a new benefit program. 
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8. The Continued Assistance Act increased the duration and availability of both 
PEUC, which p~ovides benefits to individuals who have exhausted their state 
unemployment benefits, and PUA, which provides unemployment compensation to 
independent contractors and others unable to access traditional UI benefits. Specifically, 
the Continued Assistance Act extended PEUC and PUA through March 14, 2021. 
Additionally, the duration of PUA benefits for eligible individuals was effectively 
extended from 39 weeks under the CARES Act to a total of 50 weeks; the amount of 
PEUC benefits for eligible individuals was extended from-13 to 24 times the individual's 
, average weekly benefit amount. FPUC was reauthorized at a lesser amount of $300 per 
week for weeks of unemployment beginning after December 26, 2020,- through March 
14, 2021. FPUC benefits remain unavailable for the gap between its expiration in the 
CARES Act (July 31, 2020) and its reauthorization in the Continued Assistance Act 
(December 26, 2020). 
9. On March 11, 2021, as the relief benefits authorized by the Continued 
Assistance Act were about to expire, the President signed the American Rescue Plan Act 
of 2021, which included an estimated $203 billion in additional relief, including 
reauthorization of PUA, FPUC, PEUC, and MEUC. Under the Americ'an Rescue Plan 
Act, PUA and PEUC were extended, without interruption, to weeks of unemployment 
ending on or before September 6, 2021, thereby allowing eligible individuals to collect 
PUA and PEUC benefits for an additional 29 weeks (79 weeks total for PUA and 53 
times the individual's average weekly benefit amount for PEUC). However, there are 25 
weeks between the w:eek ending March 13, 2021, and the last payable week of September 
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4, 2021,,making it unlikely that individuals would exhaust their full entitlement before 
the two programs expire. Additionally, the $300 FPUC benefit was extended through 
September 6, 2021. 
IO.According to data maintained by the U.S. Department of Labor-Employment 
and Training Administration, SW As requested and received approximately $427 billion 
in CARES Act funding related to PUA, FPUC~ and PEUC benefit payments. In total, it is 
estimated that as of September 2021, the federal government's response to the COVID-
19 pandemic will have included approximately $872.5 billion in pandemic related UI 
funding for state welfare agencies ("SW A") to _administer for individuals who have been 
impacted by COVID-19. 
11. Regardless of which of the three programs described above was involved ( that 
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is, whether PUA, PEUC, or FPUC), funds were distributed to program participants by 
I 
VEC. These funds were received by VEC from the United States Department of the 
Treasury (Treasury) through Treasury's program entitled Automated Standard 
Application for Payments, commonly referred to as "ASAP." ASAP is an electronic 
system that federal agencies use to securely transfer money to reciptent organizations. 
Federal agencies enroll recipient or'ganizatioris, authorize their payments, and manage 
their accounts. Recipient organizations then request payments from these pre-authorized 
accounts. Recipient organizations may include state and local governments, educational 
and financial institutions, vendors and contractors, profit and non-profit entities, and 
Indian tribal organizations. ASAP is free for both federal agencies and recipient 
organizations. 
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12. The PUA, FPUC, and LW AP programs (collectively, "pandemic 
unemployment benefits") are administered by the various states, including the 
Commonwealth of Virginia, but their benefits are funded by' the federal government. In 
,, 
order to receive pandemic benefits, an applicant must access a website maintained and 
administered by the VEC and file a claim. Separate claims are not filed for PUA, FPUC, 
and L W AP. Rather, a single claim for PUA, if approved, results in an approved claim for 
the additional FPUC and L W AP benefits as well. 
13. Individuals are only eligible for pandemic unemployment benefits if they are 
unemployed for reasons related to the COVID-19 pandemic and are otherwise available 
to work and are seeking employment. 
14. To apply for pandemic unemployment benefits via the VEC website, the 
applicant is required to enter Personally Identifiable Information ("PII") including name, 
date of birth, Social Security Number, email address, phone number, and physical 
address. An applicant is then required to answer a series of questions to determine 
eligibility and payment amount. An applicant must then attest, under penalty of perjury, 
that the information provided in the claim application is true and accurate. 
15. Upon completion, the application is submitted to the VEC. If approved, the 
applicant can choose whether to have the pandemic unemployment benefits deposited 
' 
directly into a bank account of the applicant's choosing, or the funds can be loaded on a 
pre-paid debit card which is then shipped to the applicant via United States Postal Service 
to the address listed on the application. 
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16. The recipient of pandemic unemployment benefits receives a unique Personal 
Identification Number ("PIN") to access the VEC each week to recertify their 
unemployment status. Payments for pandemic unemployment benefits are based on a 
seven-day period, from Sunday through Saturday. Thus, the benefits' recip~ent must 
. 
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certify every seven days that the recipient: was ready, willing and able to work each day; ' 
was seeking full time employment; did not refuse any job offers or referrals; and had 
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·reported any employment during the week-and the gross pay or other payments received. 
17. The Southwest Virginia Regional Jail Authority - Haysi is located in Haysi, 
Virginia, in the Western District of Virginia. 
18. Tazewell County, Virginia, is in the Western District of Virginia. 
The Scheme 
19. In March 2020, Josef Ludwig BROWN ("BROWN"), Jonathan Scott WEBB 
("JONATHAN SCOTT WEBB or J. WEBB"), and Crystal Saman~ha SHAW ("SHAW") 
developed a scheme and artifice to file fraudulent claims for pandemic unemployment 
benefits via the VEC website. The scheme and artifice was to submit claims for each co-
conspirator, eachjneligible to receive pandemic unemployment benefits, by making 
materially false representations including, but not limited to: the applicant was 
unemployed as a result of COVID-19 and the applicant was ready, willing, and able to 
work each day. 
20. Because pandemic unemployment benefits were paid on a weekly basis, the 
scheme was a continuing scheme whereby SHAW and her co-conspirators agreed and 
conspired to file weekly recertifications for the claims they submitted. In so doing, 
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SHAW reverified and recertified the same materially false representations and pretenses 
as stated above for each claim submitted, on numerous occasions over the course of the 
conspiracy. 
21. Co-conspirators fall into two general categories: 1) inmates at the SWVRJA-
Haysi who passed on PII to SHAW by BROWN and J. WEBB so that SHAW could file 
fraudulent claims; and 2) personal friends or acquaintances of BROWN, SHAW, and/or 
J. WEBB who provided their PII so that SHAW could file their fraudulent claims 
22. Co-conspirators did numerous acts, including, but not limited to, the following 
acts: 
a. At the time the scheme was devised, BROWN was incarcerated at the 
Southwest Virginia Regional Jail Authority - Haysi (SWVRJA-Haysi). BROWN 
provided his PII to SHAW via email and telephone for the purpose of filing a fraudulent 
claim. SHAW then filed a fraudulent claim on behalf of BROWN. 
b. In furtherance of the scheme, BROWN obtained PII of incarcerated co-
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conspirators at SWVRJA-Haysi and provided their PII to SHAW to _submit fraudulent 
claims or fraudulent recertifications for pandemic unemployment benefits on their behalf. 
c. Co-conspirators who were not incarcerated at the time of their filing 
provided their PII to SHAW, BROWN, and/or J. WEBB for the purpose of filing their 
fraudulent claims. 
d. Some co-conspirators filed their initial claims prior to incarceration, 
but, once incarcerated, provided their PII to SHAW in order for her to fraudulently file 
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• VEC claim recertifications concerning their eligibility to work. These individuals were 
ineligible to file pandemic unemployment claims during periods of incarceration. 
e. Each co-conspirator listed in this indictment conveyed his/her PII to 
SHAW, directly or indirectly through other co-conspirators, for the purpose of filing a 
fraudulent claim for pandemic unemployment benefits. With the assistance of the co-
conspirators listed herein, SHAW filed at least 21 fraudulent claims or recertifications of 
eligibility for pandemic unemployment benefits. 
f. In filing the fraudulent claims, SHAW used the same address of the 
residence in which she lived: 220 Bellwood Road, Raven, VA 24639, for 11 of the co-
. 
\ 
conspirators' applications, ensuring pre-paid debit cards used to disburse pandemic 
• unemployment benefit payments were sent to SHAW. SHAW also utilized the address of 
BROWN, 155 Dark Hollow Road, North Tazewell, VA 24630, for at least 4 of the co-
conspirators' applications; at that time, BROWN was incarcerated at SWVRJA-Haysi 
and did riot have access to collect any mail generated as a result of the fraudulent claims 
or recertifications. 
g. Once claims were approved, the VEC mailed via United States Postal 
Service monetary determination letters, Personal Identification Number (PIN) codes, and 
pre-paid debit cards in all co-conspirators' .names to the Bellwood Road and Dark Hollow 
Road addresses, in addition to other addresses where the ~o-conspirators previously 
resided, as listed on the applications. 
h. In order to continue receiving weekly pandemic unemployment benefits, 
SHAW made subsequent weekly recertifications on the respective co-conspirator's 
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behalf. SHAW filed claims by electronically accessing the VEC website'from her 
computer while at home in Tazewell, VA, or via telephone communication directly with 
the VEC. 
COUNT ONE 
(18 U.S.C § 371 - Coiispiracy to Defraud the United States) 
The Grand Jury charges that: 
1. The information in the Introductio.n is realleged and incorporated by reference. 
2. Between on or about March 15, 2020, and on or about September 30, 2021, in 
the Western District of Virginia and elsewhere, JOSEF LUDWIG BROWN, 
CRYSTAL SAMANTHA SHAW, JONATHAN SCOTT WEBB, CHRISTOPHER 
KIRK WEBB, STEPHANIE AMBER BARTON, TERRENCE BROOKS 
VILACHA, IJALEIGH MCKENZIE WOLFE, CARA CAMILLE BAILEY; 
JESSICA DAWN LESTER, 'BRIAN EDWARD ADDAIR, RUSSELL ERIC 
STILTNER, JOSEPH FREDERICK HASS, DANIEL WAYNE HORTON, JUSTIN 
WARREN MEADOWS, JASON DALE WORLEY, JERAMY BLAKE FARMER, 
CLINTON MICHAEL ALTIZER, and others knowingly and willfully conspired to (1) 
defraud the United States and (2) commit an offense against the United States, to wit: file 
/ 
fraudulent claims for pandemic unemployment benefits as authorized by, and 
administered through federal law, in violation of Title 18, United States Code, §1040(a), 
such benefits being authorized, paid, and disbursed in connection with the Coronavirus 
\ 
Disease (COVID-19) pandemic, an emergency declaration under §501 of the Robert T. 
Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. § 5191). 
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3. It was a part of the conspiracy that the named co-conspirators provided PII for 
the purpose of filing fraudulent claims for pandemic unemployment benefits in order to 
, 
receive funds to which they were not entitled. 
4. To effect the object of the conspiracy, the co-conspirators did several acts, 
including but not limited to those acts described in the Introduction to this Indictment. 
5. All in violation of Title 18, United States Code, Section 371. 
COUNTS TWO THROUGH EIGHTEEN 
(18 U.S.C § 1040(a)- Fraud in Connection with Emergency Benefits) 
The Grand Jury charges that: 
1. The information in the Introduction is realleged and incorporated by reference. 
2. On or about the dates detailed below, in the Western District of Virginia and · 
elsewhere, the individuals listed below, as principals, aiders, and abettors, knmlingly 
made and caused to be made materially false, fictitious, and fraudulent statements and 
representations on claim applications for pandemic unemployment benefits that were 
authorized, paid, and disbursed in connection with an emergency declaration under §501 
of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 
§ 5191). 
Count 
Name 
Date Filed 
·Claim Paid 
2 
JOSEF LUDWIG BROWN 
July 16, 2020 
$28,696.00 
3 
CRYSTAL SAMANTHA SHAW 
March 30, 2020 
$34,650.00 
4 
JONATHAN SCOTT WEBB 
May 6, 2020 
$32,589.00 
5 
CHRISTOPHER KIRK WEBB 
May 12, 2020 
$19,678.00 
6 
STEPHANIE AMBER BARTON 
April 30, 2020 
$30,070.00 
12 
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Count 
Name 
Date Filed 
Claim Paid 
7 
HALEIGH MCKENZIE WOLFE 
October 5, 2020 
$13,978.00 
8 
TERRENCEBROOKSVILACHA September 28, 2020 $14,894.00 
9 
CARA CAMILLE BAILEY 
July 16, 2020 
$26,406.00 
10 
JESSICA DAWN LESTER 
July 3, 2020 
$22,284.00 
11 
- BRIAN EDWARD Al)DAIR 
June 12, 2020 
$22,284.00 
12 
RUSSELL ERIC STILTNER 
June 22, 2021 
$16,898.00 
13 
JOSEPH FREDERICK HASS 
July 1, 2020 
$19,316.00 
14 
DANIEL WAYNE HORTON 
August 20, 2020 
$17,784.00 
15 
JUSTIN WARREN MEADOWS 
July 12, 2020 
$13,202.00 
16 
JASON DALE WORLEY 
July 25, 2020 
$9,698.00. 
17 
JERAMY BLAKE FARMER 
January 30, 2021 
$7,786.00 
18 
CLINTON MICHAEL ALTIZER 
July 22, 2020 
$10,992.00 
3. The materially false, fictitious, and fraudulent statements and representations, 
to wit: that the claimant (1) had been employed at the time of the COVID-19 outbreak;< 
(2) was unemployed as a result of the COVID-19 pandemic; and (3) was available to 
work and was actively seeking employment, were made in a circumstance involving a 
, 
benefit transported ·in the mail at any point in the authorization, transportation, 
transmission, transfer, disbursement, and payment of such benefit. 
4. All in violation of Title 18, l!nited States Code, Sections 2 and 1040(a)(2). 
COUNT NINETEEN 
(18 U.S.C § 1349 - Conspiracy to Commit Mail Fraud) 
The Grand Jury charges that: 
/ 
1. The information in the Introduction is realleged and incorporated by reference. 
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2. On or about and between March 30, 2020, and September 30, 2021, in the 
Western Dis!rict of Virginia and elsewhere, JOSEF LUDWIG BROWN, CRYSTAL 
SAMANTHA SHAW, JONATHAN SCOTT WEBB, CHRISTOPHER KIRK 
. 
WEBB, STEPHANIE AMBER BARTON, TERRENCE BROOKS VILACHA, 
HALEIGH MCKENZIE WOLFE, CARA CAMILLE BAILEY, JESSICA DAWN 
LESTER, BRIAN EDWARD ADDAIR, RUSSELL ERIC STILTNER, JOSEPH, 
FREDERICK HASS, DANIEL WAYNE HORTON, JUSTIN WARREN 
MEADOWS, JASON DALE WORLEY, JERAMY BLAKE FARMER, CLINTON 
MICHAEL ALTIZER, and others, as principals, aiders, and abettors, knowingly 
conspired to devise a scheme and artifice to defraud, and for obtaining money by means 
of false and fraudulent pretenses and representations, and for the purpose of executing 
such scheme causing to be delivered by mail according to the direction thereon any 
matter or thing, to wit: monetary determination letters, and PIN codes, among other 
items, such matter or thing pertaining to benefits that were authorized, paid, and 
disbursed in connection with an emergency declaration under §501 of the Robert T. 
Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. § 5191), in violation 
of Title 18, United States Code, Section 1341. 
3. All in violation ofTitle 18, United States Code, Section 1349. 
A TRUE BILL, this 
,2 / 
day of May, 2024. 
~~~-J&w ~ Pt>5 
/s/ Grand Jury Foreperson 
United States Attorney 
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