Superseding Indictment — No. 5:21-cr-20510 (Dkt. 133, E.D. Mich.)

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A superseding indictment filed October 25, 2022 in United States v. Sharodney Harrison and eight co-defendants, Case No. 21-cr-20510, in the U.S. District Court for the Eastern District of Michigan, before Judge Judith E. Levy. It charges conspiracy to commit wire fraud under 18 U.S.C. § 1349 and aggravated identity theft under 18 U.S.C. § 1028A(a)(1). The general allegations describe the unemployment insurance system and the Pandemic Unemployment Assistance benefits, and state that the scheme's participants communicated by text message and telephone. Count One names Sharodney Harrison, Seandrea Crawford, Sharrell Harrison, Sha-Ron Harrison, Sharease Harrison, Edward Taylor, James Mayfield, Frank Jennings and Sharonda Griffin.

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Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.355 Filed 10/25/22 Page 1 of£18

\

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA,

Case No. 21-cr-20510

Plaintiff,

Hon. Judith E. Levy
Vv.

Violations: 18 U.S.C. § 1349
D-1 SHARODNEY HARRISON, 18 U.S.C. § 1028A(a)(1)
D-2 SEANDREA CRAWFORD, 18 U.S.C. § 2

D-3 SHARRELL HARRISON,
D-4 SHA-RON HARRISON,
D-5 SHAREASE HARRISON,
D-6 EDWARD TAYLOR,
D-7 JAMES MAYFIELD,

D-8 FRANK JENNINGS, FILED USOC - CLRK DET
D-9 SHARONDA GRIFFIN, 2022 OCT 25 Pxd:49

Defendants.

SUPERSEDING INDICTMENT
THE GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS

At times relevant to this Superseding Indictment:

Unemployment Insurance Program

1. The Social Security Act of 1935 initiated the federal and state
unemployment insurance (UI) system. The system provides benefits to individuals
who are unemployed for reasons beyond their control. The purpose of the UI system

is twofold: first, to lessen the effects of unemployment through cash payments made


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.356 Filed 10/25/22 Page 2 of 18

directly to laid-off workers, and second, to ensure that life necessities are met on a
weekly basis while the worker seeks employment. In Michigan, the UI system is
administered by the Michigan Unemployment Insurance Agency (MUIA), which is
part of the Michigan’s Department of Labor and Economic Opportunity. Other
States administer their UI programs through similar state-run agencies. Regardless
of state, the U.S. Department of Labor funds each of the respective state agency’s
administrative costs, including salaries, office expenses, and computer equipment.

2. State unemployment systems and benefits are largely financed by taxes
on private employers located in that state. When state unemployment benefits are
exhausted, they may be supplemented by federal funds appropriated by the U.S.
Department of Labor. At times relevant to this Superseding Indictment, the federal
government was providing significant supplemental benefits to the states as a result
of the COVID-19 pandemic.

3. Beginning in or about March 2020 and continuing through in or about
September 2021, the Families First Coronavirus Response Act (FFCRA);
Coronavirus Aid, Relief, and Economic Security (CARES) Act; and American
Rescue Plan Act of 2021 (ARPA) created federal programs that allowed for the
significant outlay of federal funds flowing to and through the states to offset the

historic need for unemployment benefits by the American workforce, including in


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.357 Filed 10/25/22 Page 3 of 18

the State of Michigan and in the Eastern District of Michigan. Collectively, these
benefits are often referred to as Pandemic Unemployment Assistance (PUA).

4. Normally, in the absence of fraud, an unemployed worker initiates an
UI claim in person, over the telephone, or on the Internet. Currently, the
overwhelming majority of UI claims are filed online through a state website. In order
to be eligible for UI benefits, the worker must demonstrate a certain level of earnings
in several quarters immediately preceding the application. The amount of
unemployment benefits that a UI claimant might be eligible for depends on a variety
of factors, including but not limited to the length of his or her previous employment
and the amount of wages he or she earned.

5. The state agency will either approve or reject a UI claim based on the
application made by the unemployed worker. If the state agency approves a UI claim,
the claimant is required to re-certify the claim via telephone or Internet at various
times during the life of the claim. The worker must also certify that he or she is still
unemployed and actively seeking work.

6. One way in which the State of Michigan provides unemployment
benefits to a claimant is through the use of a debit card. At all times relevant to this
Superseding Indictment, those debit cards were issued by the Bank of America,
which were mailed to the claimant through the U.S. Postal Service. The

unemployment benefits were loaded onto the debit card electronically. Alternatively,


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.358 Filed 10/25/22 Page 4 of 18

a worker would provide the state agency with a bank routing number and bank
account, and Bank of America would deposit their unemployment benefits directly.
In either case, additional benefits were loaded electronically by Bank of America at
intervals thereafter.

7. At all times relevant to this Superseding Indictment, the Bank of
America centers used to process Michigan’s UI claims were located in Virginia and
Texas, so claims filed in Michigan would have resulted in interstate wire
transmissions from the state of Michigan to the states of Virginia or Texas to initiate
payment of benefits.

8. At all times relevant to this Superseding Indictment, when a claimant
using an internet protocol (IP) address registered in Michigan filed a claim with an
out-of-state UI agency, the servers used to process those claims were located outside
the state of Michigan. For example, a California claim filed from an IP address
registered to a Michigan residence would be processed through a server located
outside of the state of Michigan.

9. In an effort to prevent and otherwise inhibit fraud, the state agencies
capture certain data surrounding the interaction between an individual and the UI
system. Although states utilize their own unique systems, many times the data that
is collected includes the dates, times, and IP address associated with a device

accessing a claim. The state systems tie this information to the user-entered


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.359 Filed 10/25/22 Page 5of 18

information captured to facilitate the claim (i.e. name, address, social security
number, Bank of America or other bank account numbers, bank routing numbers,
etc.).
The Defendants and Relevant Individuals

10. Defendant SHARODNEY HARRISON was a resident of the Eastern
District of Michigan.

11. Defendant SEANDREA CRAWFORD was a resident of the Eastern
District of Michigan.

12. Defendant SHARRELL HARRISON was a resident of the Eastern |
District of Michigan.

13. Defendant SHA-RON HARRISON was a resident of the Eastern
District of Michigan.

14. Defendant SHAREASE HARRISON was a resident of the Eastern
District of Michigan.

15. Defendant EDWARD TAYLOR was a resident of the Eastern District
of Michigan.

16. Defendant JAMES MAYFIELD was a resident of the Eastern District
of Michigan.

17. Defendant FRANK JENNINGS was a resident of the Eastern District

of Michigan.


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.360 Filed 10/25/22 Page 6 of 18

18. Defendant SHARONDA GRIFFIN was a resident of the Eastern
District of Michigan.

Purpose of the Scheme to Defraud

19. The purpose of the scheme to defraud was to obtain money by, among
other things, submitting fraudulent UI claims.

The Scheme to Defraud

20. Between on or about February 1, 2020, to on or about January 26,
2021, SHARODNEY HARRISON devised a scheme to defraud several states and
the federal government by filing fraudulent UI claims using the personal information
of individuals without their knowledge or consent, or who were not eligible to
receive benefits, or both.

21. SHARODNEY HARRISON conspired with other individuals to assist
with and participate in his scheme. Among the actions taken by those individuals to
further the goals of the scheme were: (1) creating email accounts to link with UI
claims; (2) submitting fraudulent UI claims; (3) re-certifying the UI claims; (4) using
their telephone numbers to verify identity of the fraudulent claims; (5) creating
online bank accounts in which the UI benefits were deposited; (6) collecting mail
for the UI claims; and (7) collecting mail with pre-paid cards on which UI benefits
had been deposited. SHARODNEY HARRISON and other members of the

conspiracy shared information about filing fraudulent UI claims and worked together


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.361 Filed 10/25/22 Page 7 of 18

to file fraudulent UI claims. In return for their assistance, SHARODNEY
HARRISON would promise to pay individuals using proceeds from the fraud
scheme.

22. In furtherance of the scheme, SHARODNEY HARRISON and the
other individuals involved in this scheme communicated via text message and

telephone.

COUNT ONE

18 U.S.C. § 1349
Conspiracy to Commit Wire Fraud

D-1 SHARODNEY HARRISON,
D-2 SEANDREA CRAWFORD,
D-3 SHARRELL HARRISON,
D-4 SHA-RON HARRISON,
D-5 SHAREASE HARRISON,
D-6 EDWARD TAYLOR,

D-7 JAMES MAYFIELD,

D-8 FRANK JENNINGS,

D-9 SHARONDA GRIFFIN.

23. Paragraphs 1 through 22 of this Superseding Indictment are realleged
and incorporated by reference as though fully set forth herein.

24. From on or about February 1, 2020, to on or about January 26, 2021,
in the Eastern District of Michigan, and elsewhere, the defendants, SHARODNEY
HARRISON, SEANDREA CRAWFORD (“CRAWFORD”), SHARRELL
HARRISON, SHA-RON HARRISON, SHAREASE HARRISON, EDWARD

TAYLOR (“TAYLOR”), JAMES MAYFIELD (“MAYFIELD”), FRANK


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.362 Filed 10/25/22 Page 8 of 18

JENNINGS (“JENNINGS”), and SHARONDA GRIFFIN (“GRIFFIN”), knowingly
combined, conspired, confederated, and agreed with each other and other
individuals, both known and unknown to the Grand Jury, to commit wire fraud, that
is, to knowingly and with the intent to defraud, devise and intend to devise a scheme
and artifice to defraud, and to obtain money and property by means of materially
false and fraudulent pretenses, representations, and promises, said scheme including
a material misrepresentation and the concealment of a material fact, and for the
purpose of executing and attempting to execute the scheme to defraud, to transmit
and cause to be transmitted by means of wire, radio, and television communication,
writings, signals, pictures, and sounds in interstate and foreign commerce, all in
violation of Title 18, United States Code, Section 1343.
Object of the Conspiracy
25. The object of the conspiracy was the same as the purpose of the scheme
to defraud set forth in Paragraph 19 of this Superseding Indictment.
Manner and Means of the Conspiracy
26. It was part of the conspiracy that some members of the conspiracy, and
others known and unknown to the grand jury, created email addresses, designed to
appear to be the legitimate email address of a UI claimant, in furtherance of

fraudulent claims.


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.363 Filed 10/25/22 Page 9 of 18

27. It was part of the conspiracy that some members of the conspiracy, and
others known and unknown to the grand jury, would use their own names and the
names of third parties, email addresses, and other personal information, to file
fraudulent UI claims, usually without the knowledge or consent of the named
claimants.

28. It was part of the conspiracy that some members of the conspiracy, and
others known and unknown to the grand jury, would share information with each
other about how to commit UI fraud efficiently and successfully in various
jurisdictions.

29, It was part of the conspiracy that SHARODNEY HARRISON, and
others known and unknown to the grand jury, coordinated and arranged for
HARRISON to have UI claims information and UI debit cards sent to their home or
neighboring addresses.

30. It was part of the conspiracy that others known and unknown to the
grand jury would then alert SHARODNEY HARRISON when UI information or UI
debit cards arrived at those addresses. SHARODNEY HARRISON would then tell
those individuals what to do with UI information and debit cards that they received.

31. It was part of the conspiracy that some members of the conspiracy
traveled from Michigan to California from on or about August 25, 2020, to on or

about September 4, 2020, to expedite the process of filing fraudulent UI claims in


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.364 Filed 10/25/22 Page 10 of 18

California. Believing that they could have California UI claims paid more quickly
if California mailing addresses were used for the UI claims, these members of the
conspiracy rented an Airbnb located in Los Angeles, California, and used the address
of that Airbnb and other California addresses to file fraudulent California UI claims
in the days leading up to the trip, and while they were in California.

All in violation of Title 18, United States Code, Section 1349.

COUNT TWO
18 U.S.C. §§ 1028A(a)(1); 2
Aggravated Identity Theft; Aiding and Abetting

D-1 SHARODNEY HARRISON,
D-2 SEANDREA CRAWFORD.

32. Paragraphs 1 through 31 of this Superseding Indictment are realleged
and incorporated by reference.

33. Between on or about August 25, 2020 through on or about September
11, 2020, within the Eastern District of Michigan, D-1 SHARODNEY HARRISON
and D-2 SEANDREA CRAWFORD, while aided and abetted by one another, did
knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, Victim C.S., during and in relation the felony
violation charged in Count One, Conspiracy to Commit Wire Fraud, in violation of
18 U.S.C. § 1349, knowing that the means of identification belonged to another

actual person.

All in violation of 18 U.S.C. § 1028A(a)(1).

10


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.365 Filed 10/25/22 Page 11 of 18

COUNT THREE
18 U.S.C. §§ 1028A(a)(1); 2
Aggravated Identity Theft; Aiding and Abetting

D-1 SHARODNEY HARRISON,
D-9 SHARONDA GRIFFIN.

34. Paragraphs 1 through 33 of this Superseding Indictment are realleged
and incorporated by reference.

35. Between on or about May 8, 2020 through on or about July 14, 2020,
within the Eastern District of Michigan, D-1 SHARODNEY HARRISON and D-9
SHARONDA GRIFFIN, while aided and abetted by one another, did knowingly
transfer, possess, and use, without lawful authority, a means of identification of
another person, Victim S.C., during and in relation the felony violation charged in
Count One, Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349,
knowing that the means of identification belonged to another actual person.

All in violation of 18 U.S.C. § 1028A(a)(1).

COUNT FOUR

18 U.S.C. § 1028A(a)(1)
Aggravated Identity Theft

D-3 SHARRELL HARRISON.
36. Paragraphs 1 through 35 of this Superseding Indictment are realleged

and incorporated by reference.
37. Between on or about June 22, 2020 through on or about September 12,

2020, within the Eastern District of Michigan, D-3 SHARRELL HARRISON, did

11


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.366 Filed 10/25/22 Page 12 of 18

knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, Victim S.C., during and in relation the felony
violation charged in Count One, Conspiracy to Commit Wire Fraud, in violation of
18 U.S.C. § 1349, knowing that the means of identification belonged to another
actual person.

All in violation of 18 U.S.C. § 1028A(a)(1).

COUNT FIVE
18 U.S.C. § 1028A(a)(1)
Aggravated Identity Theft

D-4 SHA-RON HARRISON.
38. Paragraphs 1 through 37 of this Superseding Indictment are realleged

and incorporated by reference.

39. Between on or about May 1, 2020 through on or about August 22, 2020,
within the Eastern District of Michigan, D-4 SHA-RON HARRISON, did
knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, Victim E.P., during and in relation the felony
violation charged in Count One, Conspiracy to Commit Wire Fraud, in violation of
18 U.S.C. § 1349, knowing that the means of identification belonged to another
actual person.

All in violation of 18 U.S.C. § 1028A(a)(1).

Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.367 Filed 10/25/22 Page 13 of 18

COUNT SIX

18 U.S.C. § 1028A(a)(1)
Aggravated Identity Theft

D-5 SHAREASE HARRISON.
40. Paragraphs 1 through 39 of this Superseding Indictment are realleged

and incorporated by reference.

41. Between on or about May 21, 2020 through on or about July 4, 2020,
within the Eastern District of Michigan, D-5 SHAREASE HARRISON, did
knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, Victim I.S., during and in relation the felony
violation charged in Count One, Conspiracy to Commit Wire Fraud, in violation of
18 U.S.C. § 1349, knowing that the means of identification belonged to another
actual person.

All in violation of 18 U.S.C. § 1028A(a)(1).

COUNT SEVEN

18 U.S.C. § 1028A(a)(1)
Aggravated Identity Theft

D-6 EDWARD TAYLOR.
42. Paragraphs 1 through 41 of this Superseding Indictment are realleged

and incorporated by reference.
43. Between on or about May 6, 2020 through on or about September 10,

2020, within the Eastern District of Michigan, D-6 EDWARD TAYLOR, did


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.368 Filed 10/25/22 Page 14 of 18

knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, Victim D.R-S., during and in relation the felony
violation charged in Count One, Conspiracy to Commit Wire Fraud, in violation of
18 U.S.C. § 1349, knowing that the means of identification belonged to another

actual person.

All in violation of 18 U.S.C. § 1028A(a)(1).

COUNT EIGHT
18 U.S.C. § 1028A(a)(1)
Aggravated Identity Theft

D-8 FRANK JENNINGS.
44. Paragraphs | through 43 of this Superseding Indictment are realleged

and incorporated by reference.

45. Between on or about May 8, 2020 through on or about August 5, 2020,
within the Eastern District of Michigan, D-8 FRANK JENNINGS, did knowingly
transfer, possess, and use, without lawful authority, a means of identification of
another person, Victim T.S., during and in relation the felony violation charged in
Count One, Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349,
knowing that the means of identification belonged to another actual person.

All in violation of 18 U.S.C. § 1028A(a)(1).


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.369 Filed 10/25/22 Page 15 of 18

FORFEITURE ALLEGATIONS

46. Pursuant to Fed. R. Cr. P. 32.2(a), the government hereby provides
notice to the defendants of its intention to seek forfeiture of all proceeds, direct or
indirect, or property traceable thereto, all property that facilitated the commission of
the violations alleged, or property traceable thereto, and all property involved in, or
property traceable thereto, of the violations set for in this Superseding Indictment.

47. Substitute Assets: If the property described above as being subject to

forfeiture, as a result of any act or omission of Defendants:
a. Cannot be located upon the exercise of due diligence;
b. Has been transferred or sold to, or deposited with, a third party;
c. Has been placed beyond the jurisdiction of the Court;

d. Has been substantially diminished in value; or

e. Has been commingled with other property that cannot be divided
without difficulty;


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.370 Filed 10/25/22 Page 16 of 18

the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21, United States Code, Section 853(p), and Title 28, United States
Code, Section 2461(c).

THIS IS A TRUE BILL

s/ Grand Jury Foreperson
Grand Jury Foreperson

DAWN N. ISON
United States Attorney

s/ John K. Neal

John K. Neal

Assistant United States Attorney
Chief, White Collar Crime Unit

s/ Meghan S. Bean
Meghan Sweeney Bean
Assistant United States Attorney

s/ Craig Weier
Craig Weier
Assistant United States Attorney

Dated: October 25, 2022

16


Case 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.371 Filed 10/25/22 Page 17 of 18

nated States were you Criminal Case Cover Sheet | Case Number
astern District of Michigan 21-cr-20510 to
wii
NOTE: It is the responsibility of the Assistant U.S. Attorney signing this form to complete it accurately in all respects. F~] Fare)
wed =
3 fom
| Bx
eee fe | | ; Companion Case Number: 5 5
This may be a companion case based upon LCrR 57.10 (b)(4)': Judge Assigned: = at
ete
Llves No AUSA’s Initials: ASTD pa N
Case Title: USAv. HARRISON, et al.
County where offense occurred: Wayne
Check One: [X]Felony ms Misdemeanor [IPetty
Indictment/ Information -- no prior complaint.
Indictment/ Information --- based upon prior complaint [Case number: ]
¥_Indictment/ Information -- based upon LCrR 57.10 (d) [Complete Superseding section below].
Superseding to Case No: 21-cr-20510 Judge: Judith E. Levy
CJ Corrects errors; no additional charges or defendants.
[_]Involves, for plea purposes, different charges or adds counts.
Embraces same subject matter but adds the additional defendants or charges below:
Defendant name Charges Prior Complaint (if applicable)
* See attached for Defendant list designating 18U.S.C. 1028A(a)(1)
defendant and their new charge(s) 18 U.S.C. 2

Please take notice that the below listed Assistant United States Attorney is the attorney of record for
the above captioned case.

October 25, 2022 N44 Pe OD.

Date Megha gweney Bean

V. Fort Street, Suite 2001
Detroit, Ml 48226-3277
Phone: 313-226-0214

Fax: 313-226-2372

E-Mail address: Meghan.Bean@usdoj.gov
Attorney Bar #: P80790

1 Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, or (2) the same
or related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be companion cases
even though one of them may have already been terminated.
5/16


se 5:21-cr-20510-JEL-EAS ECF No. 133, PagelD.372 Filed 10/25/22 Page 18 of 18

Attachment to Criminal Cover Sheet Superseding Case Information
Harrison, et al. 21-20510

Defendant name Charges

D-1 SHARODNEY HARRISON, 18 U.S.C. 1028A(a)(1); 2
D-2 SEANDREA CRAWFORD, 18 U.S.C. 1028A(a)(1); 2
D-3 SHARRELL HARRISON, 18 U.S.C. 1028A(a)(1)
D-4 SHA-RON HARRISON, 18 U.S.C. 1028A(a)(1)
D-5 SHAREASE HARRISON, 18 U.S.C. 1028A(a)(1)
D-6 EDWARD TAYLOR, 18 U.S.C. 1028A(a)(1)
D-7 JAMES MAYFIELD, (no new charges)

D-8 FRANK JENNINGS, 18 U.S.C. 1028A(a)(1)

D-9 SHARONDA GRIFFIN, 18 U.S.C. 1028A(a)(1); 2

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