Indictment — United States v. Chanette Lewis

Record facts

U.S. District Court, Southern District of New York · No. 1:21-cr-00729-LAK · Doc. 28 · 2021-12-01 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
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v . -
CHANETTE LEWIS , 
X 
INDICTMENT 
21 Cr. 
a/k/a " Netty Hott ," 
TATIANA BENJAMIN , 
a/k/a " Ta Banks ," 
a/k/a "Lyric Muvaa , " 
TATIANA DANIEL , 
21 CRIM 
a/k/a " Kimora Daniel , " and 
HEAVEN WEST , 
Defendants . 
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COUNT ONE 
(Wire Fraud) 
The Grand Jury charges: 
729 
1 . 
From at least in or around April 2020 up to and including 
in or around July 2020 , in the Southern District of New York and 
elsewhere , CHANETTE LEWIS , a/k/a "Netty Hott ," TATIANA BENJAMIN, 
a/k/a "Ta Banks , " a/k/a "Lyric Muvaa ," TATIANA 
DANIEL , 
a/k/a 
"Kimora Dani el, " and HEAVEN WEST, the defendants , willfully and 
knowingly, having devised and intending to devise a scheme and 
artifice to defraud and for obtaining money and property by means 
of false and fraudulent pretenses, representations, and promi ses , 
transmitted and caused to be transmitted by means of wire, radio , 
and television communication in interstate and fore i gn commerce , 
writi ngs , signs , signals, pictures, and sounds for the purpose of 
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executing such scheme and artifice , and aided and abetted the same , 
to wit , the defendants defrauded New York City' s COVID-19 Hotel 
Room Isolation Program (the "Program" ) 
which was intended to 
provide hotel rooms , free of cost , fo r patients convalescing from 
COVID-1 9 and for healthcare workers who needed to self-isolate 
because of exposure to COVID-19 
by falsely claiming to be 
healthcare workers , by misappropriating actual healthcare workers ' 
identifying information , and by selling these hotel rooms to those 
who did not meet the Progral
s requirements, and sent and received 
interstate wires to and from the Southern District of New York , 
and elsewhere , in furtherance of that scheme. 
(Title 18, United States Code , Sections 1343 and 2.) 
COUNT TWO 
(Conspiracy to Commit Wire Fraud) 
The Grand Jury further charges : 
2 . 
From at least in or around April 2020 up to and including 
in or around July 2020 , in the Southern District of New York and 
e lsewhere , 
CHANETTE LEWIS, a/k/a "Netty Hott, " TATIANA BENJAMIN , 
a/k/a "Ta 
Banks," a/k/a "Lyric Muvaa ," TATIANA 
DANIEL, 
a/k/a 
"Kimora Daniel ," and HEAVEN WEST , the defendants , and others known 
and 
unknown , 
willfully 
and 
knowingly, 
combined , 
conspired , 
confederated, and agreed together and with each other to commit 
wire fraud , in violation of Title 18, United States Code , Section 
1343 . 
2 
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3. 
It was a part and an object of the conspiracy that 
CHANETTE LEWIS, 
Banks," 
a/k/a 
a/k/a "Netty Hott," TATIANA BENJAMIN, a/k/a "Ta 
"Lyric 
Muvaa," 
TATIANA 
DANIEL, 
a/k/a 
"Kimora 
Daniel," and HEAVEN WEST, 
the defendants, and others known and 
unknown, willfully and knowingly, having devised and intending to 
devise a scheme and artifice to defraud and for obtaining money 
and 
property 
by 
means 
of 
false 
and 
fraudulent 
pretenses, 
representations, and promises, would and did transmit and cause to 
be 
transmitted 
by 
means 
of 
wire, 
radio, 
and 
television 
communication in interstate and foreign commerce, writings, signs, 
signals, pictures, and sounds for the purpose of executing such 
scheme and artifice, in violation of Title 18, United States Code, 
Section 1343, to wit, the defendants defrauded the Program by 
falsely claiming to be healthcare workers, by misappropriating 
actual healthcare workers' identifying information, and by selling 
these hotel 
rooms 
to those 
who 
did not meet 
the Program's 
requirements, and sent and received interstate wires to and from 
the Southern District of New York, and elsewhere, in furtherance 
of that scheme. 
(Title 18, United States Code, Section 1349. ) 
3 
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COUNT THREE 
(Honest Services Fraud) 
The Grand Jury further charges: 
4 . 
From at least in or around May 2020 up to and including 
in or around June 2020, in the Southern District of New York and 
elsewhere , 
CHANETTE 
LEWIS, 
a/k/a "Netty Hott," the defendant, 
having devised and intending to devise a scheme and artifice to 
defraud, and to deprive her employer -- a call center in New York 
City 
("Call Center-1") 
that handled phone calls and certain 
reservations for the Program --
of its intangible right to her 
honest services , transmitted and caused to be transmitted by means 
of wire , radio, and television communication in interstate and 
foreign commerce , writings , signs, signals, pictures , and sounds 
for the purpose of executing such scheme and artifice to defraud, 
and aided and abetted the same, to wit, using online accounts, 
LEWIS abused her employment at Call Center-1 to secure Program 
hotel 
rooms 
for 
non-qualifying individuals 
in 
exchange 
for 
payment, and LEWIS sold healthcare workers ' personal identifying 
information -- to which she had access by virtue of her employment 
at Call Center-1 -- to co-conspirators in exchange for a fee, in 
order to abuse and profit from the Program, and sent and received 
interstate wires to and from the Southern District of New York, 
and elsewhere, in furtherance of that scheme . 
(Title 18 , United States Code, Sections 1343, 1346 , and 2 .) 
4 
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COUNT FOUR 
(Aggravated Identity Theft) 
The Grand Jury further charges : 
5 . 
From at least in or around May 2020 up to and including 
in or around July 2020 , in the Southern District of New York and 
elsewhere , 
CHANETTE 
LEWIS , 
a/k/a 
"Netty 
Hott ," 
and 
TATIANA 
BENJAMIN , a/k/a "Ta Banks , " a/k/a "Lyric Muvaa , " the defendants , 
knowingly 
transferred , 
possessed , 
and 
used, 
without 
lawful 
authority , a means of identification of another person , during and 
in relation to a felony violation enumerated in Title 18 , United 
States 
Code , 
Section 
1028A(c) , 
to 
wit , 
LEWIS 
and 
BENJAMIN 
transferred , possessed , used , and aided and abetted the transfer , 
possession , and use of , the names and other personal identification 
information of healthcare workers in the course of committing the 
wire 
fraud offenses charged in Counts 
One 
and 
Two 
of this 
Indictment . 
(Title 18 , United States Code, Sections 1028A and 2 . ) 
COUNT FIVE 
(Theft of Government Money, Property, or Records through 
Unemployment Benefits Fraud) 
The Grand Jury further charges: 
6 . 
From in or around November 2020 up to and including in 
or around September 2021 , in the Southern District of New York and 
elsewhere , 
CHANETTE 
LEWIS , 
a/k/a "Netty Hott ," the defendant , 
embezz l ed , stole , purloined, and converted to her own use and the 
5 
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use of another , and without authority , sold , conveyed , and disposed 
of records , vouchers , money , and things of value of the United 
States and a department and agency thereof , to wit , the United 
States Department of Labor , which exceeded the sum of $1 , 000 , and 
received , concealed, and retained the same with intent to convert 
it to her use and gain , knowing it to have been embezzled , stolen , 
purloined , and converted , to wit , LEWIS secured a total of more 
than $45 , 000 in federally funded unemployment benefits by claiming 
falsely that she had not been employed since February 2020 due to 
a lack of work because of the COVID- 19 pandemic , when in truth and 
fact , LEWIS was employed for at least some of that period at Call 
Center- 1 , and LEWIS ' s employment there ceased not because of the 
COVID- 19 pandemic but because LEWIS stopped showing up to work in 
or around June 2020 . 
(Title 18 , United States Code, Section 641 . ) 
FORFEITURE ALLEGATIONS 
7 . 
As the result of committing the offenses charged in 
Counts One and Two of this Indictment , CHANETTE LEWIS , a/k/a "Netty 
Hott , " TATIANA BENJAMIN , a/k/a "Ta Banks , " a/k/a " Lyric Muvaa ," 
TATIANA 
DANIEL , 
a/k/a 
" Kimora 
Daniel ," and 
HEAVEN 
WEST , 
the 
defendants , shall forfeit to the United States , pursuant to Title 
18 , United States Code , Section 981(a) (1) (C) and Title 28 , United 
States Code, 
Section 2461 (c) , 
any and all property, 
real and 
personal , that constitutes or is derived from proceeds traceable 
6 
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to the commission of said offenses , including but not limited to 
a sum of money in United States currency representing the amount 
of proceeds traceable to the commission of said offenses. 
8 . 
As the result of committing the offenses charged in Count 
Three and Five of this Indictment , CHANETTE LEWIS , a/k/a "Netty 
Hott , " the defendant , shall forfeit to the United States , pursuant 
to Title 18 , United States Code , Section 981 (a) (1) (C) 
and Title 
28 , United States Code , Section 2461 (c), any and all property , 
real and personal , that constitutes or is derived from proceeds 
traceable to the commission of said offenses , including but not 
limited to a sum of money in United States currency representing 
the amount of proceeds traceable to the commission of said offense. 
Substitute Assets Provision 
9 . 
If any of the above-described forfeitable property, as 
a result of any act or omission of the defendants : 
a . 
cannot 
be 
located 
upon 
the 
exercise 
of 
due 
diligence ; 
b . 
has been transferred or sold to, or deposited with , 
a t hird person ; 
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 which 
cannot be subdivided without difficulty ; 
7 
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it is the intent of the United States , pursuant to Title 21 , United 
States Code , Section 853 (p) , and Title 28 , United States Code , 
Section 2461 , to seek f orfeiture of any other property of the 
defendants up to the value of the forfeitable property described 
above. 
(Title 18 , United States Code , Section 981 ; 
Title 21 , United States Code , Section 853 ; and 
Title 28 , United States Code , Section 2461 . ) 
Isl 
FOREPERSON 
DAMIAN WILLIAMS 
United States Attorney 
8 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
CHANETTE LEWIS, 
a/k/a "Netty Hott ," 
TATIANA BENJAMIN, 
a/k/a "Ta Banks , " 
a/k/a "Lyric Muvaa," 
TATIANA DANIEL, 
a/k/a "Kimora Daniel," and 
HEAVEN WEST, 
Defendants. 
INDICTMENT 
21 Cr. 
(18 u.s.c . §§ 1343, 1349 , 1346 , 
1028A, 641 , and 2.) 
DAMIAN WILLIAMS 
United States Attorney 
Foreperson 
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