Criminal Complaint — United States v. Mykia King (No. 2:21-mj-30178, E.D. Mich.)
Summary
A sealed criminal complaint (AO 91) filed April 14, 2021 as ECF No. 1 in United States v. Mykia King, Case 2:21-mj-30178, in the U.S. District Court for the Eastern District of Michigan, charging wire fraud, mail fraud and conspiracy under 18 U.S.C. 1343, 1341 and 1349 from July 2020 through the present. The affidavit of Special Agent Shanika Sanders of the Department of Labor Office of Inspector General, sworn before U.S. Magistrate Judge Elizabeth A. Stafford, alleges that a State of Michigan lead claims examiner, charged in a separate complaint, released payment on fraudulent unemployment claims, including multiple claims filed by King. It states the scheme caused an actual loss of approximately over $923,000 to the State of Michigan. It reports that approximately 34 claims were filed from a single IP address using repeated identification photos.
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“Criminal Complaint — United States v. Mykia King (No. 2:21-mj-30178, E.D. Mich.).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-no-2-21-mj-30178-dkt-1-e-d-mich-30e4751c27/
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Case 2:21-mj-30178-DUTY ECF No. 1, PageID.1
AUSA: Alyse Wu Filed 04/14/21 Telephone:
Page 1 of(313)
24 226-9589
AO 91 (Rev. ) Criminal Complaint Special Agent: Shanika Sanders Telephone: (313) 226-2573
UNITED STATES DISTRICT COURT
for the
Eastern District of Michigan
United States of America Case: 2:21−mj−30178
v.
Assigned To : Unassigned
Mykia King
Assign. Date : 4/14/2021
CMP: SEALED MATTER (MAW)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of July 2020 through the present in the county of Wayne in the
Eastern District of Michigan , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. 1343 Wire Fraud
18 U.S.C. 1341 Mail Fraud
18 U.S.C. 1349 Conspiracy to Commit Wire and Mail Fraud
This criminal complaint is based on these facts:
See attached affidavit.
✔ Continued on the attached sheet.
Complainant’s signature
Special Agent Shanika Sanders
Printed name and title
Sworn to before me and signed in my presence
DQGRUE\UHOLDEOHHOHFWURQLFPHDQV
Date: April 14, 2021 Judge’s signature
City and state: Detroit, MI Elizabeth A. Stafford, U.S. Magistrate Judge
Printed name and title
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.2 Filed 04/14/21 Page 2 of 24
Affidavit in Support of an Application for an Arrest Warrant
I, Shanika Sanders, being first duly sworn, hereby depose and state as follows:
Introduction and Agent Background
1. I am a Special Agent (SA) of the U.S. Department of Labor, Office of
Inspector General (DOL/OIG), and have been so employed since January 2016.
Prior to this assignment, I was employed as an investigator in Industry Operations
for the Bureau of Alcohol, Tobacco, Firearms and Explosives for three years. I am
currently assigned to the Detroit Field Office of DOL/OIG. During my years at the
Department of Labor, I have conducted numerous investigations into criminal
violations of both Title 29 and Title 18 of the United States Code. During this time,
I have been either the lead agent or supporting agent on several investigations
involving criminal schemes targeting the State of Michigan’s (SOM)
Unemployment Insurance Agency (UIA) through the filing of false or fictitious
unemployment insurance (UI) claims. Based on my direct personal experience with
these cases, I have become familiar with the methods that criminals use to attack
and exploit the UI systems as well as tools and methods criminals often utilize to
facilitate that fraud.
2. I have graduated from the Criminal Investigator Training Program (CITP)
and the Inspector General Investigator Training Program (IGITP) at the Federal
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.3 Filed 04/14/21 Page 3 of 24
Law Enforcement Training Center (FLETC). I attended and participated in joint
in-service sessions for DOL-OIG/OI-LRF agents and Federal Bureau of
Investigation (FBI) agents, for training on the current criminal laws prohibiting
labor racketeering and other criminal violations of Title 18 and Title 29 of the
United States Code. I have also received training in documentary and electronic
evidence given by members of the Computer Crime & Intellectual Property
Section (CCIPS) of the U.S. Department of Justice (DOJ). Furthermore, I received
training specific to insider threats and internal employee investigations in IGITP as
employee integrity investigations commonly worked by IG agents.
3. As a result of my participation in this investigation, I submit that there is
probable cause to believe that Mykia King (DOB XX/XX/1993) has committed
federal crimes, including but not necessarily limited to mail fraud (18 U.S.C.
§ 1341), wire fraud (18 U.S.C. § 1343), and conspiracy to commit those crimes (18
U.S.C. § 1349). I make this affidavit based upon personal involvement in the
subject criminal investigation, including review of law enforcement databases,
financial documents, Internet Service Provider (ISP) records, and unemployment
insurance claims data from SOM records detailing a UI fraud scheme perpetrated
by Mykia King and State of Michigan Lead Claims Examiner Jermaine Rose. On
August 18, 2020, Rose was charged in a criminal complaint in the Eastern District
of Michigan for wire fraud (18 U.S.C. § 1343), mail fraud (18 U.S.C. § 1341),
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.4 Filed 04/14/21 Page 4 of 24
conspiracy to commit those acts (18 U.S.C. § 1349), and theft of government funds
(18 U.S.C. § 666) (Case No. 20-mj-30303).
4. I have also been provided with information from other law enforcement
agents and officials from the United States Secret Service (USSS), and the State of
Michigan’s Fraud Investigation Unit (SOM-FIU). Because this affidavit is
submitted for the sole purpose of supporting a criminal complaint and arrest
warrant, it does not necessarily contain all information and facts discovered and
developed in the course of this investigation.
Summary
5. In early July 2020, my agency received allegations involving a fraud scheme
aimed at defrauding the SOM and the U.S. Government of millions of dollars
earmarked for Pandemic Unemployment Assistance (PUA). In reviewing these
allegations, investigating agents identified SOM UIA Lead Claims Examiner
Jermaine Rose as a target of the investigation. The investigation has shown that
Jermaine Rose has used his position as a SOM employee to wrongfully release
payment on multiple fraudulent UI claims filed against the SOM, including
multiple claims filed by Mykia King. Jermaine Rose was not assigned nor had
any legitimate reason to access, let alone modify, the claims. The actions of Rose
and others involved in this investigation have resulted in an actual loss of
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.5 Filed 04/14/21 Page 5 of 24
approximately over $923,000 to the State of Michigan. Between July 3, 2020 and
July 30, 2020, when he was suspended by the agency, Jermaine Rose attempted to
override holds on approximately over $1,515,000 in additional fraudulent claims.1
These attempts were blocked due to daily monitoring by SOM.
Unemployment Insurance – Background & COVID-19
6. The Social Security Act of 1935 initiated the federal and state
unemployment insurance 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
directly to laid-off workers, and second, to ensure that life necessities are met on a
weekly basis while the worker seeks employment. In the State of Michigan, the UI
system is administered by the Unemployment Insurance Agency, which is part of
the SOM’s Department of Labor and Economic Opportunity (DLEO). The U.S.
Department of Labor funds many UIA administrative costs, including salaries,
office expenses, and computer equipment.
1
The criminal complaint charging Rose stated that Rose’s actions have resulted in
an actual loss of $1,011,000 and that he was found to have attempted to override
holds on approximately $761,000 in additional fraudulent claims. Since that time,
SOM conducted further analysis of the claims reviewed by Rose, and provided
Affiant with updated loss calculations.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.6 Filed 04/14/21 Page 6 of 24
7. State unemployment systems and benefits are joint state and federal
enterprises 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 the time of this
application, the federal government is providing significant supplemental benefits
to the states as a result of the COVID-19 pandemic.
8. The Families First Coronavirus Response Act (FFCRA) became law on
March 18, 2020, and provided additional flexibility for state unemployment
insurance agencies and additional administrative funding to respond to the
COVID-19 pandemic. The Coronavirus Aid, Relief, and Economic Security
(CARES) Act was later signed into law on March 27, 2020, and the American
Rescue Plan Act of 2021 (ARPA) was later signed and further expanded states’
ability to provide unemployment insurance for many workers impacted by the
COVID-19 pandemic, including for workers who are not ordinarily eligible for
unemployment benefits.
The CARES act further expanded states’ ability to provide unemployment
insurance for many workers impacted by the COVID-19 pandemic, including for
workers who are not ordinarily eligible for unemployment benefits. One such
program established to accomplish that end was the Federal Pandemic
Unemployment Compensation (FPUC) program.
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The FPUC allowed eligible individuals who were collecting certain UI benefits,
including regular unemployment compensation, to receive an additional $600 in
federal benefits per week for weeks of unemployment ending on or before July 31,
2020.
Another such program, the Pandemic Emergency Unemployment Compensation
(PEUC) program, allowed those who exhausted benefits under regular
unemployment compensation or other programs to receive up to 13 weeks of
additional federally funded benefits up to December 26, 2020.
On December 27, 2020, the President signed legislation that extended these
programs for an additional 12 weeks. Those receiving unemployment benefits
were entitled to an additional $300 each week of unemployment until April 4,
2021. At the time of this application, the legislation and programs detailed above
have extended many of these federally backed benefits until early September 2021.
That is all to say, the recent federal legislation and programs detailed above
allowed for a significant outlay of federal funds to flow to and through the states to
offset the recent and historic need of the American workforce for unemployment
benefits as a result of the COVID-19 pandemic, including the American workforce
in the SOM and in the Eastern District of Michigan (EDMI). Collectively and
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.8 Filed 04/14/21 Page 8 of 24
colloquially, the funds flowing from these programs have come to be known as
Pandemic Unemployment Assistance (PUA).
9. Normally (in the absence of fraud), an unemployed worker initiates an UI
claim. This can be accomplished by submitting a claim in person, over the
telephone, or on the Internet. Currently, the overwhelming majority of UI claims
are filed online through the UIA’s 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.
10. The SOM UIA will either approve or reject a UI claim based on the
application made by the unemployed worker. If the SOM UIA 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. One way in which
unemployment benefits are provided to a claimant is through the use of a debit
card, issued by the Bank of America (BOA), which is mailed to the claimant
through the U.S. Postal Service. The unemployment benefits are loaded onto the
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.9 Filed 04/14/21 Page 9 of 24
debit card electronically, and additional benefits are loaded onto the card
electronically every two weeks.
Unemployment Insurance – Fraud Prevention
11. In an effort to prevent and otherwise inhibit external fraud, SOM UIA
captures certain external data surrounding the interaction between an individual
and the UIA system. This data is compiled in a system named the “Michigan
Integrated Data Automated System” (MiDAS). Each time a claim is accessed in
MiDAS, it creates a digital footprint of sorts. Some of the data that the SOM
collects includes the dates, times, Internet Protocol (IP) address, and Media Access
Control (MAC) address associated with the device accessing the claim. SOM ties
this information to the user-entered information captured to facilitate the claim
(i.e., name, address, social security number, BOA or other bank account numbers,
bank routing numbers, etc.). SOM’s MiDAS system also utilizes certain
proprietary algorithms that automatically identify and stop possible fraud based on
whether or not a claim exhibits fraud indicators that exceed a designated threshold.
Agents also note that humans who review claims and conclude that the payments
may be involved in fraud can also take action to stop payment of the claims.
For the remainder of this affidavit, the investigating agent will refer to the process
detailed above as a “fraud-stop.”
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.10 Filed 04/14/21 Page 10 of 24
12. In an effort to prevent and otherwise inhibit internal fraud or insider threats,
SOM UIA captures certain internal data surrounding the interaction between SOM
employees, contractors, consultants and MiDAS. That is to say that MiDAS
maintains an “audit trail,” which details any insider who touches, alters, or
otherwise modifies a claim. SOM can attribute an insider’s actions to a particular
individual, as those accessing the system are required to enter unique credentials.
SOM also maintains workflow logs for its employees that detail which claims are
assigned to a particular employee. Additionally, SOM maintains call logs to
document telephonic contact between employees and claimants. The workflow
logs and call logs detail whether insiders had a legitimate reason to access or
modify a claim.
13. Investigators from SOM’s Fraud Investigations Unit have the ability to
access and review the data maintained for both external and internal actors in
MiDAS. It is through the analysis of this data that investigating agents can identify
fraudulent trends and tendencies associated with the unemployment insurance
claims.
Claims Examiner Jermaine Rose
14. The investigation has shown that Jermaine Rose was hired by the State of
Michigan on or about March 28, 2004 as an Unemployment Insurance Examiner.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.11 Filed 04/14/21 Page 11 of 24
15. According to the Michigan Civil Service Commission Job Specification
listed on the State of Michigan’s website, an Unemployment Insurance Examiner
(UIE) is responsible for reviewing and processing various UI claims using SOM
equipment and the SOM’s MiDAS system. UIEs provide services to claimants,
employers, and the general public.
Probable Cause
16. In early July 2020, SOM-FIU alerted DOL-OIG about a suspected Pandemic
Unemployment Assistance (PUA) fraud scheme occurring involving a State of
Michigan employee who was then working from home at a residence located in the
Eastern District of Michigan.
17. SOM-FIU had determined that approximately 34 UI claims were filed
electronically from the same IP address 24.127.138.244. After review of the
claims, it was determined the same driver license photos and social security cards
were uploaded for multiple claims, even though the claimants seemed to have
different names and addresses. It is common sense that over 30 different
individuals all utilizing the same IP address to file their UI claims is fraudulent on
its face because it is unlikely that so many individuals reside at a single address (let
alone are all eligible to file UI claims). In addition, the fact that multiple claims
used the same pictures for their proof of identification—for example, one picture
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.12 Filed 04/14/21 Page 12 of 24
was used with four different claims and another for three different claims—
provides further indication of fraud. 28 of the claims filed by the IP address were
stopped and Identity Verification (IDV) was requested. Jermaine Rose improperly
accessed, discarded Identity Verification issues, and released payments on 23 of
the 28 fraud-stop claims; this resulted in a loss of over $366,000 to SOM.
18. The SOM-FIU investigators reviewing Jermaine Rose’s audit logs
recognized the aforementioned activity as problematic and subsequently began a
more extensive review of his MiDAS audit logs. SOM-FIU made the
determination that Rose’s actions were fraudulent based on the fact that in the
overwhelming majority, if not every case, Rose overrode a fraud-stop placed on
the underlying claim. Review by SOM-FIU indicates that Rose neglected to notate
the files as to why the stops were discarded, which is standard procedure for a UIE.
Additionally, SOM-FIU’s review of Rose’s assigned work items failed to disclose
any legitimate reason to access and/or modify the subject claims.
Finally, through the analysis of Rose’s audit logs, SOM-FIU determined that Rose
targeted specific claims generally associated with similar IP addresses and physical
addresses. That is to say, Rose appeared to be intentionally overriding specific
fraud-stops and his actions were not a result of randomly approving unrelated
claims.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.13 Filed 04/14/21 Page 13 of 24
19. Agents determined that IP Address 24.127.138.244 was controlled by
Comcast and obtained the related records on July 23, 2020. Analysis of the
records disclosed that the account was active and that the service and billing
address associated with the account was XXXX0 N Park Drive #XX5, Southfield,
MI 48075. DTE utility records received on October 26, 2020 stated that Mykia
King was the account holder at the same address were the IP address was located.
Mykia King’s PUA Claims
20. On May 16, 2020, a PUA claim for an individual identified herein as “K.F.”
was electronically filed with the SOM. A Michigan driver’s license was uploaded
as proof of identification for the fraudulent claim on June 9, 2020. The address
used for the claim was Mykia King’s address, XXXX0 N. Park #XX5, Southfield,
MI 48075. Due to the out-of-state Social Security Number, the system requested
an Identity Verification (IDV). On June 11, 2020, Jermaine Rose accessed the
account and discarded the IDV. K.F.’s PUA claim was processed for payment.
21. On the same date, approximately 15 minutes earlier, Jermaine Rose
discarded an IDV request for a PUA claim for an individual identified herein as
“R.E.” R.E.’s PUA claim had the same driver’s license photo as K.F.’s. R.E.’s
claim also used the same street address as K.F.’s, but had a different apartment
number.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.14 Filed 04/14/21 Page 14 of 24
22. Jermaine Rose viewed the claims—under different names but using the same
documents—just 15 minutes apart, and discarded both fraud stops, resulting in a
total loss of $21,800 to the State of Michigan.
23. Mykia King uploaded her real Michigan identification card when applying
for her own UI benefits. The ID below was compared to the automated teller
machine (ATM) photos provided by Bank of America, to confirm the identity of
who was using the fraudulent UI debit cards.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.15 Filed 04/14/21 Page 15 of 24
24. On June 27, 2020, Mykia King can be seen using the R.E. Bank of America
UI debit card.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.16 Filed 04/14/21 Page 16 of 24
25. On the same day, Mykia King is seen using the K.F. Bank of America UI
debit card at another ATM.
26. On May 13 and May 16, 2020, PUA claims were filed for individuals
identified herein as “T.W.” and “P.S.” respectively. Both claims were filed using
Mykia King’s address. However, due to the SSNs belonging to out-of-state
residents, the system requested an Identity Verification (IDV) for both claims.
Fraudulent Michigan driver licenses bearing pictures of the same individual (with
different names) were uploaded as proof of identification for the fraudulent claims.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.17 Filed 04/14/21 Page 17 of 24
On June 19, 2020, Jermaine Rose accessed the accounts, just eight minutes apart,
and discarded the IDVs. Both PUA claims were processed for payment, resulting
in a loss to SOM of $21,480.
27. On May 23, 2020, Mykia King can be seen using the T.W. Bank of
America UI debit card.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.18 Filed 04/14/21 Page 18 of 24
28. On June 27, 2020, Mykia King can be seen using the P.S. Bank of America
UI debit card, a minute after using the R.E. UI debit card at the same ATM.
29. On June 5 and June 9, 2020, PUA claims were filed for individuals
identified herein as “T.R.” and “M.B.” respectively. M.B.’s claim was filed using
Mykia King’s address. T.R.’s claim used the same street address, but had a
different apartment number. However, due to the SSNs belonging to out-of-state
residents, the system requested an Identity Verification (IDV), for both claims.
Fraudulent Michigan driver licenses bearing pictures of the same individual (with
different names) were uploaded as proof of identification for the fraudulent claims.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.19 Filed 04/14/21 Page 19 of 24
30. On June 10, 2020, Jermaine Rose accessed the M.B.’s claim and discarded
the IDV. Both the T.R. and M.B. PUA claims were processed for payment. The
loss to SOM was $20,120.
31. On June 28, 2020, Mykia King can be seen using the T.R. Bank of America
UI debit card.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.20 Filed 04/14/21 Page 20 of 24
32. On July 7, 2020, Mykia King can be seen using the M.B. Bank of America
UI debit card.
33. On September 8, 2020, Bank of America provided bank records for 17
Michigan Unemployment Insurance debit cards that were associated with claims
that appear to have been fraudulently filed by King, including statements and ATM
photos. The cards were used primarily to make ATM withdrawals from Bank of
America ATMs. Mykia King was seen at the ATM making withdrawals with
every UI debit card. None of the cards used were issued to her.
34. In my training and experience, it appears that Mykia King fraudulently filed
UI claims in order to obtain unemployment benefits she was not entitled to. The IP
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.21 Filed 04/14/21 Page 21 of 24
address associated with Mykia King’s Southfield address was responsible for
electronically filing the above-described PUA claims. Many of those claims used
the same photos, with different Personal Identifying Information (PII), as proof of
identification. Also, seven of the cards were mailed to XXXX0 N. Park #XX5
where Mykia King resides; several more used the same street address with
different apartment numbers. In my training and experience, I believe it is possible
Mykia King would have the ability to gain possession of the cards mailed to her
apartment complex using the different apartment numbers. With the filing of these
fraudulent claims, Mykia King attempted to defraud the State of Michigan out of
approximately over $930,200, but actually obtained approximately $366,820.
Uses of Mail and Wires
35. After the Unemployment Insurance Agency accepts an unemployment
claim, it transfers the initial unemployment benefits into an account associated
with a bank, a prepaid debit card, or with an unemployment insurance debit card.
UI funds are sent via wire from Michigan and processed through the Bank of
America (which handles all Michigan UI processing), specifically through Bank of
America data center locations in the states of Virginia and Texas. In this case, after
the funds were processed through Bank of America, Mykia King used the Bank of
America debit cards to make cash withdrawals from ATMs throughout the Detroit
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.22 Filed 04/14/21 Page 22 of 24
Metro area. Therefore, the disbursement of these fraudulently obtained UI funds
involved the use of interstate wires, which constitutes a violation of 18 U.S.C.
§ 1343 (and conspiracy to commit that offense in violation of 18 U.S.C. § 1349).
36. In at least seven instances, an unemployment insurance debit card provided
by Bank of America was mailed to Mykia King’s address through the United
States mail because it was the address provided for the fraudulent UI claim. This
debit card could be used to access the fraudulently obtained UI funds via ATMs or
could be used at accepting retailers for point of purchase transactions. Therefore,
the mailing of these debit cards involved the use of the United States mail, which
constitutes a violation of 18 U.S.C. § 1341 (and conspiracy to commit that offense
in violation of 18 U.S.C. § 1349).
Summary
37. Based on my training and experience, the activity detailed above appears to
be part of an UI fraud scheme perpetrated by Mykia King and Jermaine Rose, and
may involve other co-conspirators currently unknown to law enforcement. The
basis for my statement derives from the information below:
a. During my career at DOL, I have worked several UI fraud cases
involving multiple fraudsters and I am familiar with how criminals can manipulate
the SOM’s UI system to obtain fraudulent benefits.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.23 Filed 04/14/21 Page 23 of 24
b. Within the last 30 days, I have had conversations with members of the
law enforcement intelligence community concerning the rampant levels of PUA
fraud occurring all over the country. Those officials have discussed with me
various scams and schemes they are tracking involving PUA including the
possibility of insiders facilitating UI fraud schemes, including schemes similar to
this.
Additionally, the FBI has advised that there are significant criminal resources and
“guides” available through criminal networks on how to defraud various states,
including SOM, of PUA benefits. Many of these schemes involve coordinated
efforts by a group of individuals who are communicating using electronic devices
and social media.
c. Based on Jermaine Rose’s activity, it appears that the general scheme
proceeds as follows. Outside co-conspirators enter bad claims into MiDAS and
provide the names/social security numbers associated with the claims to Jermaine
Rose. Jermaine Rose then discards any fraud-stops on the bad claims, facilitating
the release of the fraudulently obtained payments. Review of Jermaine Rose’s cell
phone seized during a search warrant shows he uses Facebook Messenger, calls
and text messages to communicate during these fraud schemes with others. This is
bolstered by SOM-FIU analysis that Jermaine Rose’s activity does not appear
random, but rather targeted at specific claims.
Case 2:21-mj-30178-DUTY ECF No. 1, PageID.24 Filed 04/14/21 Page 24 of 24
Conclusion
38. Based on the forgoing, there is probable cause to believe that Mykia King
has committed federal crimes, including but not necessarily limited to mail fraud
(18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and conspiracy to commit those
acts (18 U.S.C. §, 1349), in connection with a scheme to defraud the federal/state
unemployment insurance program and obtain unemployment benefits by means of
false and fraudulent pretenses and representations.
Respectfully submitted,
______________________
Shanika Sanders
Special Agent
U.S. Department of Labor –
Office of Inspector General
Sworn to before me and signed in my
presence and/or by reliable electronic means.
_________________________________________
ELIZABETH A. STAFFORD
UNITED STATES MAGISTRATE JUDGE
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