Criminal Complaint — United States v. Maurice Mills (Mag. No. 20-8426, D.N.J.)

Summary

Criminal complaint in United States v. Maurice Mills, Mag. No. 20-8426 (JAD), in the U.S. District Court for the District of New Jersey, attested by telephone before Magistrate Judge Joseph A. Dickson on October 2, 2020. It charges wire fraud under Title 18, United States Code, Section 1343 from about August 2020 through about September 2020, in a scheme to defraud the State of New York and individuals. A Department of Labor, Office of Inspector General special agent states that a single New Jersey IP address was used to file unemployment insurance claims for more than approximately 20 individuals, including Texas residents with benefits directed to New Jersey, and that the investigation revealed Mills made an ATM withdrawal of benefits on September 29, 2020. The claims had resulted in more than approximately $400,000 in actual losses.

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                     UNITED STATES DISTRICT COURT
                        DISTRICT OF NEW JERSEY


UNITED STATES OF AMERICA                     HON. JOSEPH A. DICKSON

         V.                                  Mag. No. 20-8426 (JAD)

MAURICE MILLS                                CRIMINAL COMPLAINT


      I, Joseph Patricola, being duly sworn, state the following is true and
correct to the best of my knowledge and belief:

                              SEE ATTACHMENT A

In violatioh of Title 18, United States Code, Section 1343.

      I further state that I am a Special Agent with the United States
Department of Labor, Office of Inspector General, and a Task Force Officer with
the Federal Bureau of Investigation and that this complaint is based on the
following facts:

                              SEE ATTACHMENT B

continued on the attached page and made a part hereof.




                                               eph Patricola, Special Agent
                                             Department of Labor-OIG

Agent Patricola attested to this Complaint by telephone pursuant to FRCP
4. l(b)(2)(A)

Sworn to before me and subscribed in my presence,

October 2, 2020                             at District of New Jersey




HONORABLE JOSEPH A. DICKSON
UNITED STATES MAGISTRATE JUDGE
                                ATTACHMENT A

      From in or about August 2020 through in or about September 2020, in
the District of New Jersey and elsewhere, defendant

                               MAURICE MILLS

knowingly and intentionally devised and intended to a scheme and artifice to
defraud the State of New York and individuals, and to obtain money and property
by means of materially false and fraudulent pretenses, representations, and·
promises, and, for the purpose of executing and attempting to execute such
scheme and artifice to defraud, did transmit and cause to be transmitted by
means of wire communications in interstate and foreign commerce, certain
writings, signs, signals, pictures, and sounds, including a telephone call made
from a location in New Jersey to a location outside of New Jersey.

      In violation of Title 18, United States Code, Section 1343 and Section 2.
                                ATTACHMENT B

       I, Joseph Patricola, am a Special Agent with the United States
Department of Labor, Office of Inspector General, and a Task Force Officer with
the Federal Bureau of Investigation. I am familiar with the facts set forth herein
based on my own investigation, my conversations with other law enforcement
officers, and my review of reports, documents, and other evidence. Because
this Complaint is being submitted for a limited purpose, I have not set forth
each and every fact that I know concerning this investigation. Where
statements of others are related herein, they are related in substance and in
part unless otherwise indicated. Where I assert that an event took place on a
particular date, I am asserting that it took place on or about the date alleged.

       1.   On or about March 27, 2020, the Coronavirus Aid, Relief, and
Economic Security Act "CARES Act" was signed into law. The CARES Act
created a new temporary federal program unemployment insurance program
called Pandemic Unemployment Assistance ("PUA"). PUA provides
unemployment insurance benefits ("UIBs") for individuals who are not eligible
for other types of unemployment (e.g., self-employed, independent contractors,
gig economy workers). The CARES Act also created a new temporary federal
program called Federal Pandemic Unemployment Assistance ("FPUC") that
provides an additional $600 weekly benefit to those eligible for PUA and regular
UIBs.

      2.     The New York State Department of Labor administers and manages
the regular unemployment and PUA programs in the State of New York. Thus,
subject to certain eligibility requirements, a person who is unemployed, but
who used to be employed by an employer in the State of New York, can apply to
receive UIBs from the State of New York. The State of New York offers an online
portal ("the Portal") through which applicants can apply for UIBs and other
types of benefits. In addition, the State of New York allows individuals to
submit applications for UIBs over the telephone.

      3.    The State of New York logs information concerning claims for UIBs
submitted through the Portal or over the telephone. Among other things, the
State of New York logs Internet Protocol ("IP") addresses and phone numbers
associated with UIB requests.

      4.    Records provided by the State of New York revealed that a single IP
address ending in the digits 249 (the "IP Address") was used to submit UIB
claims on behalf of more than approximately 20 individuals (the "IP Address
Claims"). For example, on or about September 21, 2020, an IP Address Claim
was submitted by telephone via a call that originated from the IP Address and
was received in a location in New York.

        5.    Records obtained from the provider of the IP Address revealed that
at all times relevant to the investigation described herein, the IP Address was a'
static IP address that resolved to a single residential location in New Jersey (the
"NJ Location") and was subscribed to by an individual ("Individual l").

       6.    Records provided by the State of New York also revealed that
approximately three IP Address Claims directed that U!Bs be mailed to a
residential street address in New Jersey with the house number 342 (the "New
Jersey Address"). The investigation has revealed that the New Jersey Address
does not exist and that the residence bearing house number 344 on the same
street is under construction. Based upon my training and experience, those
involved in UIB and similar frauds often have funds sent to a drop location,
such as a vacant or under-construction home, in order to thwart law
enforcement.

       7.    Records provided by the State of New York further reveal that a
telephone number ending in the digits 8970 (the "8970 Number") was used in
connection with approximately four IP Address Claims that law enforcement
believe to be fraudulent. Three applications were in the name of Texas
residents but directed that the UIBs be sent to locations in New Jersey. An
additional application was submitted on a recorded telephone call, during
which the caller made unauthorized use of the name and personal
identification information of a third party.

    8.    Records obtained by law enforcement from the provider of the 8970
Number revealed that it is subscribed to by Individual 1.

      9.     Records obtained from the State of New York revealed additional IP
Address Claims submitted on behalf of Texas residents that directed the UIBs
to be sent to locations in New Jersey. Based upon my training and experience,
and the investigation to date, the fact that one IP address in New Jersey is
making UIB claims to the State of New York for individuals residing in Texas
but asking for the UIBs to be sent to New Jersey indicates that the claims are
fraudulent.

       10.   Records obtained from a car dealership (the "Dealership") revealed
that, on or about August 11, 2020, defendant MILLS and Individual 1
purchased a 2017 Mercedes-Benz (the "Mercedes") for approximately $36,000.
The records further reveal that defendant MILLS and Individual 1 paid for the
Mercedes with credit cards and approximately $14,000 in cash.
       11.   Records from the Dealership further revealed that defendant MILLS
applied for credit in connection with the purchase of the Mercedes. On some of
the credit application forms defendant MILLS provided the 8970 Number as his
telephone number.

       12.   On or about September 25, 2020, an IP Address Claim was made
to the State of New York. The claim directed the UIBs to be sent to the New
Jersey Address. On or about September 28, 2020, a debit card with the UIBs
was mailed to the New Jersey Address. On or about September 29, 2020, a
withdrawal was made using the debit card at an ATM in New Jersey. The
investigation to date , including surveillance of defendant MILLS earlier on
September 29, 2020, and a review of the video of the withdrawal, revealed that
defendant MILLS made the withdrawal.

       13.  Records in a law enforcement database indicate that defendant
MILLS is associated with the NJ Location. On or about September 29, 2020,
law enforcement observed defendant MILLS in the Mercedes in close proximity
to the NJ Location.

      14. To date, the IPAddress Claims have resulted in more than
approximately $400,000 in actual losses and more than approximately
$600,000 in potential losses.


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