Sealed Complaint, 21 MAG 9354 (Southern District of New York) — Chanette Lewis, Tatiana Benjamin, Tatiana Daniel, Heaven West

Summary

This sealed complaint, 21 MAG 9354 in the Southern District of New York, was sworn by Special Agent Jared Eannucci before Chief Magistrate Judge Gabriel W. Gorenstein on the 28th day of September, 2021. It charges Chanette Lewis, Tatiana Benjamin, Tatiana Daniel and Heaven West with wire fraud and wire fraud conspiracy over New York City’s COVID-19 Hotel Room Isolation Program. The complaint alleges that the defendants falsely claimed to be healthcare workers, misappropriated real healthcare workers’ identifying information and sold rooms to people who did not qualify, and that the scheme cost the federal government and New York City more than approximately $400,000. Lewis, described as an employee of a call center that handled Program reservations, is also charged with honest services fraud, aggravated identity theft and unemployment benefits fraud.

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MICHAEL D. NEFF!
Assistant United States Attorney
Before: THE HONORABLE GABRIEL W. GORENSTEIN
Chief United States Magistrate Judge
Southern District of New York
ae , 21 MAG 9354
UNITED STATES OF AMERICA : SEALED COMPLAINT
-V.- : Violations of 18
: U.S.C. SS 1343, 1349,
CHANETTE LEWIS, : 1346, 1028A, 641, & 2
a/k/a “Netty Hott,” :
TATIANA BENJAMIN, : COUNTY OF OFFENSE:
a/k/a “Ta Banks,” : NEW YORK

a/k/a “Lyric Muvaa,”
TATIANA DANIEL,

a/k/a “Kimora Daniel,” and
HEAVEN WEST,

Defendants.

SOUTHERN DISTRICT OF NEW YORK, ss.:

JARED EANNUCCI, being duly sworn, deposes and says that
he is a Special Agent with the United States Attorney’s Office for
the Southern District of New York, and charges as follows:

COUNT ONE
(Wire Fraud)

1. From at least in or around April 2020 up to and including
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
Daniel,” 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 promises, 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, 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, for patients convalescing from
COVID-19 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 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, Sections 1343 & 2.)

COUNT TWO
(Wire Fraud Conspiracy)

2. From at least in or around April 2020 up to and including
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
Daniel,” and HEAVEN WEST, the defendants, and others known and
unknown, willfully and knowingly, did combine, conspire,
confederate, and agree together and with each other to commit wire
fraud, in violation of Title 18, United States Code, Section 1343.

3. It was a part and an object of the conspiracy that
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, 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, knowingly 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 -- which
was intended to provide hotel rooms, free of cost, for patients
convalescing from COVID-19 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 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,
in violation of Title 18, United States Code, Section 1343.

(Title 18, United States Code, Section 1349.)

COUNT THREE
(Honest Services Fraud)

4. From at least in or around May 2020 up to and including
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.

(Title 18, United States Code, Sections 1343, 1346, and 2.)

COUNT FOUR
(Aggravated Identity Theft)

5. From at least in or around May 2020 up to and including
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 as part of committing the offenses charged
in Counts One and Two of this Complaint.

(Title 18, United States Code, Sections 1028A and 2.)
COUNT FIVE
(Unemployment Benefits Fraud)

6. From in or around November 2020, up to and including the
present, in the Southern District of New York and elsewhere,
CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant, willfully and
knowingly embezzled, stole, and converted to her own use or the
use of another, money of the United States exceeding $1,000 in
value, to wit, LEWIS secured a total of more than $45,000 in
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.)

The bases for my knowledge and for the foregoing charges are,
in part, as follows:

7. I am a Special Agent with the United States Attorney’s
Office for the Southern District of New York (“USAO-SDNY”), and I
have been personally involved in the investigation of this matter.
My duties and responsibilities include the investigation of
financial crimes, such as wire fraud, mail fraud, identity theft,
money laundering, computer crime, and theft from the Government.
This affidavit is based on my personal participation in this
investigation, my examination of reports, records, videos, audio
recordings, and photographs, and my conversations with other
individuals, including other law enforcement officers. Because
this affidavit is being submitted for the limited purpose of
establishing probable cause for the offenses cited above, it does
not include all the facts that I have learned during this
investigation. Where the contents of documents, statements, and
conversations of others are reported herein, they are reported in
substance and in part, except where otherwise indicated. Moreover,
all dates and numbers are approximate.

THE FRAUD SCHEME INVOLVING NEW YORK CITY’S COVID-19 HOTEL PROGRAM

Overview of the Fraud Scheme

8. In response to the COVID-19 pandemic, New York City
created the COVID-19 Hotel Room Isolation Program (the “Program”),
described in greater detail below, which was intended principally
for patients convalescing from COVID-19 and for healthcare workers
who needed to be isolated because of exposure to COVID-19. Funded
by New York City and the Federal Emergency Management Agency
(“FEMA”), the Program provided free hotel rooms for qualifying
individuals throughout New York City, including in Manhattan and
the Bronx. The Program existed from approximately March 24, 2020
until July 2020.

9, This ongoing investigation has revealed that the fraud
scheme has defrauded the federal government and New York City out
of more than approximately $400,000 through fraudulently obtaining
hotel rooms from the Program. Specifically, participants in the
fraud abused the Program by (1) securing free Program hotel rooms
for themselves by claiming falsely that they were healthcare
workers, and (2) selling Program hotel rooms to those who did not
qualify for them. In various instances, those who bought
fraudulently obtained Program hotel rooms threw large parties, and
sometimes even engaged in violence.

10. At least one participant in the fraud scheme, CHANETTE
LEWIS, a/k/a “Netty Hott,” the defendant, worked at a particular
call center (Call Center-1), which handled phone calls and certain
reservations for the Program. As a result of LEWIS’s employment,
she had access to legitimate healthcare workers’ identifying
information. As set forth below, LEWIS abused her position,
including by misappropriating healthcare workers’ personal
identifying information, revealing the Program’s inner workings to
co-conspirators, and making unauthorized sales of Program hotel
rooms to those who did not meet the Program’s requirements. LEWIS
and others advertised and discussed these fraudulently obtained
hotel rooms on Facebook.

The COVID-19 Pandemic

11. A novel coronavirus, COVID-19, which causes severe acute
respiratory syndrome, first emerged in China in late 2019. COVID-
19 is infecting people and spreading easily from person-to-person.
It has since infected more than approximately 230 million people
in more than 200 countries and territories, and it has caused more
than 4.7 million deaths. The first confirmed case of COVID-19 in
the United States was in January 2020. By early March 2020, COVID-
19 had reached New York State. During March 2020, the World Health
Organization declared COVID-19 a pandemic, and the President of
the United States declared a national emergency. By late March
2020, New York City was the epicenter of the global health crisis.
The Program

12. Based on my participation in this investigation,
including my review of the New York City government website, my
review of documents, and my conversations with others, I am aware
of the following, among other things:

a. In response to the COVID-19 pandemic, New York City
(the “City”) created the COVID-19 Hotel Room Isolation Program
(the Program). At first, the Program was open only to healthcare
workers. Over time, the Program expanded to additional categories
of at-risk and/or infected individuals. Thus, in total, the
Program was open to (1) patients who had tested positive for COVID-
19; (2) individuals who believed, based on their symptoms, that

they were infected with COVID-19; (3) individuals who did not have
COVID-19 but who lived with someone did; and (4) healthcare workers
who needed to isolate because of exposure to COVID-19.

b. As stated on the City’s website describing the
Program, such individuals “may qualify to self-isolate in a hotel,
free of charge, for up to 14 days if you do not have a safe place
to self-isolate.”! The City’s website supplied examples of those
who may not be able to safely self-isolate -- e.g., “[y]our home
does not have space for you to stay six feet away from others”;
[y]ou share rooms or a bathroom”; or “[y]ou live with someone who
is vulnerable.” Funded by the City and FEMA, the Program provided
free hotel rooms for qualifying individuals. As the City’s website
noted, “This program, including food, linens, and local phone
service, is free for eligible New Yorkers.”

Cc. At first, it was not necessary for an individual to
provide identification in order to access their hotel room. Then,
the City’s Office of Emergency Management (“OEM”) asked hotels
participating in the Program to start checking for valid
identification for non-healthcare workers on or about May 15, 2020,
and for healthcare workers on or about June 8, 2020. Healthcare
workers were also asked to provide their healthcare identification.

d. Those who wished to book a hotel room through the
Program could either call a phone number or use an online hotel
booking platform. OEM had a call center in New York City (Call
Center-1) handle phone calls for the Program from on or about March
24, 2020 to on or about June 8, 2020.

1 COVID-19 Hotel Program; Isolation Hotel Program for Those with
COVID-19, available at https://wwwl.nyc.gov/site/helpnownyc/get-
help/covid-19-hotel-program.page (last visited Sept. 27, 2021).

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e. The Program existed from on or about March 24, 2020
until on or about July 6, 2020 (though the program honored
previously booked rooms until the end of July 2020).

The Fraud Scheme

13. Based on my participation in this investigation --
including (among other things) my review of emails, financial
records, information provided by hotels to the City, publicly
available Facebook posts and videos, Facebook account information
obtained through a judicially authorized search warrant, Call
Center-1 records, information from a Call Center-l1 executive, and
my conversations with others, including law enforcement officers
-- I am aware of the following, among other things:

a. CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant,
was a Call Center-1l employee. LEWIS worked at Call Center-l asa
temporary employee, hired specifically for the Program, from in or
around April 2020 until in or around June 2020.

b. LEWIS booked a large volume of hotel rooms through
the Program. At times, LEWIS misappropriated the personal
identifying information of actual healthcare workers, to which she
had access by virtue of her employment.

Cc. LEWIS and various other participants advertised
hotel rooms on Facebook, including on portions of their accounts
that were openly available to the public over the Internet.

d. LEWIS and other co-conspirators sold fraudulently
obtained hotel rooms -- including rooms located in Manhattan and
the Bronx -- to customers who were ineligible for the Program.

LEWIS and other co-conspirators charged varying amounts depending
on the duration of the customers’ hotel stay; for example, at one
point LEWIS charged $50 for one night, $150 for one week, $300 for
two weeks, and $350 for one month.

e. Customers paid in cash and using electronic payment
services such as Cash App, Zelle, Chime, and PayPal. LEWIS
advertised to potential customers that, when hotels asked for a
healthcare worker’s identification, LEWIS would supply a purported
paystub and a letter asserting that the individual was
(purportedly) a healthcare worker.

f. In addition to selling fraudulently obtained hotel
rooms, participants in the scheme also secured free Program hotel
rooms for themselves by falsely claiming to be healthcare workers.
g. The federal government and New York City paid more
than approximately $400,000 for the hotel rooms that were diverted
as a result of this fraud scheme.

The Defendants

CHANETTE LEWIS

LEWIS’s Fraudulent Personal Use of Program Hotel Rooms

14. Based on my analysis of hotel booking records, I have
learned that CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant,
fraudulently booked at least approximately 28 nights of rooms from
the Program for herself. Specifically:

a. At least approximately 28 nights’ worth of hotel
rooms were booked in LEWIS’ name (“Chanette Lewis”). The
individual using these rooms claimed to be a healthcare worker.

b. The email account associated with these bookings is
a particular Google email account (“LEWIS Email Account-1”), which
is used by LEWIS:

i. Based on my review of Call Center-1 records,
I know that LEWIS provided LEWIS Email Account-1 in connection
with her employment at Call Center-1.

ii. Based on my review of Google records, I know
that LEWIS Email Account-1 is subscribed in LEWIS’ name (“Chanette
Lewis”) and that the account was accessed from an Internet Protocol
(“IP”) address ending in -161 (the “161 IP Address”).2 Based on
my review of IP address subscriber information, I know that the
subscriber for the 161 IP Address is LEWIS’s husband.

Cc. In addition, at least approximately 29 nights of
hotel rooms were booked in the names of two individuals believed
to be LEWIS’s immediate relatives, based on financial records,
Facebook records, and records from the New York City Human
Resources Administration.

15. I believe that CHANETTE LEWIS, a/k/a “Netty Hott,” the
defendant was not, in fact, a healthcare worker. Among other
things, based on my review of two unemployment insurance (“UI”)

2 An IP address is a unique, machine-readable numeric address that
computers use to identify each other on the Internet (e.g.,
123.45.67.890).
applications submitted in 2020 and 2021 under LEWIS’s name and
personal identifiers, I know that LEWIS claimed prior employment
in maintenance and as a call representative in the teleservices
industry. Indeed, at a time of unique need for healthcare workers
during the COVID-19 pandemic, LEWIS was working at a call center.

LEWIS’s Fraudulent Sales of Program Hotel Rooms to Others

16. As set forth herein, based on a combination of hotel
booking records, Facebook posts and messages, and Cash App records,
I believe that CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant,
fraudulently sold at least approximately 1,936 nights’ worth of
Program hotel rooms to others. ?

Facebook Records

17. I respectfully submit that there is probable cause to
believe that a particular Facebook account, with a vanity name of
“Netty Hott” (the “LEWIS Facebook Account”), was used by CHANETTE
LEWIS, a/k/a “Netty Hott,” the defendant. Specifically, based on
a review of Facebook records, including records obtained by a
Court-authorized search warrant:

a. The LEWIS Facebook Account sent several private
messages confirming her identity, including messages in or around
April and May 2020 in which she: (1) supplied her name (e.g.,
“Chanette Lewis”; “Yes u can say me Chanette Lewis I work for omE
311 teleservies”); (2) supplied a photograph of her apparent New
York State Driver’s License, which contains the name “Chanette S
Lewis”; and (3) provided a photograph of an apparent check sent to
“Chanette Lewis” from the United States Treasury.

b. The LEWIS Facebook account was accessed from the
161 IP Address.

Cc. On one occasion, the LEWIS Facebook Account posted
an apparent airplane ticket (for a flight from New York to Miami)
in the name of “Chanette Lewis”.

d. On another occasion, the LEWIS Facebook Account
posted a video to Facebook in which a woman stated, in substance
and part, “Thank you for calling NYC COVID-19 Hotel hotline, my
name is Chanette.” I believe that the woman in this video was
LEWIS, based on a comparison of this video (which clearly features

3 These fraudulent sales occurred both during and after LEWIS’s
employment at Call Center-1, which ended on or about June 11, 2020.

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the speaker’s face) to other photographs and videos of LEWIS,
including photographs from a Government database.

18. Based on my review of the contents of the LEWIS Facebook
Account, which were obtained pursuant to a search warrant, I know
that in the approximate period from April to July 2020, CHANETTE
LEWIS, a/k/a “Netty Hott,” the defendant, used Facebook in
furtherance of the scheme. Based on my review of the LEWIS
Facebook Account from that period, my training and experience, and
my familiarity with this investigation, I believe that the
following examples demonstrate LEWIS’s involvement in the scheme: 4

a. Advertisements posted by LEWIS for the sale of
Program hotel rooms (e.g., “I’m Doing Hotels 60 Percent 5 star
hotels I do not know exactly what hotel u would be place but I

know it would be 5 star kg hotel .. be cash app ready !!”; “Book
Today, $300 For the whole monthhhhhhhhhhhhhh !! !! !! 11%);

b. Direct communications between LEWIS and potential
purchasers of hotel rooms (e.g., “Good evening, basically you would
give me your full name I’1ll1 make the reservation in the borough
you choose . All hotels are 4 and 5 star hotel”);

Cc. Efforts by LEWIS to recruit co-conspirators to help
her sell fraudulently obtained Program hotel rooms, including
offering a $100 commission for each room sold (e.g., after
receiving a message from another individual stating “I’ll sell
them for you send videos of the rooms,” LEWIS responded, “I got
u..For every room u sale for me I give u $100”);

d. Communications in which LEWIS informed customers
that she was creating bookings in which she falsely indicated that
the customer was a health care worker (e.g., “I’m booking it as u
a health care worker”);

e. Admissions that LEWIS stole doctors’ personal
identifying information in furtherance of the scheme (e.g., “I
work for 311 oem that how I got doctors licenses and stuff .
I work in the part that I collect they information and I do and
approval the booking . . . I take doctors and stuff certificate
numbers and stuff”; “I stole some doctor numbers and emails..I was
writing down they employed ID number lmao”; “we book for the doctor

4 All communications quoted in this Complaint are in substance and
in part, and cited Facebook posts and messages are quoted verbatim
herein, including any errors in spelling, grammar, and
punctuation, except where otherwise noted.

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and health care workers . . .I be stealing they employer id number
and license number and stuff”; “I’m taken my job information”);

f. Acknowledgements by LEWIS that the program was
meant for health care workers (e.g., “That the shit I provide
people at my job / It for people who been expose to covid 19 / And
health care workers”);

g. Statements indicating that LEWIS had fraudulent
documents to indicate that customers of the fraud scheme were
health care workers (e.g., “IVE JOB LETTERS AND PAYSTUBS”; “Once
I get the approval on my end for the hotels than u would send me
the money ill send the confirmation along with a job paystub and
job letter that is now require”);

h. Claims by LEWIS that she made significant money
from the scheme (e.g., “I made 16K in 5 days I’m proud of
myselffffft”); and

i. Indications that LEWIS had two co-conspirator
assistants in the scheme, Kimora Daniel and Ta Banks (e.g.,
“Kiaomar Daniels and ta banks those are my assistance”; “I’ve

fucking that kiaomara Daniel girl being a middle man for me and
her dumb ass let someone bring a kid to a hotel and got kick
out.”). (Both of these co-conspirators are discussed below.)

19. In addition, during May and June 2020, the LEWIS Facebook
account engaged in online conversations with a Facebook account
with the vanity name “Ta Banks” (the “BENJAMIN Facebook Account”).
As explained in detail below in paragraph 25, I respectfully submit
that there is probable cause to believe the BENJAMIN Facebook
Account is used by TATIANA BENJAMIN, a/k/a “Ta Banks,” a/k/a “Lyric
Muvaa,” the defendant. These conversations culminated in CHANETTE
LEWIS, a/k/a “Netty Hott,” the defendant, selling information to
BENJAMIN for approximately $800. Based on my review of these
exchanges, I know the following, among other things:

a. During these conversations, LEWIS explained to
BENJAMIN that certain “codes” were required to make hotel room
reservations, and LEWIS admitted that she was selling these codes
to others (“I’m charging people for the codes”).

b. During these conversations, LEWIS told BENJAMIN to
inform customers that they would need valid identification along
with a credit card, but clarified that “the hotel is paid for in
full” already; the customer’s credit card would be charged only if
“they damage propert[y].”

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Cc. On or about June 20, 2020, LEWIS and BENJAMIN
engaged in the following conversation, in substance and part:

LEWIS: I wanna teach u the ropes of it

BENJAMIN: [emojis] let’s get this bread while this shit
active

LEWIS: Exactly

LEWIS: I wouldn’t charge u the whole price , but I’1ll
charge u and teach u the ropes on wat needed

After some back and forth, LEWIS and BENJAMIN agreed on $800. LEWIS
then sent a photograph with handwritten information containing the
names, email addresses, and phone numbers for two employees at
different New York City hospitals, before continuing as follows:

LEWIS: This is for Brooklyn
I’ve to walk u thru it
FaceTime ?

BENJAMIN: Ok
LEWIS: Nyc.gov/covidl9hotel

BENJAMIN then sent LEWIS a photograph of a portion of the online
hotel reservation portal for healthcare workers, before LEWIS
continued as follows:

LEWIS: Always start the employee ID with 1237 for
Brooklyn locations
License # always start with 1001

BENJAMIN then sent LEWIS photographs of a fillable online form,
entitled “Healthcare Worker New Reservation.” BENJAMIN appears to
have filled out the “employer ID number” in the manner that LEWIS
advised, as the number begins with “1237”. Later during this
conversation, LEWIS shared contact information for three
healthcare workers at New York area hospitals, such as the names,
email addresses, and phone numbers for three social workers who
worked at hospitals in Manhattan, Westchester, and Queens.

d On or about June 21, 2020, the conversation

continued, and BENJAMIN appeared to indicate that she would be
splitting proceeds 50-50 with LEWIS, at least for hotel stays of

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a certain length: “Ima only do a month for those fire locations
for $400 every person we go $200 $200 .. .”

e. On or about June 22, 2020, LEWIS wrote to BENJAMIN,
in substance and in part, the following:

I’m at work right now
We have a new update
They caught on

Don’t do no bookings yet

* * *

I’m at work

And a update is today and tomorrow oem isn’t
taking no reservations

Because people been scamming the center

So they are blocking every thing done today
and tomorrow

20. In July 2020, the LEWIS Facebook Account sent the
BENJAMIN Facebook Account a screenshot of an apparent “landing
page,” which gave the user the opportunity to access any of the
listed Google email accounts, or to “Sign into another account,”
or to “Sign out of all accounts”. This particular landing page
listed ten different Google email accounts, including (1) LEWIS
Email Account-1, and (2) an email address that began with “dr.”
(the “Fraudulent Doctor Email Address”). Based on my review of
Google records, I know that the Fraudulent Doctor Email Address
was created on or about June 28, 2020; was linked to LEWIS’s
cellphone number; and was associated with the 161 IP Address (which
as described above, is associated with LEWIS). Based on my review
of hotel reservation records, I know that the Fraudulent Doctor
Email Address was used in connection with obtaining a Program hotel
reservation from on or about June 28, 2020 (i.e., the same day the
Fraudulent Doctor Email Address was created) until on or about
July 7, 2020. The IP address associated with the reservation is
the 161 IP Address. Accordingly, I believe that CHANETTE LEWIS,
a/k/a “Netty Hott,” the defendant, was involved in the creation of
fake email addresses in furtherance of this fraud scheme.

21. Based on my review of certain private Facebook messages
from the LEWIS Facebook Account, I am also aware that, in or around
early July 2020, CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant,
supplied seemingly fabricated documents -- i.e., a “job letter”
and “pay stub” -- to an apparent hotel customer of hers. The “job
letter” asserted that a particular individual was employed as a
Registered Nurse at a particular hospital in New York, New York.

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The “job letter” also included the hospital’s logo and claimed to
be written by a Human Resources Administrator.

22. Based on my review of publicly available posts on the
LEWIS Facebook Account, I have learned that CHANETTE LEWIS, a/k/a
“Netty Hott,” the defendant, claimed to have made various lavish
purchases during (or in the months immediately after) this fraud
scheme, including trips to Las Vegas and Atlantic City; a BMW 750
series car; designer shoes; a spa visit; and several elective
procedures, including dental work and plastic surgery.

Financial Records

23. Based on my analysis of Cash App records, I believe that
CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant, used (at least)
the following three Cash App accounts in furtherance of the scheme
(“LEWIS Cash App Account-1,” “LEWIS Cash App Account-2,” and “LEWIS
Cash App Account-3,” collectively the “LEWIS Cash App Accounts”):

a. LEWIS Cash App Account-1 and LEWIS Cash _ App
Account-2: Account records for both of these accounts indicate
that they are registered in LEWIS’ name (“Chanette Lewis”), contain
identifiers consistent with Call Center-1 employment records, and
were accessed from the 161 IP Address (which as described above,
is associated with LEWIS). In addition, the accounts are
respectively identified with names “nettyhott” and “nettyhot” that
closely resemble LEWIS’ Facebook vanity name, “Netty Hott.”

b. LEWIS Cash App Account-3: Account records indicate
that this account is registered in the name of LEWIS’ husband.
The investigation has revealed that LEWIS openly used some of her
husband’s accounts in furtherance of the scheme, including:
(1) his Facebook account (where wall-posts regarding Program
hotels sometimes said, “via Netty,” which I believe connotes that

“Netty Hott” was in fact posting this information); and (2) his
Cash App account (i.e., LEWIS Cash App Account-3) to a limited
extent -- in particular, where the “memo” portion of certain

transactions specified that they were for “Netty”.

24. Based on my analysis of Cash App records for the LEWIS
Cash App Accounts, as well as records for a PayPal account
registered to LEWIS Email Account-1, I know that, during the period
from April to July 2020, other individuals paid “Lewis” or “Netty”
for at least approximately 1,936 nights’ worth of hotel rooms. A
number of these payments include notations in the memo section
such as: “room”, “hotel”, “telly”, “1 month telly”, “Bronx Room
Peter []”, “Hotel Manhattan 2 week extension for Kenny []”, “bed”,

14
“alpha hotel”, “1 month booking”, “for the 2 week room”, “for 3
nights”, “hotel room”, “telly for the month”, “Josh - Vdays”, “2
week stay in Manhattan”, “Josh 5 days”, “3 week extension please
[heart emoji]”, and “ayo telly”. The prices associated with these
payments are generally consistent with the approximate prices that
CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant, discussed on
Facebook for Program hotel rooms.

TATIANA BENJAMIN

BENJAMIN’s Fraudulent Sales of Program Hotel Rooms to Others

25. 1 respectfully submit that there is probable cause to
believe that the BENJAMIN Facebook Account, with a vanity name of
“Ta Banks,” was used by TATIANA BENJAMIN, a/k/a “Ta Banks,” a/k/a
“Lyric Muvaa,” the defendant. Based on my review of Facebook
account information, I believe that TATIANA BENJAMIN used the
BENJAMIN Facebook account for several reasons, including, among
others, the following:

a. The BENJAMIN Facebook Account was accessed from a
particular IP address ending in -104 (the “104 IP Address”). The
104 IP Address is also associated with three Google email accounts
that I believe are used by BENJAMIN (the “BENJAMIN Google
Accounts”); for two of these three email accounts, according to
subscriber information obtained from Google, the subscriber name
is “Tatiana Benjamin,” and for the third, the subscriber name is
“Ta Banks,” the vanity name for the BENJAMIN Facebook Account.

b. The BENJAMIN Facebook Account is associated with a
particular cellphone number (the “4890 Phone Number”). The 4890
Phone Number is also tied to: (1) a UI benefits application

submitted by BENJAMIN; and (2) the subscriber information for the
BENJAMIN Google Accounts.

Cc. Based on my review of the BENJAMIN Facebook
Account, I know that the account has sent private messages
including, among other things: (1) a photograph of a shipping
label, in which the sender of the package is “Tatiana Benjamin” at
an address in Astoria, New York; (2) a purported employment
verification letter addressed to “Tatiana Benjamin” in Astoria,
New York; and (3) messages in which the sender states that her
first name is “Tatiana,” and her last name is “Benjamin”.

26. As noted above, see supra J 19 (which is incorporated
herein by reference), CHANETTE LEWIS, a/k/a “Netty Hott,” and
TATIANA BENJAMIN, a/k/a “Ta Banks,” a/k/a “Lyric Muvaa,” the

15
defendants, communicated with each other in furtherance of the
scheme using their respective Facebook accounts. In short, during
these conversations, LEWIS explained to BENJAMIN that certain
“codes” were required to make hotel reservations; admitted that
she was selling these codes to others; and sold BENJAMIN, for at
least $800, (1) personal identifying information of at least five
healthcare professionals, and (2) the “codes” themselves (e.g.,
“Always start the employee ID with 1237 for Brooklyn locations /
License # always start with 1001”). In addition, LEWIS and
BENJAMIN appeared to agree to split profits, at least as to the
fraudulent sale of certain hotel reservations.

27. In addition, based on my review of the contents of the
BENJAMIN Facebook Account, I know that TATIANA BENJAMIN, a/k/a “Ta
Banks,” a/k/a “Lyric Muvaa,” the defendant, also engaged in
extensive communications with potential customers of the fraud
scheme and/or other co-conspirators not named herein about the
sale of fraudulently obtained Program hotel rooms, including,
among other examples, the following:

Facebook Messages between BENJAMIN and FB-User-1

BENJAMIN: Yea my friend works in 311 she pulling strings
rn

FB-User-1: So she’s doing them ?

BENJAMIN: Yes. U need a code now to get approve

BENJAMIN: she’s gonna send u the application and then u
tell her ur info send her ur payment
She approves u

* * *

BENJAMIN: cash app LyricMuvaa ( $5 ) ima send u her
Facebook u send her $60 for ur 3 days and u got ya hotel

FB-User-1: Why do you charge for her fb ?

BENJAMIN: Ppl charge for vendors, she’s my vendor

16
Facebook Messages between BENJAMIN and FB-User-2

BENJAMIN: ok my friend work for 311 I’m just the middle
man once u fill the application she will approve it but
u gotta send her the payment.

* * *

FB-User-2: Tell her send me it

BENJAMIN: Netty Hott
FB-User-2: li

BENJAMIN: My bad but she got so many people writing her
u gotta hit her up and tell her Ta Banks sent u.

Facebook Message Between BENJAMIN and FB-User-3

BENJAMIN: Lol anything is possible wen u know a 311
operator S

Facebook Message Between BENJAMIN and FB-User-4

BENJAMIN: Friend at 311 gave me the juice for the hotel
so I been booking ppl rooms

Facebook Messages Involving LEWIS/FB-User-5, and then
BENJAMIN/FB-User-6

In late June 2020 and early July 2020, a Facebook user
(“FB-User-5”) sent messages to the LEWIS Facebook
Account, requesting that LEWIS book hotel rooms for two
people. Specifically, he requested a hotel room for the
3rd-6th for one person (“Customer-1”), and for the 4th-
7th for the other (“Customer-2”), and added, “If not
same hotel then same area if possible.” LEWIS sent this
information (e.g., the Customers’ names and the dates of
their requests) to BENJAMIN over Facebook. Promptly
after receiving this information, BENJAMIN then wrote to
a different Facebook user (“FB-User-6”):

BENJAMIN: Bro make the people’s emails for me
It’s gon be In the emails

17
Then ima send the link

* * *

[Customer-l1’s name] (3rd - 6th) [Customer-2’s name] (4th
Make two emails with those names

Based on my training, experience, and involvement in this
investigation, I believe that in these Facebook messages, BENJAMIN
admitted that she was exploiting the Program, which she knew was
for essential workers; confirmed that she was working with
CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant (“Netty Hott”);
and requested that a co-conspirator create email addresses in
furtherance of the scheme (“Bro make the people’s emails for me”).

28. In or around early July 2020, a number of individuals
sent Facebook messages to the BENJAMIN Facebook Account in which
they attached screenshots of a form email from OEM -- entitled
“Regarding Your Hotel Request” -- which informed the recipient
that they were “not eligible for this program.” TATIANA BENJAMIN,
a/k/a “Ta Banks,” a/k/a “Lyric Muvaa,” the defendant, told at least
some of her customers, in substance and in part, to “disregard the
letter,” because “I don’t think they really gonna kick ppl out.”
Around the same time, BENJAMIN received Facebook messages from an
apparent customer stating, “Boys pulls up to my shit said it was
fraud . . . They said ‘the city called & said it was paid for
fraudulently.’” Around this time, BENJAMIN wrote to CHANETTE
LEWIS, a/k/a “Netty Hott,” the defendant, at the LEWIS Facebook
Account, that “We goin to jail lmao.” Then, BENJAMIN and LEWIS
agreed to: (1) induce additional individuals to pay for hotel rooms
even though the Program appeared to be “over”; and (2) conceal
this misconduct by claiming, falsely, that they had been “hacked,”
as set forth in the following exchange between the BENJAMIN
Facebook Account and the LEWIS Facebook Account:

LEWIS: Smh yea it over

LEWIS: The vendor stop paying

BENJAMIN: no but tell they asses to wait simple !! Let’s
only do 3 days for $100 faster money

Do 20 people a day that’s 2 bands til they stop this
shit

18
BENJAMIN: But let’s Zoe all these people today and tmm
delete the connection page Shit

BENJAMIN: And then say people hacked my page lmaoo

LEWIS: That what we going to do

BENJAMIN: I already zoed people for at least 1,200

BENJAMIN: That why I said we need to change our pics n
shit

BENJAMIN: I posted my in the connection page just now
with the fake page

Cash App Records

29. Based on my analysis of Cash App records, I believe that
TATIANA BENJAMIN, a/k/a “Ta Banks,” a/k/a “Lyric Muvaa,” the
defendant, used at least three Cash App accounts in connection
with this fraud scheme (“BENJAMIN Cash App Account-1,” “BENJAMIN
Cash App Account-2,” and “BENJAMIN Cash App Account-3,”
collectively the “BENJAMIN Cash App Accounts”):

a. I have reviewed BENJAMIN’s UI application, which
lists a date of birth (the “BENJAMIN Birthdate”), a Social Security
Number (the “BENJAMIN SSN”), and a residential address in Astoria,
New York (the “BENJAMIN Address”).

b. BENJAMIN Cash App Account-1 and BENJAMIN Cash App
Account-2: These accounts are subscribed in BENJAMIN’s' name
(“Tatiana Benjamin”), with matching identifiers, including the
BENJAMIN Birthdate, the last four digits of the BENJAMIN SSN, and
the address of the building for the BENJAMIN Address. In addition,
as noted above, in a Facebook message, BENJAMIN directly told
someone to “cash app LyricMuvaa,” which is the account name
associated with BENJAMIN Cash App Account-1. The account name of
BENJAMIN Cash App Account-2 is substantially similar, with only
one different letter: LyricMuvaaa. These two Cash App accounts
are also associated with a common bank account (the “BENJAMIN Bank
Account”).

19
Cc. BENJAMIN Cash App Account-3: The third Cash App
account used by BENJAMIN is also associated with the BENJAMIN Bank
Account. In Facebook messages in or around June and July 2020,
BENJAMIN told multiple people to send payment to this third Cash
App account, and explained in some instances that the account
belonged to the father of her child (e.g., “Okay cash app
SDreskii600 now send ya name and number and borough”; “Send it to
SDreskii600”%; “SDreski600 send it to my daughters dad”; “Send it
to Sdreskii6é00 if u can’t find me. . . That’s my daughter father
shit”).

30. Based on my analysis of these three Cash App accounts,
I know that, for the period from May to July 2020, other
individuals paid TATIANA BENJAMIN, a/k/a “Ta Banks,” a/k/a “Lyric
Muvaa,” the defendant, for at least approximately 398 nights’ worth
of Program hotel rooms. A number of these payments include
notations in the memo section such as: “hotel”, “Telly”, “the

room”, “hotel fel”, “hotel Tyrone”, “Brooklyn hotel”, “room for 1
week. Alexis .”, “1 week.”, “Room”, “for hotel for week”, and
“hotel for july 4-6”. The prices associated with these payments
are generally consistent with the approximate prices that BENJAMIN

discussed on Facebook for Program hotel rooms.

31. Based on my analysis of Cash App records, I know that on
or about June 20, 2020, BENJAMIN Cash App Account-1 paid LEWIS
Cash App Account-2 approximately $800 for “teaching lessons
[emojis omitted],” according to the notation in the memo section.
This $800 payment corresponds to the date of LEWIS and BENJAMIN’s
Facebook conversation quoted above (see supra J 19), in which LEWIS
supplied inside information to BENJAMIN (e.g., “Always start the
employee ID with 1237 for Brooklyn locations”) and said she would
“teach” BENJAMIN “the ropes,” in exchange for $800.

BENJAMIN’s Fraudulent Personal Use of Program Hotel Rooms

32. Based on my analysis of hotel booking records, I have
learned, among other things, that at least approximately 14 nights’
worth of hotel rooms were booked in the name of “Tatiana Benjamin”
using the Program. The individual using these rooms claimed to be
a respiratory therapist, but as set forth below, I believe this
claim was false. There is a Google email account associated with
this booking; the subscriber of that email account is “Tatiana
Benjamin,” and the phone number associated with the account is the
4890 Phone Number. Accordingly, I believe that the “Tatiana
Benjamin” whose name is associated with 14 nights’ worth of hotel
rooms is the same person as the defendant, TATIANA BENJAMIN, a/k/a
“Ta Banks,” a/k/a “Lyric Muvaa.”

20
33. Based on my review of Facebook records, I know that
(1) the user of the BENJAMIN Facebook Account listed her employment
as a “bottle girl,” which entails serving bottles of alcohol to
tables; and (2) in Facebook messages, BENJAMIN explained her
employment situation to LEWIS as follows: “Ima supervisor at red
mango and I work for my gma but my aunt be doing the work for me
and clocking me in so I really just be a red mango.” Based on my
review of public information, I know that Red Mango is a store
that sells frozen yogurt and smoothies. Accordingly, I believe
that defendant TATIANA BENJAMIN’s, a/k/a “Ta Banks,” a/k/a “Lyric
Muvaa, claim of being a respiratory therapist was false.

TATIANA DANIEL

DANTEL’s Fraudulent Personal Use of Program Hotel Rooms

34. Based on my analysis of hotel booking records, I have
learned, among other things, the following:

a. At least six nights’ worth of hotel rooms were
booked in the name of “Tatiiana Daniel” using the Program. The
individual using these rooms claimed to be a respiratory therapist,
but as set forth below, I believe this claim was false.

b. The subscriber for the Google email account
associated with this booking is “Tati Daniel,” and the phone number
associated with this email account is subscribed in the name of
CHANETTE LEWIS, a/k/a “Netty Hott,” the defendant, and is

associated with various accounts belonging to LEWIS.

Based on this information, as well as the information below, I
believe that “Tatiana Daniel”, whose name is associated with six
nights’ worth of hotel rooms is the same person as TATIANA DANIEL,
a/k/a “Kimora Daniel,” the defendant.

35. The records I have reviewed do not support the claim
that TATIANA DANIEL, a/k/a “Kimora Daniel,” the defendant, was a
healthcare worker. Based on my review of a UI application

submitted by DANIEL in June 2020, with a particular date of birth
(the “DANIEL Birthdate”) and Social Security Number (the “DANIEL
SSN”) that are linked to DANIEL through financial accounts and a
U.S. Passport application, I am aware that DANIEL represented that
her Education Level was “Grade 12,” and her last employment was as
a “Sales agent” at a “Huropean wax center” in Brooklyn, New York.

21
DANIEL’s Fraudulent Sales of Program Hotel Rooms to Others

36. As set forth herein, based on a combination of hotel
booking records, Facebook posts and messages, financial records,
and email records, I believe that TATIANA DANIEL, a/k/a “Kimora
Daniel,” the defendant, fraudulently sold at least approximately
144 nights’ worth of Program hotel rooms to others.

Email Records

37. I believe that a particular Google email account
(“DANIEL Email Account-1”), registered to “Tatiana Daniel,” was
used by TATIANA DANIEL, a/k/a “Kimora Daniel,” the defendant.
Among other things, DANIEL Email Account-1 is associated with at
least four financial accounts that belong to “Tatiana Daniel”.
These four financial accounts either contain the DANIEL Birthdate,
the DANIEL SSN, the last four digits of the DANIEL SSN, or a

combination of these identifiers. The subscriber information for
at least one of these four financial accounts also includes a
particular New York State Driver’s License Number (“NYSDL”); based

on my review of a government database, which contains information
from the New York State Department of Motor Vehicles, I know that
this NYSDL Number is associated with DANIEL, listing the DANIEL
Birthdate. Thus, I believe that DANIEL used DANIEL Email Account-1.

Facebook Records

38. I believe that a particular Facebook account, with the
vanity name of “Kimora Daniel,” was used by TATIANA DANIEL, a/k/a
“Kimora Daniel,” the defendant (the “DANIEL Facebook Account”).
Based on my review of Facebook records, I believe that DANIEL used
the DANIEL Facebook Account for several reasons, including the
following:

a. The DANIEL Facebook Account sent a private message
confirming her identity: Another Facebook user asked, “Tatiana
Daniel? Just making sure”, and the user replied, “Yes that’s me.”

b. The DANIEL Facebook Account is associated with both
DANIEL Email Account-1 and the DANIEL Birthdate.

Cc. The DANIEL Facebook Account notes her employment as
a sales agent at a European Wax Center, which is what DANIEL
represented as her most recent employment in her UI benefits
application in June 2020.

22
d. The DANIEL Facebook Account is associated with a
particular IP address ending in -45 (the “45 IP Address”). The 45
IP Address is also associated with at least two financial accounts
that: (1) belong to a subscriber named “Tatiana Daniel”;
(2) contain the DANIEL Birthdate; and (3) contain the last four
digits of the DANIEL SSN.

39. Based on my review of the contents of the DANIEL Facebook
Account, which were obtained pursuant to a search warrant, I know
that in the approximate period from June to July 2020, this account
(among other things) advertised the sale of fraudulently obtained
hotel rooms; communicated with potential purchasers of hotel
rooms; mentioned that TATIANA DANIEL, a/k/a “Kimora Daniel,” the
defendant, was working with CHANETTE LEWIS, a/k/a “Netty Hott,”
the defendant; and acknowledged that the Program was intended for
healthcare workers. Specifically, during this period, DANIEL’s
Facebook wall posts and private messages included the following:

a. After DANIEL received a private message from
another Facebook user asking in substance what she was doing,
DANIEL replied, “Selling these Telly’s”.

b. “T have another business...I’m working with netty”.

Cc. After DANIEL received a private message from
another Facebook user stating, “Hi I’m looking for a hotel
somewhere around downtown Brooklyn for Father’s Day,” DANIEL
replied, “Good morning , yes I have hotels. 3 night minimum 45S a
night , breakfast included if you want the full 14 days it will be
325 and it can also be extended right now I currently have the
Hilton and Hamilton downtown Brooklyn...All hotels I have right
now you can check in starting today”.

d. In a private message to another Facebook user,
DANIEL wrote, “40S a night 1505 a week 250S 2 weeks 300$ entire
month ( ONLY TODAY ) ] 3 night minimum Please provide your First
& Last Name Email Number Also when checking in you need a credit
card or debit card to put on file as you would for any other hotel
for security damages or theft .” The recipient of this message
then replied, “Saydatttt does it matter where ?” and DANIEL
responded, “Yes NYC love”.

e. “Today I will be doing hotels from 2pm - 9pm If you
would like to book a hotel please comment below 300$ 1 month 250S$

20 days 150S 10 days 100S 3 days MUST BE CASH APP READY J”.

23
f. “T cannot pick a specific hotel for you because the
system generates it and picks the hotel I can only place you in
the borough you wanna be in”.

40. Based on my training, experience, and involvement in
this investigation, I believe that in these Facebook posts and
messages, TATIANA DANIEL, a/k/a “Kimora Daniel,” the defendant:

a. Advertised the sale of Program hotel rooms (e.g.,
“Good morning , anyone needs a HOTEL? Today I will be doing hotels
from 2pm-9pm If you would like to book a hotel please comment below

300S 1 month 2508 20 days 150S 10 days MUST BE CASH APP READY J No
REFUND POLICY only Jf..”).

b. Communicated directly with potential purchasers of
hotel rooms (e.g., in response to an inquiry about hotel
availability, DANIEL replied, “Good morning, yes I have hotels. 3
night minimum 45S a night, breakfast included if you want the full
14 days it will be 325 and it can also be extended right now I
currently have the Hilton and Hamilton downtown Brooklyn...all
hotels you can check in starting today”).

Cc. Confirmed that she was working with CHANETTE LEWIS,
a/k/a “Netty Hott,” the defendant (e.g., “TI have another
business...I’m working with netty”).

d. Explained some of the inner workings of the scheme

(e.g., “I cannot pick a specific hotel for you because the system
generates it and picks the hotel I can only place you in the
borough you wanna be in”).

41. In addition, based on my review of the DANIEL Facebook
account, I know that CHANETTE LEWIS, a/k/a “Netty Hott,” and
TATIANA DANIEL, a/k/a “Kimora Daniel,” the defendants, exchanged
various Facebook messages in furtherance of the scheme using the
LEWIS Facebook Account and the DANIEL Facebook Account. For
example, on or about June 11, 2020, LEWIS sought DANIEL’s advice
as to pricing, asking, “What u think I should put the price of ?
Because I’m doing them 2 weeks straight breakfast included.” On
or about June 18, 2020, LEWIS sent DANIEL a screenshot of a
Facebook post in which LEWIS requested “a worker to help me out
Today & Tomorrow” in exchange for $300 -- “someone loyal a quick
learner”. LEWIS told DANIEL that she had “97 request”, and DANIEL
replied, “BITCH LET ME HELP YOU”. And on or about June 28, 2020,
DANIEL and LEWIS had the following exchange:

24
DANIEL: We gotta relocate that bitch they keep asking
for employee ID
Wanna teach me now after the relocation?

LEWIS: I’11 teach u in the AM

DANIEL: Alright I gotttt maddd ppl

42. Based on my review of the DANIEL Facebook Account, I
know that TATIANA DANIEL, a/k/a “Kimora Daniel,” the defendant,
exchanged Facebook messages in furtherance of the scheme in June
and July 2020 with a Facebook account with vanity name “Heaven
West” (the “WEST Facebook Account”), which as explained below, has
been identified through the investigation as being used by HEAVEN
WEST, the defendant. Those messages included the following:

DANIEL: Sis you still got hotel RL
If so how long how many days

WEST: I’m only doing 1 week & 2 week hotel
And a week is 2 bills 2 weeks 3 bills 1 month is
450

DANIEL: How long you got rl for?

Accordingly, I believe that TATIANA DANIEL, a/k/a “Kimora Daniel,”
and HEAVEN WEST, the defendants, worked together in connection
with this fraud on the Program.

Cash App Records

43. Based on my analysis of Cash App records, I believe that
at least sixteen Cash App accounts were used in general by TATIANA
DANIEL, a/k/a “Kimora Daniel,” the defendant, and at least three

of them are directly relevant to this fraud. For each of these
three Cash App accounts (the “DANIEL Cash App Accounts”): (1) the
account name is “Tatiana Daniel”; (2) the date of birth is the

DANIEL Birthdate; and (3) the accounts reference the last four
digits of the DANIEL SSN. Two of these three accounts also are
connected to the 45 IP Address and one uses DANIEL Email Account-1l.

44. Based on my analysis of Cash App account records for the
DANIEL Cash App Accounts, I know that, for the period from May to
July 2020, other individuals paid “Tatiana Daniel” for at least
approximately 144 nights’ worth of Program hotel rooms. A number

25
of these payments to “Daniel” include notations in the memo section
such as: “hotel”, “telly”, “10 days”, “telly for a month”, and
“Ryah for three day hotel”. The prices associated with these
payments are generally consistent with the approximate prices that
DANIEL discussed on Facebook for Program hotel rooms.

45. Based on my analysis of Cash App Account records, I know
that, for the period from May to July 2020, CHANETTE LEWIS, a/k/a
“Netty Hott,” and TATIANA DANIEL, a/k/a “Kimora Daniel,” the
defendants, had at least eight transactions between them.

HEAVEN WEST

WEST’s Fraudulent Personal Use of Program Hotel Rooms

46. Based on my analysis of hotel booking records, I have
learned, among other things, the following:

a. At least approximately 12 nights’ worth of hotel
rooms were booked in the name of “Heaven West” using the Program.
The individual using these rooms claimed to be a custodian at NYC
Health and Hospitals, and a food service worker at two New York
City area hospitals. As set forth in detail below, I believe that
these claims of working at these hospitals were false.

b. The email accounts associated with these bookings
include, among others, a particular Google email account (“WEST
Email Account-1”).

i. Based on my review of Google records for WEST
Email Account-1, I know that the subscriber name is “Heaven West,”
and the recovery email account is another Google email account
(“WEST Email Account-2”).

ii. Based on my review of Google records for WEST
Email Account-2, I know that the subscriber name is “Heaven West”.

Cc. Based on my review of Facebook subscriber
information, I know that the WEST Facebook Account is linked to
both WEST Email Accounts-1 and -2, and contains a particular
birthdate (the “WEST Birthdate”).

d. Based on my review of financial accounts, I know
that at least three financial accounts are associated with the
name “Heaven West” and WEST Email Account-2; two of these three
accounts include a birthdate, which is the WEST Birthdate.

26
Accordingly, I believe that “Heaven West” whose name is associated
with (at least) 12 nights’ worth of hotel rooms is the same person
as HEAVEN WEST, the defendant. Indeed, the WEST Facebook Account
shared a screenshot of a “Confirmation Email” from New York City
Emergency Management, confirming that “Heaven West” was booked for
14 nights at a hotel in New York, New York.

47. I believe that HEAVEN WEST, the defendant, was not, in
fact, a healthcare worker or hospital employee. Among other things:

a. I reviewed a UI application submitted in April 2020
under the name “Heaven A. West” -- whom I believe to be WEST, based
on the name, the WEST Birthdate, the Social Security Number, phone
number, and the residential address. On this UI application, WEST
represented that her last employment was as an “Usher” at a
document management company in New York.

b. Based on my review of records from the U.S. Small
Business Administration, I am aware that in or around July 2020,
an individual named “Heaven West” -- associated with both the WEST
Birthdate and WEST Email Account-2 -- filed an application for a
loan (through the COVID-19 Economic Injury Disaster Loan program) ;
in this loan application, WEST represented that she was the owner
of a sole proprietorship, specifically a “Hair & Nail Salon.”

WEST’s Fraudulent Sales of Program Hotel Rooms to Others

48. As set forth herein, based on a combination of hotel
booking records, Facebook posts and messages, and financial
records, I believe that HEAVEN WEST, the defendant, fraudulently
sold at least approximately 179 nights’ worth of Program hotel
rooms to others.

Facebook Records

49, I believe that HEAVEN WEST, the defendant, used the WEST
Facebook Account (with vanity name “Heaven West”). Based on my
review of Facebook records, I believe that WEST used the WEST
Facebook Account for several reasons, including the following:

a. The WEST Facebook Account is associated with WEST
Email Account-1l.

b. The WEST Facebook Account lists the WEST Birthdate.
Cc. The WEST Facebook Account sent various private
messages confirming identity, including one containing a

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photograph of her apparent New York State Identification Card,
which includes the WEST Birthdate and the name, “Heaven Anu West.”
In other messages, she supplied her name (“Heaven West”) and her
birthday (the WEST Birthdate).

d. The WEST Facebook Account is linked to a financial
account that, in turn, is associated with WEST Email Account-2.

50. Based on my review of the contents of the WEST Facebook
Account, which were obtained pursuant to a search warrant, I know
that in the period from April to July 2020, this account (among
other things) advertised the sale of fraudulently obtained hotel
rooms; communicated with potential purchasers of hotel rooms; and
noted her awareness that the Program was intended for healthcare
workers. Between April and July 2020, HEAVEN WEST, the defendant,
made wall posts and sent private messages that included the
following, all of which are in substance and/or in part:

e WEST received a private message from another Facebook
user (“FB-User-7”) stating, “I could try to get you a
free room / Send me your first and last name if they
approve the application you could check in the hotel
/ Have a lil party in there,” and WEST replied, “How?”
FB-User-7 responded, “The essential workers
application,” to which WEST replied, “Oh ok”.

e After WEST received a private message from another
Facebook user (“FB-User-8”) stating, “You know how to
do the application right,” WEST replied, “Yea”. FB-
User-8 continued, “Make a fake email to send your
Confirmations too.” WEST replied, “I got them already
I’m Gucci.” FB-User-8 responded, “so just do that
and tax n[*****] for confirmations
Newyorkpresibytarian emails end like Nyp.org,” and
WEST replied, “Ik / Bro I got ittttttttt / LMFAOQOOOOO
I’m all set” and added, “I got 3 people Telly’s
today.”

e “Who need a hotel / ask me questions about hotels....”

e WEST received a message from another Facebook user
asking how many “Telly’s” WEST “could get,” and WEST
replied, “Any amount / I just need full names / And
the amount of days.”

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“OK YALL I LIED I GOT 2 HOTELS IN THE BRONX AND 2 IN
MANHATTAN FOR SALE. yall know the drill - be CASH APP
OR ZELLE ready !!!!%

“ANYONE NEED A HOTEL?

1 week is 2 bills

2 weeks 3 bills

1 month is 450

IF INTERESTED INBOX ME & COMMENT I INBOXED YOU”

“Please do not ask me to hold a hotel room for you,
because if someone is CASH APP AND APPLE PAY READY
I’m selling it !”

When one potential customer objected to WEST’s price-
per-night ($50) as too high, WEST replied that this
room “go for 135/night / I’m giving you a major deal
/ You can go to kimora for Telly’s tho besides me”

“When inboxing me for Telly’s please send: -desired
check in date -full name -budget -how many days you

want y’all been great ”

“T have no locations in queens
I can give you the Manhattan Telly for cheaper Imk”

WEST wrote to an apparent hotel customer, “since I
used ya name / You got a friend that check into for
you? .. . Because i think they going to dub your name
Since I used it already.” The customer replied, “Okay
bet so use [a different name, which he supplied].”

An apparent hotel customer wrote private messages to
WEST stating, “The security be bitchin ? / Cause imma
have a few people”. WEST replied, “Nah . . . No more
than 5-7 people.” Later, WEST added, “Make sure you
don’t go all up at once.”

After WEST received a private message from another
Facebook user (“FB-User-9”) stating, “good morning
you got rooms sis?”, WEST replied, “Nah I dead don’t
bro / All essential hotels are clipped” and added:
“They finding out we was scamming the system lol.”

29
51. Based on my review of the contents of the WEST Facebook
Account, I know that, during the period of the fraud scheme, one
customer (“FB-User-10”) complained to WEST in a string of messages,
writing in substance and in part that:

I’m the one getting played rn be I gave you 200S$
for a telly and still don’t have a telly

and now ur not tryna give my bread back for a
room that u didn’t even pay for bc the hote said
the government Pays for the room. . . You messed
up the dates the first time which is why I was
unable to check in and I told you why I couldn’t
check in and now your trying to tell me I receive
my goods and services when I did not be I’m not
staying in that hotel it got canceled bc nobody
said anything about the names having to match up
and bc they were being strict about the program.

WEST replied over Facebook, via voice messages, that she would not
issue a refund, and explained, in part: “I do this every single
day, you the only person I’m having problems with.” WEST added,
in part, “When you went to the hotel the second time with the
second confirmation, I asked you to give me a different name.”
However, WEST did offer a replacement hotel room to FB-User-10,
noting in part, “TI could make a whole ‘nother
reservation... I’ll get the confirmation within two hours. I
won’t put it in your name.” During these voice messages, WEST
explained the process, stating in part: “This is a essential -
essential worker compensation thing for the hotels. Like,
everybody - anybody can literally get it. Like, it’s a free hotel.
But like nobody knows how to get it. . . That’s what I’m selling
you. . . I get them for free and I sell them for the low. ‘'Cuz if
you buy it on your own, it’s gonna be triple, double . . . what
I’m giving y’all.”

52. Based on my training, experience, and involvement in
this investigation, I believe that in these wall posts and private
messages, HEAVEN WEST, the defendant:

a. Advertised the sale of Program hotel rooms (e.g.,
“ANYONE NEED A HOTEL? 1 week is 2 bills 2 weeks 3 bills 1 month is
450 IF INTERESTED INBOX ME & COMMENT I INBOXED YOU”).

b. Was informed by one person, and then told another,
that Program hotels were for essential workers (e.g., FB-User-7
told WEST that the hotel rooms were available through “The
essential workers application”).

30
Cc. Was told that “the government Pays for the room.”

d. Stated that the hotel rooms were “free.”
e. Admitted that the hotel scheme was a scam (e.g.,
“All essential hotels are clipped . . . They finding out we was

scamming the system lol”).

f. Admitted putting hotel reservations in the name of
someone whom she knew was not in fact the intended user of the
room (e.g., “since I used ya name / You got a friend that check
into for you ? Because i think they going to dub your name since
I used it already.”; “I won’t put it in your name.”)

53. In addition, ina series of private “voice messages” on
Facebook, HEAVEN WEST, the defendant, explained the process to
various customers or potential customers, including, among other
things, instructing one individual to return the hotel room key to
WEST herself, not to the hotel, because WEST had reserved the room
for two weeks and was selling portions (e.g., in 2-3 day blocks)
to others.

Cash App Records

54. Based on my analysis of Cash App records, I believe that
at least one Cash App account was used by HEAVEN WEST, the
defendant (the “WEST Cash App Account”). The account name for the
WEST Cash App Account is “Heaven West”; the date of birth
associated with the account is the WEST Birthdate; the account is
tied to WEST Email Account-2; and the account is linked to a
cellphone number that is also linked to the WEST Facebook Account.

55. Based on my analysis of Cash App records for the WEST
Cash App Account, I know that, during the period from approximately
May to July 2020, others paid HEAVEN WEST, the defendant, for at
least about 179 nights’ worth of Program hotel rooms. Certain
payments to WEST include a notation in the memo section such as
“telly”. Additionally, the prices associated with these payments
are generally consistent with the approximate prices that WEST
discussed on Facebook for Program hotel rooms. Some payments from
WEST also include notations such as “Telly” or “hotel refund.”

56. Based on my review of Facebook records and Cash App

records, my training and experience, and my participation in this
investigation, I believe that HEAVEN WEST, the defendant, supplied

31
direction to at least one co-conspirator (“CC-1”) in furtherance
of the scheme. Based on various Facebook messages, I believe that
WEST had CC-1 assist WEST with various aspects of the scheme,
including providing the hotel room key to customers, collecting
customer payments, and receiving inquiries from potential
customers. For example, on or about June 17, 2020, WEST reserved
a Program hotel room for a particular customer and then told the
customer to contact “my bff for the room key,” whose name and phone
number WEST supplied. WEST told this customer to “Call [CC-1’s]
number right after you send payment so y’all can make a time for
you to go over there.” On another occasion (on or about July 3,
2020), WEST told a hotel customer that her “friend” would contact
the customer “for the 150,” and WEST then supplied CC-1’s phone
number, further indicating that WEST outsourced some aspects of
the scheme to CC-1. In addition, on or about June 23, 2020, WEST
posted publicly, “Anyone who need a hotel TONIGHT hit up [CC-1] on
fb. Any other days HIT ME UP,” which I believe connotes that CC-1
was available to receive hotel inquiries on WEST’s behalf. Based
on my review of Cash App records, during the approximate period
from June to July 2020, the HEAVEN WEST Cash App Account sent more
than approximately $1,000 in total, across more than ten
transactions, to Cash App Accounts associated with CC-1. Finally,
on or about June 23, 2020, HEAVEN WEST posted a Facebook “Status”
that, in substance and part, she was “Still taking Telly’s”; a co-
conspirator (“CC-2”) then referred WEST three potential customers;
and WEST instructed CC-2, “tell them all to inbox me [CC-2].”

CHANETTE LEWIS’S FRAUD SCHEME INVOLVING UNEMPLOYMENT BENEFITS

57. Based on my involvement in this investigation, including
my review of records and my conversations with others, including
a Special Agent from the U.S. Department of Labor -- Office of

Inspector General (“DOL Agent-1”), I have learned the following,
in substance and in part:

a. Unemployment Insurance (“UI”) is a state-federal
program that provides monetary benefits to eligible lawful
workers. UI payments (benefits) are intended to provide temporary
financial assistance to lawful workers who are unemployed through
no fault of their own. In the State of New York, the state’s
Department of Labor (the “NY DOL”) administers the UI program.

b. On or about March 27, 2020, the Coronavirus Aid,
Relief, and Economic Security (“CARES”) Act was signed into law.
Under the CARES Act, UI eligibility was expanded to provide
assistance as a result of the ongoing COVID-19 pandemic. In total,
under the CARES Act (and subsequent Acts of Congress), more than

32
approximately $800 billion in additional federal funds for UI
benefits have been appropriated since in or around March 2020.

c. The NY DOL offers an online website (the “Website”)
through which applicants can apply for COVID-19 benefits and verify
unemployment status. To apply for COVID-19 benefits through the
Website, an applicant must complete a form that includes, among
other things, the applicant’s name, date of birth, social security
number, and address. In addition, the applicant can direct that
the NY DOL send any approved funds to a specific bank account or
to a debit card.

58. Based on my involvement in this investigation, including
my review of records and my conversations with DOL Agent-1, I am
aware that “Chanette Lewis” has filed two unemployment benefits
applications during the COVID-19 pandemic -- one on or about
November 25, 2020, and the other on or about March 21, 2021. (The
November 25, 2020 application sought not only prospective UI
benefits, but also retroactive UI benefits dating back to March
2020.) Based on the name, date of birth, Social Security Number,
email address, residential address, and Driver’s License number on
these applications, I believe that each was filed by CHANETTE
LEWIS, a/k/a “Netty Hott,” the defendant. As a result of these
applications, I know that LEWIS has received at least approximately
$46,000 in UI benefits for the period from in or around March 2020

to the present. However, as noted above, LEWIS was employed at
Call Center-1 for at least some of this period, namely April to
mid-June 2020. As a result, for at least several months, LEWIS

was both employed and receiving benefits as though she were
unemployed. Based on my review of these two unemployment benefits
applications, I believe that each contains material
misrepresentations, including but not limited to the following:

LEWIS’s November 25, 2020 Application

a. In response to a question about the last date she
worked, LEWIS represented that the last date she worked was
February 28, 2020.

b. In response to a question that asked, “Are you
filing this claim because your workplace closed, you were isolated
or you were quarantined due to COVID-19, also known as the
Coronavirus?”, LEWIS answered, “Yes.”

Cc. In response to a question that asked for the
applicant’s most recent employer, LEWIS represented that she most

33
recently worked performing “maintenance” at “done right” in
Brooklyn, New York.

d. In response to a question that asked why she was no
longer working for her most recent employer, LEWIS answered, “Lack
of work — COVID.”

e. In response to a question that asked, “Was all the
money you earned in 2019 and up until today in 2020 from running
your own business?”, LEWIS answered, “Yes.”

f. In response to a question that asked, “Did you lose
all of your employment in the 18 months due to lack of work?”,
LEWIS answered, “Yes.”

g. I believe that each of these answers was false.
Contrary to LEWIS’s representations, the last date that she worked
was not in February 2020; her most recent employment was not in
“maintenance” for an employer named “done right”; and her
employment did not cease due to the COVID-19 pandemic. Rather, as
noted above, she worked as a call representative at Call Center-1
from approximately April to June 2020, and her employment ceased
because she stopped showing up to work. In addition, at least as
to Call Center-1, LEWIS did not run that business.

LEWIS’s March 21, 2021 Application

h. In response to a question about the last date
worked, LEWIS represented that the last date she worked was May
14, 2020.

i. In response to a question about the reason that her
most recent employment ended, LEWIS represented that her most
recent employment as a “Call representative” in Brooklyn ended due
to “Lack of Work — COVID.”

5. I believe that each of these answers was materially
false. Contrary to LEWIS’s representations, her employment did
not cease due to “lack of work” or to the COVID-19 pandemic.
Rather, her employment at Call Center-1l existed due to the
pandemic, and her employment ceased because she stopped showing up
to work.

34
WHEREFORE, the deponent respectfully requests that warrants
be issued for the arrests of 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 that they be arrested and imprisoned, or bailed, as the case
may be.

/s/ sworn telephonically

JARED EANNUCCI
Special Agent
United States Attorney’s Office, SDNY

Sworn to me through the transmission of this
Affidavit by reliable electronic means, pursuant
to Federal Rules of Criminal Procedure 41(d) (3)
and 4.1, this 28th day of September, 2021

THE HONORABLE GABRIEL W. GORENSTEIN
Chief United States Magistrate Judge
Southern District of New York

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