Information — United States v. Crystal Jones (D. Md., Dkt. 1, April 26, 2021)
Summary
An Information filed April 26, 2021, as Document 1 in United States of America v. Crystal Jones, a/k/a "Crystal Powell-Jones," Criminal No. GLR-21-0126, in the U.S. District Court for the District of Maryland. Count One (Wire Fraud, 18 U.S.C. § 1343) alleges a scheme to defraud Victim Lender 1 involving false invoices of JAG Professional Resources, and lists a May 12, 2016 Fed Wire transfer of $47,666.65. Count Two (Willful Failure to Account For and Pay Over Tax, 26 U.S.C. § 7202) alleges a tax loss of at least $523,244.38 and lists the quarter ended June 30, 2015. A forfeiture allegation states that the United States will seek a money judgment of at least $449,123.73.
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“Information — United States v. Crystal Jones (D. Md., Dkt. 1, April 26, 2021).”
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Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 1 of 9
DJB/HMG: 2017R00587
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
UNITED STATES OF AMERICA *
*
v. * CRIMINAL NO. GLR-21-0126
*
CRYSTAL JONES, * (Wire Fraud, 18 U.S.C. § 1343; Willful
a/k/a “Crystal Powell-Jones,” * Failure to Account For and Pay Over
* Tax, 26 U.S.C. § 7202; Forfeiture, 18
Defendant * U.S.C. § 981(a)(1)(C), 21 U.S.C.
* § 853(p), 28 U.S.C. § 2461(c))
*
*******
INFORMATION
COUNT ONE
(Wire Fraud)
The U.S. Attorney for the District of Maryland charges that:
Introduction
At times relevant to this Information:
1. Defendant CRYSTAL JONES (“JONES”) and Individual 1 were residents of
Maryland.
2. JAG Professional Resources (“JAG”), a temporary employment agency, was a
partnership doing business in Howard County, Maryland, among other places.
3. JONES was an owner and managing partner of JAG, which operated from at least
2012 through August 2017. As JAG’s managing partner, JONES exercised control over every
aspect of JAG’s business, including JAG’s finances.
4. JONES also controlled a PNC bank account ending x2006, which was located in
Maryland and was held in JAG’s name (“JAG PNC x2006”).
5. Individual 1, JONES’s relative, was a silent minority partner in JAG.
Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 2 of 9
6. The City in Ohio was a municipal government located in Ohio that contracted
with JAG for temporary employment services from in or about February 2013 until in or about
February 2016.
7. Victim Lender 1 was a factoring company headquartered in Illinois.
8. Factoring was a means by which cash intensive businesses could obtain cash
quickly and reliably by leveraging accounts receivable. JAG was a cash intensive business
because JAG had to pay its temporary employees weekly or biweekly, but typically did not
receive payment from JAG’s clients until at least 30 days after services had been rendered.
Consequently, JAG could be short of the cash flow needed to pay its employees each week, but
its business model was theoretically profitable if all outstanding invoices were paid.
9. From in or about February 2013 to at least October 2016, Victim Lender 1
provided factoring services to JONES and JAG. During that time period, JAG sold its account
receivables to Victim Lender 1 and, in return, JAG received from Victim 1 cash advances
totaling approximately 90% of JAG’s accounts receivables. Upon collection of the receivables
(that is, upon receiving payments from JAG’s clients on the outstanding invoices), Victim
Lender 1 sent JAG the remaining 10% of the invoice that had been purchased, less fees Victim
Lender 1 charged for its factoring services.
10. From March 2016 to in or about May 2016, JONES caused JAG to sell Victim
Lender 1 false and fraudulent invoices totaling more than $350,000 for services that JAG had
purportedly provided to the City in Ohio. In fact, JAG’s relationship with the City in Ohio ended
in or about February 2016.
The Scheme to Defraud
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Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 3 of 9
11. Between at least in or about October 2012 and in or about August 2017, in the
District of Maryland and elsewhere,
CRYSTAL JONES,
a/k/a “Crystal Powell-Jones,”
knowingly and willfully devised and intended to devise a scheme and artifice to defraud Victim
Lender 1 and to obtain money from Victim Lender 1, as well as other lenders, by means of
materially false and fraudulent pretenses, representations, and promises (“the scheme to
defraud”).
Manner and Means of Scheme to Defraud
It was part of the scheme to defraud that:
12. JONES misused JAG to obtain corporate and personal financing that benefitted
JONES, her family members, and friends.
13. JONES created false and fraudulent paystubs purportedly issued by JAG so
JONES could obtain loans for her own benefit and the benefit of others.
14. JONES created false and fraudulent invoices that purported to represent services
that JAG had provided.
15. JONES sold false and fraudulent invoices to Victim Lender 1 as if they were
legitimate accounts receivable.
16. JONES sent emails to representatives of Victim Lender 1 in which JONES
falsely stated that payments on the false and fraudulent invoices were imminent to lull Victim
Lender 1 into a false sense of security about the outstanding collections.
17. JONES appropriated the names, signatures, and personal identifying information
of Individual 1 and others for JONES’s own benefit.
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Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 4 of 9
The Charges
18. On or about the date below, in the District of Maryland and elsewhere, the
defendant,
CRYSTAL JONES,
a/k/a “Crystal Powell-Jones”
for the purpose of executing and attempting to execute the scheme to defraud, knowingly
transmitted and caused to be transmitted in interstate commerce by means of wire
communications, any writings, signs, signals, pictures, and sounds, as set forth below:
Count Date Description of Wire
1 5/12/2016 A $47,666.65 Fed Wire transfer from Victim Lender 1, which
originated outside of Maryland, and which was deposited into the JAG
PNC x2006 account.
18 U.S.C. § 1343
18 U.S.C. § 2
4
Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 5 of 9
COUNT TWO
(Willful Failure to Account For and Pay Over Tax)
The U.S. Attorney for the District of Maryland further charges that:
1. Paragraphs 1 through 17 of Count One are incorporated here.
Introduction
2. The Internal Revenue Service (“IRS”) was an agency of the United States
Department of the Treasury responsible for enforcing and administering the tax laws of the
United States, and collecting taxes owed to the United States. Among the taxes that the IRS
administers are “employment taxes” or “payroll taxes,” which includes federal income
withholding taxes (“withholding taxes”) and Federal Insurance Contribution Act taxes (“FICA
taxes”).
a. In general, an employer must deduct and withhold income tax on the amount of
wages paid to its employees and must pay over those withheld income taxes to the
IRS. Federal income tax withholding is generally based on the number of
allowances claimed by the employee on his or her W-4 Form.
b. FICA taxes are comprised of two parts: First, old-age, survivor, and disability
insurance, which is commonly referred to as “Social Security,” and, second,
health insurance, which is commonly referred to as “Medicare.” Social Security
taxes are used to fund retirement and disability benefits, while Medicare taxes are
used to provide health and medical benefits for the aged and disabled.
3. Employers are required to file with the IRS an Employer's Quarterly Federal
Income Tax Return—Form 941 (“Form 941”), on a quarterly basis. The Form 941 is due at the
end of the month following each end of the calendar quarter (April 30, July 31, October 31, and
5
Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 6 of 9
January 31). The employer must report on the Form 941 the total amount of the employees’
wages and any other compensation subject to withholding, the total amount of income tax
withheld, the total amount of FICA taxes due, and the total tax deposits.
4. When the Form 941 is filed, employers are required to pay over to the IRS the
employment taxes that the employer has withheld, along with the employers’ share of the FICA
taxes. The corporate official responsible for collecting, accounting for, and paying over the
employment taxes is known as the “responsible person.”
5. As the managing partner of JAG, JONES was responsible for collecting,
accounting for, and paying over to the IRS all of JAG’s payroll taxes.
6. From January 2014 to in or about October 2016, JONES withheld payroll taxes
from the wages paid to JAG’s employees. However, for the quarters ending March 31, 2014 to
December 31, 2016, JONES and JAG failed to file with the IRS any Forms 941 accounting for
the payroll taxes that had been collected.
7. Additionally, with the exception of one partial payment made in the second
quarter of the 2015 tax year, for the 2014, 2015, and 2016 tax years (and the payroll quarters
ending therein) JONES and JAG failed to pay over to the IRS any of the payroll taxes withheld
from JAG employees.
8. The failure of JONES and JAG to account for and pay over payroll taxes to the
IRS resulted in a tax loss to the United States of at least $523,244.38.
The Charges
9. On or about the date below, in the District of Maryland and elsewhere, the
defendant,
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Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 7 of 9
CRYSTAL JONES,
a/k/a “Crystal Powell-Jones,”
willfully failed to truthfully account for and pay over to the IRS the federal income taxes and
FICA taxes withheld from JAG employees, which was due and owing to the United States of
America, as set forth below:
Count Tax Quarter & Year Quarter Ended Filing/Payment Dates
2 Q2 2015 June 30, 2015 July 31, 2015
26 U.S.C. § 7202
18 U.S.C. § 2
7
Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 8 of 9
FORFEITURE ALLEGATION
The U.S. Attorney for the District of Maryland further finds that:
1. Pursuant to Federal Rule of Criminal Procedure 32.2, notice is given to the
defendant that the United States will seek forfeiture as part of any sentence in accordance with
18 U.S.C. § 981(a)(1)(C), 21 U.S.C. § 853(p), and 28 U.S.C. § 2461(c), in the event of the
defendant’s conviction of the offense in Count One of the Information.
Wire Fraud Forfeiture
2. Upon conviction of the offense alleged in Count One of this Information,
the defendant,
CRYSTAL JONES,
a/k/a “Crystal Powell-Jones,”
shall forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c),
any property, real or personal, which constitutes, or is derived from proceeds traceable to such
offense. The property to be forfeited includes, but is not limited to, a money judgment of at
least $449,123.73 in U.S. currency equal to the aggregate proceeds obtained by the defendant
traceable to the scheme to defraud.
Substitute Assets
3. If, as a result of any act or omission of any defendant, any of the property
described above as being subject to forfeiture:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third person;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
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Case 1:21-cr-00126-GLR Document 1 Filed 04/26/21 Page 9 of 9
e. has been commingled with other property which cannot be divided
without difficulty,
the United States, pursuant to 2l U.S.C. $ 853(p), as incorporated by 28 U.S.C. $ 2461(c), shall
be entitled to forfeiture of any substitute property up to the value of the forfeitable property
described above.
18 u.s.c. $ e81(a)(lXC)
2l u.S.C. $ 8s3(p)
28 U.S.C. $ 2461(c)
Date: IrprilLlg ,202t
F. Lenzner
United States
ld'
9
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