Criminal Indictment — United States v. Jamika Johnson and Jerome Brian Jones (N.D. Ga., Dkt. 1)
Summary
Criminal Indictment filed November 7, 2023, in the Northern District of Georgia against Jamika Johnson and Jerome Brian Jones. Count One charges a conspiracy, continuing until on or about February 10, 2022, to make false statements in an application for a passport; the overt acts allege that a false Passport Renewal Form was submitted to the Atlanta Passport Agency in the name of Jones with the picture of another person, that Jones signed the DS-82 application under penalty of perjury, and that Johnson paid for it. Count Two charges the false statements themselves under Title 18, United States Code, Section 1542. A forfeiture provision seeks a sum of money representing the proceeds.
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“Criminal Indictment — United States v. Jamika Johnson and Jerome Brian Jones (N.D. Ga., Dkt. 1).”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-23-cr-00356-dkt-1-n-d-ga-9d363c1596/
, SHA-256 183a46d72b34597a96fa9fe26f12fee9a016e27c5158b10dbf5b9ac523cd111d.Full text
Case 1:23-cr-00356-LMM-JKL Document 1 Filed 11/07/23 Page 1 of 5
ORIGINAL FILED IN OPEN COURT
l.J.S.D.C. -Atlanta
NOV D7 2023
KEVIN p WE
IN THE UNITED STATES DISTRICT COURT By .~ IMER, Clerk
FOR THE NORTHERN DISTRICT OF GEORGIA
f tJ Deputy Clerk
ATLANTA DIVISION
UNITED STATES OF AMERICA
V. Criminal Indictment
JAMIKA JOHNSON No. 1 :eacR-356
JEROME BRIAN JONES
THE GRAND JURY CHARGES THAT:
Count One
1. Beginning on a date unknown to the Grand Jury, and continuing until on or
about February 10, 2022, in the Northern District of Georgia, the defendants,
JAMIKA JOHNSON
JEROME BRIAN JONES
did knowingly and willfully combine, conspire, confederate, agree, and have a tacit
understanding with each other, and other persons unknown to the Grand Jury, to
violate Title 18, United States Code, Section 1542, that is, to willfully and
knowingly make false statements in an application for a passport, with intent to
induce and secure the issuance of a passport under the authority of the United
States for their own use and use of another, contrary to the laws regulating the
issuance of passports and the rules prescribed pursuant to such laws, in violation of
Title 18, United States Code, Section 1542.
Case 1:23-cr-00356-LMM-JKL Document 1 Filed 11/07/23 Page 2 of 5
Manner and Means
2. It was a part of the conspiracy that the defendants, JAMIKA JOHNSON and
JEROME BRIAN JONES, would prepare and submit a false Passport Renewal
Form to the Atlanta Passport Agency in an effort to obtain a passport in defendant
JONES 's name but with the picture of another person.
Overt Acts
3. In furtherance of the conspiracy and to effect the objects of the conspiracy,
the following overt acts, among others, were committed in the Northern District of
Georgia. On or about February 10, 2022:
a. The defendants, JAMIKA JOHNSON and JEROME BRIAN JONES,
entered the United States Department of State - Atlanta Passport
Agency, located at 230 Peachtree Street in Atlanta, Georgia.
b. While inside the Atlanta Passport Agency, defendant JOHNSON filled
out defendant JONES's DS-82 Passport Renewal Application and
attached a photdgraph of another person who was not defendant
JONES to the application.
c. While inside the Atlanta Passport Agency, defendant JONES
submitted his DS-82 Passport Renewal Application with the
photograph of another person. Defendant JONES signed the DS-82
Passport Renewal Application under penalty of perjury attesting,
among other things, that the photograph submitted with his
application is a genuine, current photograph of himself.
2
Case 1:23-cr-00356-LMM-JKL Document 1 Filed 11/07/23 Page 3 of 5
d. pefendant JOHNSON paid for defendant JONES 's DS-82 Passport
j
Renewal Application.
All in violation of Title 18, United States Code, Section 3 71.
CountTwo
4. The Grand Jury re-alleges and incorporates by reference the factual
allegations set forth in paragraphs 2 and 3 as if fully set forth herein.
5. On or about February 10, 2022, in the Northern District of Georgia, the
defendants,
JAMIKA JOHNSON
JEROME BRIAN JONES
aided and abett~d by each other and others unknown to the Grand Jury, willfully
and knowingly made false statements in an application for a passport with intent to
induce and secure the issuance of a passport under the authority of the United .
States for their own use and the use of another, contrary to the laws regulating the _
issuance of passports and the rules prescribed pursuant to such laws, which
statements they knew to be false, in violation of Title 18, United States Code,
Sectfon 1542 and Title 18, United States Code, Section 2.
Forfeiture
6. Upon conviction of one or more of the offenses alleged in Co~nts One
through.Two of this Indictment, the defendants, JAMIKA JOHNSON and
JEROME BRIAN JONES, shall forfeit to the United States of America, pursuant
3
Case 1:23-cr-00356-LMM-JKL Document 1 Filed 11/07/23 Page 4 of 5
to Title 18, United States Code, Section 982(a)(6), any property, real or personal,
constituting~ or derived from or traceable-to, proceeds obtained directly or ·
indirectly from the commission of said offenses and any property, real or personal,
used to facilitate, or intended to be used to facilitate, the commission of said
offenses, including, but not limited to, the following:
MONEY JUDGMENT: A sum of money in United States currency
representing the amount of proceeds obtained as a result of the offenses
for which the defendants are convicted.
-
If, as a result of any act or omission of the defendants, any property subject to
forfeiture:
( 1) cannot be located upon the exercise of due diligence;
(2)has been transferred or sold to, or deposited with, a third party;
(3)has been placed beyond the jurisdiction of the Court;
(4) has been substantially diminished in value; or
(5)has been commingled with other property which cannot be divided
without difficulty;
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Case 1:23-cr-00356-LMM-JKL Document 1 Filed 11/07/23 Page 5 of 5
the United States intends, pursuant to Title 21, United States Code, Section 853(p),
as incorporated by Title 18, United States Code, Section 982(b )( 1), to seek
forfeiture of any other property of said defendant up to the value of the forfeitable
property.
A
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\(1.A,.X BILL
?~ ~
~PERSON
RYAN K. BUCHANAN
CUni~:c A?~~N
Assistant United States Attorney
600 U.S. Courthouse
75 Ted Turner Drive SW
Atlanta, Georgia 30303
Office: (404) 581 -6000
Fax: (404) 581-6181
Georgia Bar No. 775084
5
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