Indictment — United States v. Gerard C. Moorer (N.D. Ill.)

Summary

An Indictment filed 05/06/26 as Document #: 1 in United States of America v. Gerard C. Moorer, Case 1:26-cr-00209, U.S. District Court, Northern District of Illinois, Eastern Division, citing Title 18, United States Code, Section 1343. In Count One the Special September 2025 Grand Jury charges that beginning on or about May 10, 2020 and continuing until on or about September 6, 2021 the defendant devised a scheme to defraud and to obtain money from the Illinois Department of Employment Security (IDES) in the form of Pandemic Unemployment Assistance (PUA) benefits. It alleges that the application stated the defendant had not been employed by the federal government since October 1, 2018 and that the defendant filed weekly certifications claiming not to have worked, when the defendant was employed as an aide to Congressman A.

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“Indictment — United States v. Gerard C. Moorer (N.D. Ill.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-26-cr-00209-dkt-1-n-d-ill-d8e2ff211f/, SHA-256 364c1eafb0758a768835388bf90c85bf6de9c6747363700205b08cf9498f5e62.

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Case: 1:26-cr-00209 Document #: 1 Filed: 05/06/26 Page 1 of 9 PageID #:1

FIL ED GMC
/2026
5/6
N UNITED STATES DISTRICT COURT 1:26-cr-0209
THOMA.SDG . BRUTO R T
ISTRIC T C O U NORTHERN DISTRICT OF ILLINOIS Judge Lindsay C. Jenkins
CLERK, U.S
EASTERN DIVISION Magistrate Judge Beth W. Jantz
RANDOM / Cat. 3
UNITED STATES OF AMERICA
No.
v.
Violation: Title 18, United States
GERARD C. MOORER Code, Section 1343

COUNT ONE

The SPECIAL SEPTEMBER 2025 GRAND JURY charges that:

1. At times material to this indictment:

a. Defendant GERARD C. MOORER resided in Chicago, Illinois,

and was employed by the federal government as an aide to Congressman A, including

as a Deputy District Director.

b. The Social Security Act (“SSA”) established the dual program of

federal and state unemployment benefits. Under the SSA, each state administered

its own unemployment program through a State Workforce Agency to distribute state

unemployment benefits, within the guidelines of federal law. State unemployment

benefits are financed in part by state payroll taxes, which are held in trust by the

United States Treasury’s Federal Unemployment Trust Fund. During periods of high

unemployment, the federal government has also funded or augmented state

unemployment benefits.

c. The Illinois Department of Employment Security (“IDES”) was

the designated State Workforce Agency of the State of Illinois that administered state

unemployment insurance benefits (“UI benefits”).
Case: 1:26-cr-00209 Document #: 1 Filed: 05/06/26 Page 2 of 9 PageID #:2

d. The Coronavirus Aid, Relief, and Economic Security (“CARES”)

Act was a federal law enacted in or around March 2020 designed and intended to

provide emergency financial assistance to the millions of Americans who were

suffering the economic effects caused by the COVID-19 pandemic.

e. The CARES Act expanded individual states’ ability to provide

assistance to workers impacted by COVID-19, including workers who were not

ordinarily eligible for UI benefits. One of the temporary assistance programs

established for this purpose was known as Pandemic Unemployment Assistance

(“PUA”).

f. Under the PUA provisions of the CARES Act, individuals

qualified for PUA benefits if they were: (1) self-employed, seeking part-time

employment, or otherwise would not qualify for regular unemployment insurance or

extended benefits under state or federal law or Pandemic Emergency Unemployment

Compensation; and (2) unemployed, partially unemployed, unable to work, or

unavailable to work due to specific COVID-19 related reasons.

g. To obtain PUA benefits, claimants in the State of Illinois were

first required to apply for UI benefits through IDES. After those claims were denied,

claimants were required to complete an application form, which was signed by the

applicant. The PUA application required the applicants to acknowledge the program

rules and make certain affirmative certifications regarding the eligibility of the

claimants. In the application, claimants were required to disclose, among other

2
Case: 1:26-cr-00209 Document #: 1 Filed: 05/06/26 Page 3 of 9 PageID #:3

things: (1) whether they were “employed with the military or the federal government

since 10/1/2018”; and (2) self-certify that they met one of the COVID-19 related

reasons for being unemployed, partially unemployed, unable to work, or unavailable

to work due to a COVID-19 related reason.

h. If claimants received PUA benefits, they then needed to file

weekly certifications with IDES regarding their continued entitlement to PUA

benefits. Such certifications included, among other things, information regarding

whether the claimants worked during the prior week, including “federal

employment,” and whether the claimants were “totally or partially unemployed

because of the pandemic.”

2. Beginning on or about May 10, 2020, and continuing until on or about

September 6, 2021, in the Northern District of Illinois, and elsewhere,

GERARD C. MOORER,

defendant herein, knowingly devised, intended to devise, and participated in a

scheme to defraud, and to obtain money and property from IDES, in the form of PUA

benefits from the federal government, by means of materially false and fraudulent

pretenses, representations, and promises, which scheme is further described below.

3. It was part of the scheme that MOORER knowingly filed and caused to

be filed a false and fraudulent application for PUA benefits to IDES and filed and

caused to be filed false and fraudulent certifications, in order to fraudulently induce

IDES to pay PUA benefits to MOORER.

3
Case: 1:26-cr-00209 Document #: 1 Filed: 05/06/26 Page 4 of 9 PageID #:4

4. It was further part of the scheme that, on or about May 21, 2020,

MOORER submitted and caused to be submitted to the IDES an application for

unemployment insurance and PUA benefits on behalf of himself, which application

contained materially false statements and misrepresentations, including that he had

not been employed by the federal government since October 1, 2018, when, in truth,

MOORER knew that, since October 1, 2018, he had been employed by the federal

government as an aide to Congressman A.

5. It was further part of the scheme that, in his application for PUA

benefits, MOORER falsely indicated that he met one of the COVID-19 related reasons

for being unemployed, partially unemployed, unable to work, or unavailable to work

due to a COVID-19 related reason, when, in truth, MOORER knew that he was not

unemployed, partially unemployed, unable to work, or unavailable to work due to a

COVID-19 related reason, because he continued to be employed by Congressman A

at the time of his PUA application.

6. It was further part of the scheme that, between on or about May 24,

2020, and on or about September 6, 2021, MOORER submitted and caused to be

submitted to the IDES false and fraudulent certifications for unemployment

insurance and PUA benefits, including certifications that falsely claimed that

MOORER did not work during the periods certified, and that he was totally or

partially unemployed because of the COVID pandemic, when, in truth, MOORER

knew that he was working for Congressman A between on or about May 24, 2020,

4
Case: 1:26-cr-00209 Document #: 1 Filed: 05/06/26 Page 5 of 9 PageID #:5

and on or about September 6, 2021, and that he was not totally or partially

unemployed because of the COVID pandemic.

7. It was further part of the scheme that MOORER caused the

disbursement of thousands of dollars of fraudulently obtained PUA benefits to bank

accounts that he controlled and used the funds for his personal benefit.

8. It was further part of the scheme that MOORER misrepresented,

concealed, and hid, and caused to be misrepresented, concealed, and hidden, the

existence and purpose of the scheme and the acts done in furtherance of the scheme.

9. On or about May 26, 2021, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

GERARD C. MOORER,

defendant herein, for the purpose of executing the scheme to defraud, knowingly

caused to be transmitted in interstate commerce by means of a wire communication

certain writings, signs, and signals, namely, a certification regarding MOORER’s

eligibility for PUA benefits to the IDES, which certification was transmitted to a

server outside the State of Illinois;

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

5
Case: 1:26-cr-00209 Document #: 1 Filed: 05/06/26 Page 6 of 9 PageID #:6

COUNT TWO

The SPECIAL SEPTEMBER 2025 GRAND JURY further charges:

1. The allegations in paragraphs 1 through 8 of Count One of this

indictment are incorporated here.

2. On or about August 30, 2021, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

GERARD C. MOORER,

defendant herein, for the purpose of executing the scheme to defraud, knowingly

caused to be transmitted in interstate commerce by means of a wire communication

certain writings, signs, and signals, namely, a certification regarding MOORER’s

eligibility for PUA benefits to the IDES, which certification was transmitted to a

server outside the State of Illinois;

In violation of Title 18, United States Code, 1343.

6
Case: 1:26-cr-00209 Document #: 1 Filed: 05/06/26 Page 7 of 9 PageID #:7

COUNT THREE

The SPECIAL SEPTEMBER 2025 GRAND JURY further charges:

1. The allegations in paragraphs 1 through 8 of Count One of this

indictment are incorporated here.

2. On or about September 6, 2021, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

GERARD C. MOORER,

defendant herein, for the purpose of executing the scheme to defraud, knowingly

caused to be transmitted in interstate commerce by means of a wire communication

certain writings, signs, and signals, namely, a certification regarding MOORER’s

eligibility for PUA benefits to the IDES, which certification was transmitted to a

server outside the State of Illinois;

In violation of Title 18, United States Code, 1343.

7
Case: 1:26-cr-00209 Document #: 1 Filed: 05/06/26 Page 8 of 9 PageID #:8

FORFEITURE ALLEGATION

The SPECIAL SEPTEMBER 2025 GRAND JURY further alleges:

1. The allegations contained in Counts One through Three of this

indictment are incorporated here for the purpose of alleging forfeiture pursuant to

Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code,

Section 2461(c).

2. As a result of the violations of Title 18, United States Code, Section

1343, as alleged in the foregoing indictment,

GERARD C. MOORER,

defendant herein, shall forfeit to the United States, pursuant to Title 18, United

States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c):

any and all right, title and interest in property, real and personal, which constitutes

and is derived from proceeds traceable to the charged offenses

3. The interests of the defendant subject to forfeiture to the United States

pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United

States Code, Section 2461(c) include, but are not limited to, approximately $31,887.

4. If any of the property described above, as a result of any act or omission

by a defendant, cannot be located upon the exercise of due diligence, has been

transferred or sold to, or deposited with, a third party, has been placed beyond the

jurisdiction of the Court; has been substantially diminished in value; or has been

commingled with other property which cannot be divided without difficulty, the

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United States of America shall be entitled to forfeiture of substitute property, as

provided in Title 21, United States Code, Section 853(p).

A TRUE BILL:

FOREPERSON

______________________________
UNITED STATES ATTORNEY

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