Bill of Information — United States v. Joseph Ransome (Western District of North Carolina, Document 1)

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Bill of Information in United States of America v. Joseph Ransome, Docket No. 3:21-CR-00022, in the U.S. District Court for the Western District of North Carolina, Charlotte Division, filed 01/25/21 as Document 1 in Case 3:21-cr-00022-RJC-DSC. The United States Attorney charges Count One, Wire Fraud Scheme, 18 U.S.C. § 1343, and alleges that from at least March 2020 through July 2020 the defendant engaged in a scheme to defraud the United States Department of Labor and at least ten states by filing fraudulent unemployment insurance claims in the defendant's own name. It alleges that the defendant fraudulently applied for more than $150,000 in unemployment benefits using false employment details and directed payments to bank accounts and Green Dot cards under the defendant's control. A Notice of Forfeiture lists approximately $44,367 in proceeds of the violation.

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FILED
CHARLOTTE, NC

UNITED STATES DISTRICT COURT JAN 25 2021
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION US DISTRICT COURT

WESTERN DISTRICT OF NC

UNITED STATES OF AMERICA ) Docket No.: 3:21-CR-00022
)
Vv. ) BILL OF INFORMATION
)
JOSEPH RANSOME ) Violations: 18 U.S.C. § 1343
)
)

THE UNITED STATES ATTORNEY CHARGES:
At the specified time and at all relevant times:

1, From at least March 2020 through July 2020, the Defendant, JOSEPH
RANSOME (“RANSOME”), a resident of Indian Trail, North Carolina, within the Western
District of North Carolina, engaged in a scheme to defraud the United States Department of
Labor, and at least ten states, including North Carolina, New Jersey, Connecticut, Florida,
Minnesota, New York, Massachusetts, Maine, Washington, and Illinois, by filing fraudulent
claims for unemployment insurance (UD) benefits in his own name. During the course of the
scheme, RANSOME fraudulently applied for more than $150,000 in unemployment benefits by
filing false claims containing fake information, including but not limited to, dates and places of
employment and the reasons for termination.

Background of the Unemployment System

2. The Social Security Act of 1935 initiated the UI system, which is operated and
managed by each state at the direction of the federal government, specifically, the United States
Department of Labor (DOL). In the majority of states, benefit funding is based solely on a tax
imposed on employers. However, DOL funds all substantive and administrative costs associated
with each state’s UI system, which is run by a state agency in the respective state. The UI system
is designed to provide benefits to persons who are out of work due to no fault of their own, and
who meet other eligibility requirements of state laws.

3. Eligibility for UI, benefit amounts, and the length of time benefits are available is
determined by individual state law. In all states, individual claimants must be eligible for
employment and actively searching for employing while receiving UI benefits.

4, A claimant receives UI benefits by completing an application at a local “one-stop
center,” by telephone, or online at each state’s website. A claimant must provide the claimant’s
name, date of birth, social security number, home address, and other personal information. On a
weekly or bi-weekly basis, the claimant then files for weekly payment benefits by certifying that
the claimant is unemployed, eligible for benefits, and is seeking employment.

Case 3:21-cr-00022-RJC-DSC Document1 Filed 01/25/21 Page1of5
5. The state agencies authorize their financial services sections to release
unemployment compensation funds in the form of either: (a) a state contracted debit card mailed
to the applicant; (b) a direct deposit into a pre-paid debit card account; (c) a direct deposit into
the claimant's designated bank account; or (d) in rare cases, some states will issue a check, if
requested.

6. As relevant to this Information, direct deposits of UI funds were completed
through the automated clearing house ("ACH"), an electronic funds-transfer system that
facilitates payments within the United States.

COVID-19, the National Emergency, and FPUC

7. According to the United States Centers for Disease Control and Prevention
(CDC), Coronavirus Disease 2019 (“COVID-19”) is a respiratory illness that can spread from
person to person. The virus that causes COVID-19 is a novel coronavirus that was first identified
during an investigation into a 2019 outbreak in Wuhan, China. COVID-19 can attack human
lungs and kill infected persons, especially those who have certain risk factors identified by the
CDC,

8, On March 13, 2020, President Donald J. Trump issued a Proclamation on
Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19)
Outbreak (“the Emergency Proclamation”). The Emergency Proclamation noted that “on March
11, 2020, the World Health Organization announced that the COVID-19 outbreak can be
characterized as a pandemic, as the rates of infection continue to rise in many locations around
the world and across the United States.” Further, “[t]he spread of COVID-19 within our Nation’s
communities threatens to strain our Nation's healthcare systems.”

9. At all relevant times, Section 2104 of the Coronavirus Aid, Relief, and Economic
Security ("CARES") Act, Pub. L. No. 116-136, 134 Stat. 281(March 27, 2020), entitled
“Emergency Increase in Unemployment Compensation Benefits,” provided for an additional
$600 weekly payment, known as “Federal Pandemic Unemployment Compensation” or “FPUC,”
to certain eligible individuals who were receiving other UI benefits under state law.

10. Atall relevant times, New Jersey, Connecticut, Florida, Minnesota, North
Carolina, New York, Massachusetts, Maine, Washington, and Illinois paid FPUC, a benefit
authorized, transported, transmitted, transferred, disbursed, and paid in connection with, a
presidentially declared major emergency (as those terms are defined in section 102 of the Robert
T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5122).

The Scheme to Defraud

11. From in or about March 2020 and continuing until in or about July 2020, in the
Western District of North Carolina, and elsewhere, and in relation to and involving a benefit
authorized, transported, transmitted, transferred, disbursed, and paid in connection with, a
presidentially declared major emergency (as those terms are defined in section 102 of the Robert
T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5122), Defendant
JOSEPH RANSOME did voluntarily and intentionally (1) participate in a scheme and artifice to
defraud with knowledge of its fraudulent nature and (2) obtain the money and property by means

2

Case 3:21-cr-00022-RJC-DSC Document1 Filed 01/25/21 Page 2of5
of false and fraudulent pretenses, representations, and promises (collectively, “the scheme to
defraud”).

Manner and Means of the Scheme to Defraud

12. It was part of the scheme to defraud that RANSOME applied for fraudulent UI
benefits in the States of North Carolina, New Jersey, Connecticut, Florida, Minnesota, New
York, Massachusetts, Maine, Washington, and Illinois, over the Internet.

13. It was further part of the scheme to defraud that RANSOME filed fraudulent
claims for UI benefits in his own name claiming non-existent employment and false reasons for
termination, among other falsities.

a. For example, RANSOME falsely claimed to have been laid off from
Walmart in North Carolina due to COVID, when in truth he was laid off for misconduct.
RANSOME claimed prior employment at Target, BestBuy, Lowe’s, and Hobby Lobby,
among others, when he did not work for those companies. Further, RANSOME falsely
claimed he was laid off from some of these companies because he had been diagnosed
with COVID or due to lack of work because of COVID-19. On some occasions,
RANSOME used a social security number and mailing address that did not belong to
him.

14. It was further part of the scheme to defraud that RANSOME directed that
payments of the fraudulent UI benefits be made to bank accounts and Green Dot cards under his
control, using wires in interstate commerce. For example:

a. On or about March 26, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of North Carolina in his name falsely
claiming that he had been laid off from Walmart in North Carolina because of a diagnosis
of COVID-19. The fraudulent UI benefit claim directed that payments be made to a
NASA Federal Credit Union (NASA FCU) account ending *3832.

b. On or about March 28, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of New York in his name falsely
claiming prior employment at Walmart in that state. The fraudulent UI benefit claim
directed that payments be made to a NASA FCU account ending *3832 and a Wells
Fargo Bank (Wells Fargo) account ending *6251.

C. On or about March 29, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Illinois in his name falsely
claiming prior employment at Hobby Lobby in that state and that he had been laid off
because of a diagnosis of COVID-19. The fraudulent UI benefit claim directed that
payments be made to a NASA FCU account ending in *3832,

d. On or about April 4, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Massachusetts in his name falsely
claiming prior employment at Walmart in that state. The fraudulent UI benefit claim
directed that payments be made to a NASA FCU account ending in *3832.

3

Case 3:21-cr-00022-RJC-DSC Document1 Filed 01/25/21 Page 3 of 5
€. On or about April 5, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of New Jersey in his name falsely
claiming prior employment at Target in that state and that he had been laid off because of
a diagnosis of COVID-19. The fraudulent UI benefit claim directed that payments be
made to a NASA FCU account ending *3832 and a SunTrust account ending *2364.

f. On or about April 7, 2020, RANSOM submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Minnesota in his name falsely
claiming prior employment at Lowe’s in that state. The fraudulent UI benefit claim
directed that payments be made to a NASA FCU account ending *3832.

g. On or about April 30, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Washington in his name falsely
claiming prior employment at Costco Wholesale Corporation in that state. The fraudulent
UI benefit claim directed that payments be made to a NASA FCU account ending in
+3832 and a Wells Fargo account ending *6251.

h. - On or about May 10, 2020, RANSOME submitted and caused to be
submitted a fraudulent UI benefit claim to the State of Connecticut in his name falsely
claiming prior employment at Best Buy and that he had laid off because of a diagnosis of
COVID-19. The fraudulent UI benefit claim directed that payments be made to a NASA
FCU account ending in *3832 and a Wells Fargo account ending *6251.

COUNT ONE
Wire Fraud Scheme (18 U.S.C. $1343)

15. Between in or about March 2020 and continuing through July 2020, in the Western

District of North Carolina, and elsewhere, Defendant JOSEPH RANSOME knowingly executed
and attempted to execute the above described scheme and artifice to defraud and for obtaining
money and property by means of materially false and fraudulent pretenses, representations, and
promises, and by concealment of material facts, would and did transmit and cause to be transmitted
by means of wire communication in interstate commerce, any writing, sign, signal, picture, and
sound for the purposes of executing said scheme and artifice fo wit the electronic submission of
fraudulent UI claims and the bank wires depositing the UI benefits.

All in violation of Title 18, United States Code, Section 1343.

Case 3:21-cr-00022-RJC-DSC Document1 Filed 01/25/21 Page 4of5
NOTICE OF FORFEITURE

Notice is hereby given of 18 U.S.C. § 982 and 28 U.S.C. § 2461(c). Under Section 2461(c),
criminal forfeiture is applicable to any offenses for which forfeiture is authorized by any other
statute, including but not limited to 18 U.S.C. § 981 and all specified unlawful activities listed or
referenced in 18 U.S.C. § 1956(c)(7), which are incorporated as to proceeds by Section

981(a)(1)(C). The following property is subject to forfeiture in accordance with Section 982 and/or
2461(c):

a. All property which constitutes or is derived from proceeds of the violations set forth
in Count One of this bill of information; and

b. If, as set forth in 21 U.S.C. § 853(p), any property described in (a) 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, all other property of the defendant/s to
the extent of the value of the property described in (a).

The following property is subject to forfeiture on one of the grounds set forth above:
approximately $44,367 in proceeds of the violation set forth in Count One.

R. ANDREW MURRAY
UNITED STATES ATTORNEY

CARYN FINLEY
ASSISTANT UNITED STATES ATTORNEY

Case 3:21-cr-00022-RJC-DSC Document1 Filed 01/25/21 Page 5of5


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