Devontae Stokes — Information

Summary

An Information in United States v. Devontae Stokes in the U.S. District Court for the District of New Jersey, filed after he waived prosecution by indictment and charging conspiracy under 18 U.S.C. § 1349. It describes Stokes as an inmate at FCI Fort Dix and sets out the background of Pandemic Unemployment Assistance, created by the CARES Act signed on or about March 27, 2020. The Information alleges that Stokes and his conspirators obtained other people's names, dates of birth and social security numbers without their consent, caused unemployment benefit applications to be made to state workforce agencies, and obtained more than $140,000 in response. It closes with a forfeiture allegation.

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Full text

2022R00240 / ADK


                          UNITED STATES DISTRICT COURT
                             DISTRICT OF NEW JERSEY

 UNITED STATES OF AMERICA                        Hon.

                   V.                            Criminal No. 22-


 DEVONTAE STOKES                                  18 u.s.c. § 1349


                                 INFORMATION

       The defendant having waived in open court prosecution by indictment,

the United States Attorney for the District of New Jersey charges:

                                    BACKGROUND

        1.     At various times relevant to this Information:

               a.       Defendant DEVONTAE STOKES was an inmate at FCI Fort

Dix, a federal correctional institutional with an adjacent satellite camp located

in Fort Dix, New Jersey.

               b.       On or about March 27, 2020, the Coronavirus Aid, Relief,

and Economic Security Act (the "CARES Act") was signed into law. The CARES

Act created a new temporary federal unemployment insurance program called

Pandemic Unemployment Assistance ("PUA"). PUA provided unemployment

insurance benefits ("UIBs") for individuals who were not eligible for other types

of unemployment (e.g., the self-employed, independent contractors, gig

economy workers). The CARES Act also created a new temporary federal

program called Federal Pandemic Unemployment Assistance ("FPUC") that
provided an additional $600 weekly benefit to those eligible for PUA and regular

UIBs.

             c.    Subject to certain eligibility requirements, a person who was

unemployed, but who used to be employed by an employer in a given state

could apply to receive UIBs from that state.

             d.   Each state administered the above UIB programs through a

State Workforce Agency ("SWA").

                              THE CONSPIRACY

        2.   From at least in or around April 2020 through in or around

November 2020, in the District of New Jersey and elsewhere, the defendant,

                             DEVONTAE STOKES,

did knowingly and intentionally conspire with others to devise and intend to

devise a scheme and artifice to defraud individuals, and to obtain money and

property by means of materially false and fraudulent pretenses,

representations, and promises, and, for the purpose of executing and

attempting to execute such scheme and artifice to defraud, did transmit and

cause to be transmitted by means of wire communications in interstate and

foreign commerce certain writings, signs, signals, pictures, and sounds,

including a November 6, 2020, text message from a location in New Jersey to a

location outside New Jersey, contrary to Title 18, United States Code, Section

1343.




                                        2
                        GOAL OF THE CONSPIRACY

      3.    The goal of the conspiracy was for STOKES and his conspirators

to enrich themselves by obtaining money from states through the submission

of fraudulent UIB claims.

              MANNER AND MEANS OF THE CONSPIRACY

      4.    It was part of the conspiracy that:

            a.     STOKES and his conspirators obtained personal

identification information ("PII"), including names, dates of birth, and social

security numbers belonging to other individuals without those individuals'

knowledge and consent.

            b.     STOKES and his conspirators sent each other wire

communications concerning submitting fraudulent UIB applications and

receiving proceeds resulting from the fraudulent submissions, including a text

message on November 6, 2020, from STOKES, who was located in New Jersey,

to a conspirator who was located outside of New Jersey.

            c.     STOKES and his conspirators caused fraudulent

applications to be made to SWAs for UIBs.

            d.     STOKES and his conspirators obtained more than $140,000

from the SWAs in response to the fraudulent UIB applications.

      All in violation of Title 18, United States Code, Section 1349.




                                         3
                           FORFEITURE ALLEGATION

             1. The allegations contained in this Information are incorporated

by reference as though set forth in full herein for the purpose of alleging

forfeiture pursuant to Title 18, United States Code, Section 981(a)(l)(C), and

Title 28, United States Code, Section 2461(c).

             2. Upon conviction of the offense charged in this Information, the

government will seek forfeiture from defendant STOKES, in accordance with

Title 28, United States Code, Section 2461(c), and Title 18, United States Code,

Section 981(a)(l)(C), of any and all property, real or personal, that constitutes

or is derived from proceeds traceable to the violations of Title 18, United States

Code, Section 1349.

            3. If by any act or omission of defendant STOKES any of the

property subject to forfeiture herein:

                   a.   cannot be located upon the exercise of due diligence;

                   b.   has been transferred or sold to, or deposited with, a third

                        party;

                   c.   has been placed beyond the jurisdiction of the court;

                   d.   has been substantially diminished in value; or

                   e.   has been commingled with other property which cannot

                        be subdivided without difficulty,




                                         4
it is the intent of the United States, pursuant to Title 21, United States Code,

Section 853(p), as incorporated by Title 28, United States Code, Section

2461(c), to seek forfeiture of any other property of defendant STOKES up to the

value of the property described in this forfeiture allegation.




                                             PHILIP R. SELLINGER
                                             UNITED STATES ATTORNEY




                                         5


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