Indictment Memorandum — No. 1:26-cr-00011 (Dkt. 4, W.D. Pa.)

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An indictment memorandum filed under seal April 14, 2026 in United States of America v. Elizabeth Goss, No. 1:26-cr-00011 (Erie), U.S. District Court for the Western District of Pennsylvania, submitted by U.S. Attorney Troy Rivetti and AUSA Christian A. Trabold. It states that a federal grand jury returned a five-count indictment: Counts 1 through 4, wire fraud under 18 U.S.C. § 1343, dated May 31, 2021, July 26, 2021, August 27, 2021 and August 30, 2021, and Count 5, theft of public money under 18 U.S.C. § 641, from June 2020 to February 2023. It sets out the elements of each offense and the penalties: imprisonment of not more than twenty (20) years for wire fraud and ten (10) years for theft of public money, a fine of up to $250,000 or an alternative fine under 18 U.S.C. § 3571(d), supervised release of not more than three (3) years, and a $100.00 special assessment per count.

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FILED

IN THE UNITED STATES DISTRICT COURT APR 14 2026

FOR THE WESTERN DISTRICT OF PENNSYLVANIA CLERK OF COURT OF WESTERN DISTRICT

OF PENNSYLVANIA _

UNITED STATES OF AMERICA )
)
v. ) Criminal No. 26-}|- Erie
) [UNDER SEAL]
ELIZABETH GOSS )

INDICTMENT MEMORANDUM

AND NOW comes the United States of America, by its attorneys, Troy Rivetti,
United States Attorney for the Western District of Pennsylvania, and Christian A. Trabold,
Assistant United States Attorney for said District, and submits this Indictment Memorandum to
the Court:

I. THE INDICTMENT

A federal grand jury returned a five-count Indictment against the above-named

defendant for alleged violations of federal law:

COUNT OFFENSE/DATE TITLE/SECTION

1-4 Wire Fraud 18 U.S.C. § 1343
May 31, 2021 (Count One)
July 26, 2021 (Count Two)
August 27, 2021 (Count Three)
August 30, 2021 (Count Four)

5 Theft of Public Money 18 U.S.C. § 641
From in and around June 2020,
to in and around February 2023
Il. ELEMENTS OF THE OFFENSES

A. As to Counts 1 through 4:

In order for the crime of Wire Fraud, in violation of 18 U.S.C. § 1343, to be
established, the government must prove all of the following essential elements beyond a reasonable
doubt:

1. That the defendant devised a scheme to defraud or to obtain money or
property by materially false or fraudulent pretenses, representations or promises, or willfully
participated in such a scheme with knowledge of its fraudulent nature.

2. That the defendant acted with the intent to defraud.

3. That in advancing, furthering, or carrying out the scheme, the defendant
transmitted any writing, signal, or sound by means of a wire, radio, or television communication
in interstate commerce or caused the transmission of any writing, signal, or sound of some kind
by means of a wire, radio, or television communication in interstate commerce.

B. As to Count 5:

In order for the crime of Theft of Public Money, in violation of 18 U.S.C. § 641, to
be established, the government must prove all of the following essential elements beyond a
reasonable doubt:

1. That the money or property described in the Indictment belonged to an
agency of the United States.

2. That the defendant embezzled, stole, purloined or knowingly converted to
her own use or the use of another property as described in the Indictment, without authority to do

so and with the knowledge that the property belonged to another.
3. That the stolen or converted property of the United States was valued in
excess of $1,000.00 to prove a felony. If the stolen or converted property was valued at less than
$1,000.00, the offense is a misdemeanor.

Il. PENALTIES

A. As to Counts 1 through 4: Wire Fraud (18 U.S.C. § 1343):

1. Imprisonment of not more than twenty (20) years.

2. A fine not more than the greater of:

(1) = $250,000 (18 U.S.C. § 3571(b)(3)).
or
(2) an alternative fine in an amount not more than the greater of twice
the gross pecuniary gain to any person or twice the pecuniary loss to any person other than the
defendant, unless the imposition of this alternative fine would unduly complicate or prolong the
sentencing process (18U.S.C. § 3571(d)).

3. A term of supervised release of not more than three (3) years. (18 U.S.C. §
3583, 3559).

4. Any or all the above.

B. As to Count 5: Theft of Public Money (18 U.S.C. § 641):

1. Imprisonment of not more than ten (10) years.

2. A fine not more than the greater of:

(1) $250,000 (18 U.S.C. § 3571(b)(3)).
or
(2) an alternative fine in an amount not more than the greater of twice

the gross pecuniary gain to any person or twice the pecuniary loss to any person other than the
defendant, unless the imposition of this alternative fine would unduly complicate or prolong the
sentencing process (18U.S.C. § 3571(d)).
3. A term of supervised release of not more than three (3) years. (18 U.S.C. §
3583).
4. Any or all the above

IV. MANDATORY SPECIAL ASSESSMENT

A mandatory special assessment of $100.00 must be imposed at each count upon
which the defendant is convicted, pursuant to 18 U.S.C. § 3013.

V. RESTITUTION

Restitution may be required in this case as to Counts One through Five, together
with any authorized penalty, as part of the defendant's sentence pursuant to 18 U.S.C. §§ 3663,
3663A and 3664.

VI. FORFEITURE

Forfeiture is not applicable in this case.

Respectfully submitted,

TROY RIVETTI
United States Attorney

CHRISTIAN A. TRABOLD
Assistant U.S. Attorney
PA ID No. 75013

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