Indictment — United States v. Medard Ulysse et al., District of Maryland (Document 1)

Summary

A sealed indictment filed March 4, 2021 as Document 1 in United States v. Medard Ulysse, Eghosasere Avboraye-Igbinedion and Amaya English, Case 1:21-cr-00054-RDB, in the U.S. District Court for the District of Maryland. Count One charges conspiracy to commit mail fraud under 18 U.S.C. § 1349 from about January 2018 through about November 2019. The grand jury charges that conspirators telephoned elderly victims, posed as police officers, lawyers or relatives, and persuaded them to ship cash for a grandchild's supposed bail and legal fees to vacant or for-sale addresses, and that at least 70 different victims sent at least $1.5 million. Overt acts list Fed Ex and UPS shipments of cash to addresses in Baltimore, Washington, D.C. and Pennsylvania. A forfeiture allegation seeks money judgments under 18 U.S.C. § 981(a)(1)(C).

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Case 1:21-cr-00054-RDB Documenti_ Filed 03/04/21 Page1of9

SRD/MJM 202100121 MAR - 4 2021
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND CLERK US DISTT coun

DISTRICT OF MARYLAND

BY
BEPUTY

UNITED STATES OF AMERICA * UNDER SEAL
v. * CRIMINALNO. GLA-2A/-OS Y
MEDARD ULYSSE a/k/a “Jay,” * (Conspiracy to Commit Mail Fraud,
EGHOSASERE AVBORAYE- * 18 U.S.C. § 1349; Forfeiture, 18
IGBINEDION a/k/a “Ego” a/k/a $ U.S.C. § 981(a)(1)(C), 28 U.S.C.
“Ghost,” and = § 2461(c))
AMAYA ENGLISH, *
INDICTMENT
COUNT ONE

(Conspiracy to Commit Mail Fraud)
The Grand Jury for the District of Maryland charges that:
Introduction

At all times relevant to this Indictment:

l. Defendant MEDARD ULYSSE a/k/a “Jay” (SULYSSE”) was a resident of
Miami, Florida.

*s Defendant EGHOSASERE AVBORAYE-IGBINEDION a/k/a “Ego” a/k/a
“Ghost” (‘AVBORAYE-IGBINEDION”) was a resident of Miramar, Florida.

3. Defendant AMAYA ENGLISH (“ENGLISH”) was a resident of Baltimore,
Maryland.

The Conspiracy and Scheme to Defraud

4. From in or about January 2018 through in or about November 2019, in the

District of Maryland and elsewhere, the defendants,
Case 1:21-cr-00054-RDB Documenti_ Filed 03/04/21 Page 2of9

MEDARD ULYSSE a/k/a “Jay,”
EGHOSASERE AVBORAYE-IGBINEDION a/k/a “Ego” a/k/a “Ghost,” and
AMAYA ENGLISH
did knowingly and willfully conspire, confederate, and agree with others known and unknown to
commit mail fraud, that is to knowingly and willfully devise and intend to devise a scheme and
artifice to defraud and to obtain money and property from victims, by means of materially false
and fraudulent pretenses, representations, and promises, that is, to persuade elderly victims to send
thousands of dollars in cash to members of the conspiracy under false pretenses that:
a. the money would be used to help the victims’ relatives pay legal or other expenses in
connection with crimes and other incidents that had not occurred, and
b. the money would be sent to particular individuals at their addresses, rather than to
members of the conspiracy falsely claiming to reside at those addressees
(the “scheme to defraud”), and for the purpose of executing and attempting to execute such scheme
to defraud, to knowingly deposit and cause to be deposited to be sent and delivered by the Postal
Service and private interstate carrier, and caused to be delivered by mail and private and
commercial interstate carrier, any matter and thing, according to the direction thereon, in violation
of 18 U.S.C. § 1341.

Manner and Means

oF It was part of the conspiracy and scheme to defraud that conspirators telephoned
elderly victims throughout the United States and, while posing as a police officer, lawyer, or
other individual, falsely told the victim that a relative, typically the victim’s grandchild, had been
incarcerated in connection with a car accident or traffic stop involving a crime, and needed

money for bail and legal fees, often tens of thousands of dollars.
Case 1:21-cr-00054-RDB Documenti_ Filed 03/04/21 Page 3of9

6. It was further part of the conspiracy and scheme to defraud that conspirators also
posed as the victims’ relatives themselves in order to further induce the victims to send the cash.

as It was further part of the conspiracy and scheme to defraud that conspirators
described the situation as extremely serious, sometimes indicating that drugs had been found in
the vehicle, or that the occupant of another car was injured.

8. It was further part of the conspiracy and scheme to defraud that, in order to
conceal the crime, conspirators told the victims false information, like that there had been a “gag
order” placed on the case requiring secrecy, or that the situation was embarrassing for the
grandchild, and that the victim should not share the information with others.

9. It was further part of the conspiracy and scheme to defraud that, during the
telephone calls, conspirators directed the victims to send cash to a particular address via
overnight delivery service, such as United States Postal Service Priority Mail, Fed Ex, and
United Parcel Service (“UPS”).

10. It was further part of the conspiracy and scheme to defraud that, if the victims sent
cash as directed by conspirators, conspirators would call the victims again and ask for more cash,
falsely claiming that additional funds were necessary for various purposes, such as their
grandchild’s legal expenses, bail costs, fines, or to pay damages. Conspirators would continue to
call the victims and demand additional funds, regularly obtaining tens of thousands of dollars
from the retirement savings of victims.

11. It was further part of the conspiracy and scheme to defraud that, in order to
conceal the crime, conspirators identified residential locations across the country where the cash

should be sent, including but not limited to addresses in Maryland, Delaware, Pennsylvania, and
Case 1:21-cr-00054-RDB Documenti_ Filed 03/04/21 Page4of9

Florida. Conspirators identified locations that would either be vacant or for sale, so no one
would be at those locations at the time of the deliveries.

12. It was further part of the conspiracy and scheme to defraud that conspirators
retrieved the packages of cash and distributed the fraud proceeds to other people involved in the
scheme.

13. It was further part of the conspiracy and scheme to defraud that conspirators
recruited and instructed additional people to assist in retrieving the packages of cash when they
were delivered to the specified locations.

14. It was further part of the conspiracy and scheme to defraud that ULYSSE
recruited other persons in the State of Florida to participate in the scheme with promises of travel
and cash payments.

15. It was further part of the conspiracy and scheme to defraud that ULYSSE directed
other conspirators to travel from Florida to the State of Maryland and other regions of the United
States, to identify residential locations where packages of cash could be delivered, to observe
deliveries of the packages at designated locations, to retrieve packages of cash from particular
locations, and to deliver the packages to ULYSSE, ENGLISH, or to other conspirators.

16. It was further part of the conspiracy and scheme to defraud that ULYSSE would,
at times, instruct other participants in the scheme not to open the packages of cash they retrieved
at his direction and, at other times, instruct other conspirators to open the packages, count the
cash inside, and send ULYSSE video recordings of the packages being opened and counted.

1}. It was further part of the conspiracy and scheme to defraud that AVBORAYE-

IGBINEDION, ENGLISH and other conspirators retrieved packages of cash from locations
Case 1:21-cr-00054-RDB Documenti_ Filed 03/04/21 Page5of9

designated by members of the conspiracy and relayed directions to other participants in the
scheme about where and when to retrieve packages of cash.

18. It was further part of the conspiracy and scheme to defraud that ULYSSE
distributed, and directed other conspirators to distribute, cash payments to other members of the
conspiracy for their participation in the scheme.

19. It was further part of the conspiracy and scheme to defraud that ENGLISH and
other conspirators used the Internet to track packages of cash due for delivery to locations
designated by members of the conspiracy, relayed information about the delivery status of the
packages to other conspirators, and accepted packages of cash from other conspirators on behalf
of ULYSSE.

20. It was further part of the conspiracy and scheme to defraud that ULYSSE,
AVBORAYE-IGBINEDION, ENGLISH, and other conspirators encouraged and enticed other
persons to participate in the scheme.

21. It was further part of the conspiracy and scheme to defraud that members of the
conspiracy caused at least 70 different victims to send at least $1.5 million through materially
false and fraudulent pretenses, representations, and promises.

Overt Acts

22. In furtherance of the conspiracy and scheme to defraud, and to effect the objects
thereof, the defendants, and others known and unknown to the Grand Jury, committed and
caused to be committed the following acts, among others, in the District of Maryland and
elsewhere:

a. On or about July 11, 2018, and September 20, 2018, ENGLISH sent to

other conspirators addresses in Baltimore, Maryland and Washington D.C. where members of
Case 1:21-cr-00054-RDB Document1_ Filed 03/04/21 Page 6of9

the conspiracy caused victims to ship packages of cash in order for the conspirators to retrieve

those packages, which included the following:

4 1/2018 | Murrieta, CA | Baltimore, MD A Fed Ex shipment containing
$8,000 in cash.

9/20/2018 | Missoula, MT Washington, DC A Fed Ex shipment containing
$8,000 in cash.

b. On or about August 24, 2018, AVBORAYE-IGBINEDION and
ENGLISH traveled to a location in Baltimore, Maryland where members of the conspiracy
caused a victim to ship a package containing cash via Fed Ex in order to observe the delivery and
retrieve the package.

C. On or about January 4, 2019, ULYSSE traveled from Florida to Maryland
in order to obtain packages of cash that members of the conspiracy caused victims to ship to

particular locations in the areas of Baltimore, Maryland and Washington, D.C. between January

8, 2019, and January 12, 2019, which included the following:

~ 1/9/2019 |LaQuinta,CA | Baltimore, MD _| A Fed Ex shipment containing —
$9,400 in cash

1/9/2019 | Bainbridge Island, Baltimore, MD A UPS shipment containing
WA $10,000 in cash

1/12/2019 | Shelby Township, Washington, DC A Fed Ex shipment containing
MI an unknown quantity of cash
Case 1:21-cr-00054-RDB Document1 Filed 03/04/21 Page 7 of9

1/12/2019 | Groton, CT Baltimore, MD A UPS shipment containing
$9,800 in cash.

d. On or about January 16, 2019, AVBORAYE-IGBINEDION traveled
from Florida to Maryland to obtain packages of cash that members of the conspiracy caused
victims to ship to particular locations in Baltimore, Maryland between January 17, 2019, and

January 19, 2019, which included the following

$7,200 in cash

1/18/2019 | Lindon, UT Baltimore, MD A Fed Ex shipment containing
$8,000 in cash
1/19/2019 | Colonial Heights, Baltimore, MD A Fed Ex shipment containing
VA $10,000 in cash

os On or about August 10, 2019, ENGLISH traveled to a location in
Glenolden, Pennsylvania where members of the conspiracy caused a victim to ship a package
containing $6,800 in cash via UPS and retrieved the package.

18 U.S.C. § 1349.
Case 1:21-cr-00054-RDB Documenti_ Filed 03/04/21 Page 8of9

FORFEITURE ALLEGATION
The Grand Jury for the District of Maryland further finds that:
1. Pursuant to Rule 32.2, Fed. R. Crim. P., notice is hereby given to the defendants
that the United States will seek forfeiture as part of any sentence in accordance with 18 U.S.C.
§ 981(a)(1)(C) and 28 U.S.C. § 2461(c), in the event of the defendants’ conviction under Count
One of the Indictment.

Mail Fraud Forfeiture

2. Upon conviction of the offense set forth in Count One, pursuant to 18 U.S.C.

§ 981(a)(1)(C) and 28 U.S.C. § 2461(c), the defendants,

MEDARD ULYSSE,

EGHOSASERE AVBORAYE-IGBINEDION, and

AMAYA ENGLISH
shall forfeit to the United States any property, real or personal, which constitutes or is derived
from proceeds traceable to the scheme to defraud, including, but not limited to: a money
judgment for each defendant representing the proceeds he obtained from his participation in the

scheme to defraud.

Substitute Assets

3. If any of the above-described forfeitable property, as a result of any act or
omission of the defendants:
a. cannot be located upon the exercise of due diligence
b. has been transferred, 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 divided without
Case 1:21-cr-00054-RDB Document1 Filed 03/04/21 Page9of9

difficulty,
the United States shall be entitled to forfeiture of substitute property up to the value of the

forfeitable property described above pursuant to 21 U.S.C. § 853(p), as incorporated by 28
U.S.C. § 2461(c).

18 U.S.C. § 981(a)(1)(C)
21 U.S.C. § 853(p)
28 U.S.C. § 2461(c)

Jonathan F. Lenzner
Acting United States Attorney

SIGNATURE REDACTED

Foreperson

Date: A Y/: ‘2075 J


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