Indictment — United States v. Michael Akame Ngwese Ay Makoge et al., District of Maryland (Document 1)

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An Indictment in United States of America v. Michael Akame Ngwese Ay Makoge, Dementrous Von Smith and other defendants, Case 1:22-cr-00219-LKG, Document 1, in the U.S. District Court for the District of Maryland, filed June 21, 2022. The caption lists Conspiracy to Commit Wire Fraud, 18 U.S.C. § 1349; Wire Fraud, 18 U.S.C. § 1343; Aggravated Identity Theft, 18 U.S.C. § 1028A; and Forfeiture. The grand jury alleges a conspiracy from in or about February 2020 through in or about October 2021 to submit fraudulent unemployment insurance claims in Maryland and California by impersonating victims. It alleges that the defendants caused at least 213 fraudulent UI claims to be submitted, resulting in more than 1.6 million dollars in losses.

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Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 1 of 22

CEM USA0#2021R00687

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA * UNDER SEAL
v. * CRIMINAL NO, RDB-22-219

MICHAEL AKAME NGWESE AY ¥ (Conspiracy to Commit Wire Fraud,
MAKOGE, a/k/a “Hype,” “2Hype”, * 18 U.S.C. § 1349; Wire Fraud, 18
DEMENTROUS Von SMITH, a/k/a 7 U.S.C. § 1343; Aggravated Identity
“Meecho,” “El Meecho”, * Theft, 18 U.S.C. § 1028A; Stealing
NADINE MAHORO MWAMIKAZI, i Keys Adopted by the Post Office, 18
SKY TIFFANY LAWSON, * U.S.C. 1704; Forfeiture, 18 U.S.C. §
CHRISTOPHER THOMAS YANCY, * 981(a)(1)(C), 21 U.S.C. § 853(p), 28
a/k/a “Lil Bhris,” “Lil Chris”, * U.S.C. § 2461(c))
SAYQUAN LEON BRIDGES, a/k/a *
“Quan”, *
CHRISTIAN MALIK ADREA, a/k/a *
“Leak,” “Lil Leak”, a
STEPHAWN MALIK WATSON, *
a/k/a “O-Dawg;” and x
AIYANNA MONE WASHINGTON, *
a/k/a “Yanna” %

Defendants. *

INDICTMENT

COUNT ONE
(Conspiracy to Commit Wire Fraud)

The Grand Jury for the District of Maryland charges that:
Introduction
At all times relevant to this Indictment:
L; Defendant MICHAEL AKAME NGWESE AY MAKOGE, a/k/a “Hype,”
“Hype” (“MAKOGE”) was a resident of Laurel, Maryland.
2. Defendant DEMENTROUS VON SMITH, a/k/a “Meecho,” “El Meecho”

(“VON SMITH”) was a resident of Waldorf, Maryland.
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 2 of 22

2 Defendant NADINE MAHORO MWAMIKAZI (“MWAMIKAZI”) was a
resident of Silver Spring, Maryland.

4. Defendant SKY TIFFANY LAWSON (“LAWSON”) was a resident of Bowie,
Maryland.

Ly Defendant CHRISTOPHER THOMAS YANCY, a/k/a “Lil Bhris,” “Lil Chris”
(“YANCY”) was a resident of Laurel, Maryland

6. Defendant SAYQUAN LEON BRIDGES, a/k/a “Quan” (“BRIDGES”) was a
resident of Bowie, Maryland.

7. Defendant CHRISTIAN MALIK ADREA, a/k/a “Leak,” “Lil Leak”
(“ADREA”) was a resident of Mitchellville, Maryland.

8. Defendant STEPHAWN MALIK WATSON, a/k/a “O-Dawg” (“WATSON”)
was a resident of District Heights, Maryland.

9. Defendant AITYANNA MONE WASHINGTON, a/k/a’ “Yanna”
(“WASHINGTON”) was a resident of Glenarden, Maryland.

Background on Maryland and California Unemployment Insurance

10. In Maryland, a former employee of a business who has lost his or her job can
contact the Maryland Department of Labor (“MD DOL”) and submit a claim for unemployment
insurance (“UI”) benefits. Claims for UI benefits are commonly submitted electronically through
the use of the Internet and Internet-capable computers or other electronic devices. If the former
employee meets certain requirements, including having received sufficient wages prior to
separation, they become eligible to receive UI benefits.

11. Prior to April 2021, if MD DOL approved a UI claim, Bank of America (“BOA”),

pursuant to a contract with MD DOL, would create and mail a BOA Prepaid VISA debit card with
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 3 of 22

the claimant’s name on it, to the claimant based upon information received from MD DOL. MD
DOL would subsequently authorize the electronic application of UI benefits to the debit card and
continue to do so on a periodic basis if the claimant continued to file for benefits.

12: The California Employment Development Department (“EDD”) administers the UI
program for residents and others physically performing work activities in California. Regular UI
claimants must typically be: (1) unemployed through no fault of their own; (2) able and available
to work; (3) willing to accept suitable work; and (4) actively seeking work. A person who receives
UI funds from one state workforce agency is not able to file or receive funds from another state
during the same timeframe.

13. Prior to the CARES Act, to be eligible for UI benefits administered by EDD, a
person must have been employed in California and received at least a certain amount of wages
from an employer in the 12 months preceding his or her UI benefits claim. Because of this
requirement, self-employed workers, independent contractors, and employees with insufficient
earnings were not eligible to receive regular UI benefits.

The Effect of COVID-19 and Federal Legislation on State Unemployment Insurance

14. On March 18, 2020, the President of the United States signed into law the Families
First Coronavirus Response Act (FFCRA), which provided additional flexibility for state
unemployment insurance agencies and additional administrative funding to respond to the
COVID-19 pandemic.

15. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was signed
into law on March 27, 2020. It expanded states’ ability to provide UI for many workers impacted
by the COVID-19 pandemic, including for workers who are not ordinarily eligible for

unemployment benefits.
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 4 of 22

16. The CARES Act created the Pandemic Unemployment Assistance (“PUA”)
program. Under PUA, states are permitted to provide PUA to individuals who are self-employed,
seeking part-time employment, or otherwise would not qualify for regular UI compensation.

17. To qualify for PUA benefits, an individual must not be eligible for regular UI
benefits and be unemployed, partially unemployed, or unable or unavailable to work because of
certain health or economic consequences of the COVID-19 pandemic.

18. The CARES ACT also established the Pandemic Emergency Unemployment
Compensation (“PEUC”) program.

19. PEUC covers most individuals who have exhausted all rights to regular Ul
compensation under state or federal law and who are able to work, available for work, and actively
seeking work as defined by state law.

20. PEUC also gives States the flexibility in determining whether an individual is
actively seeking work if the individual is unable to search for work because of COVID-19,
including because of illness, quarantine, or movement restrictions.

21. The CARES ACT also established the Federal Pandemic Unemployment
Compensation (“FPUC”) program.

22. From April 4, 2020, through July 31, 2020, FPUC allowed States to give an
additional $600 per week to individuals collecting regular UI compensation, PEUC, PUA, and
other approved UI benefit programs by the State.

23. FPUC was reauthorized in December 2020, and beginning in January 2021, FPUC
allows States to provide an additional $300 per week to individuals collecting regular UI
compensation, PEUC, PUA, and other approved UI benefit programs by the State. The additional,

$300-per-week FPUC benefits are set to expire on September 6, 2021.
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 5 of 22

The Conspiracy and Scheme to Defraud

24. From in or about February 2020 through in or about October 2021, in the District

of Maryland and elsewhere, the defendants,
MICHAEL AKAME NGWESE AY MAKOGE, a/k/a “Hype,” “2Hype;”
DEMENTROUS Von SMITH, a/k/a “Meecho,” “El Meecho;”
NADINE MAHORO MWAMIKAZI,
SKY TIFFANY LAWSON,
CHRISTOPHER THOMAS YANCY, a/k/a “Lil Bhris,” “Lil Chris;”
SAYQUAN LEON BRIDGES, a/k/a “Quan;”
CHRISTIAN MALIK ADREA, a/k/a “Leak,” “Lil Leak;”
STEPHAWN MALIK WATSON, a/k/a “O-Dawg;” and
AIYANNA MONE WASHINGTON, a/k/a “Yanna”

and others unknown to the Grand Jury, did knowingly and willfully conspire, confederate, and
agree to commit wire fraud, that is to knowingly and willfully devise and intend to devise a scheme
and artifice to defraud and to obtain money from victims, by means of materially false and
fraudulent pretenses, representations, and promises, to wit, impersonating victims for the purposes
of submitting fraudulent UI claims (the “scheme to defraud”), and for the purpose of executing
and attempting to execute such scheme to defraud, the defendants, MAKOGE, VON SMITH,
MWAMIKAZI, LAWSON, YANCY, BRIDGES, ADREA, WATSON, WASHINGTON, and
others unknown to the Grand Jury, did knowingly transmit and cause to be transmitted in interstate
commerce by means of a wire communication, certain signals, signs, and sounds, for the purposed

of executing the scheme to defraud, in violation of 18 U.S.C. § 1349.

Manner and Means

23: It was part of the conspiracy and scheme to defraud that MAKOGE, VON
SMITH, MWAMIKAZI, LAWSON, YANCY, BRIDGES, ADREA, WATSON,

WASHINGTON, and others unknown to the Grand Jury, obtained the names, dates of birth, and
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 6 of 22

social security numbers (“personally identifiable information”) of victims, without lawful
authority.

26. It was further part of the conspiracy and scheme to defraud that the defendants, and
others unknown to the Grand Jury, used electronic messages, phone calls, electronic mail, and
other means to aggregate and exchange the personally identifiable information of victims with
each other, and with others not known to the Grand Jury.

Bhs It was further part of the conspiracy and scheme to defraud that the defendants used
personally identifiable information taken from victims to prepare and submit fraudulent
applications for UI benefits in Maryland and California.

28. It was further part of the conspiracy and scheme to defraud that the defendants
submitted UI applications containing fraudulent representations, including, for example, the
victims’ contact information, that the victims lived in a particular state, that the victims were
available to work during the prescribed periods, and that the victims were newly unemployed.

29. It was further part of the conspiracy and scheme to defraud that the defendants
caused fictitious or false email addresses and phone numbers to be created or used in the fraudulent
UI applications.

30. It was further part of the conspiracy and scheme to defraud that the defendants
caused BOA and other financial institutions to load UI benefits onto debit cards, and then to mail
debit cards for the fraudulent UI claims to the physical addresses provided by the defendants.

31. It was further part of the conspiracy and scheme to defraud that the defendants used
false physical addresses for UI applications, such that any UI benefits that were paid by the state
would be received by the defendants, rather than the victims. In some instances, the defendants

used their own physical addresses in UI applications to receive the victims’ UI benefits. In other
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 7 of 22

instances, the defendants used the addresses of nearby residences, residences of family or the
residences of friends to receive UI applications in an effort to avoid detection by government
authorities.

32. It was further part of the conspiracy and scheme to defraud that the defendants
took the fraudulently obtained debit cards and made cash withdrawals and other transactions
throughout the District of Maryland.

35. It was further part of the conspiracy and scheme to defraud that the defendants
used the cash for their own benefit and for the benefit of others who also were not entitled to the
money.

34. As a result of the conspiracy, defendants, and others unknown to the Grand Jury,
caused at least 213 fraudulent UI claims to be submitted in Maryland and California, resulting
more than 1.6 million dollars in losses.

18 U.S.C. § 1349.
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 8 of 22

COUNTS TWO THROUGH THIRTY
(Wire Fraud)

L, Paragraphs | through 23 and 25 through 34 of Count One of this Indictment are
hereby incorporated by reference as though fully set forth herein.
2. In or about February 2020 through in or about October 2021, in the District of

Maryland and elsewhere, defendants,

MICHAEL AKAME NGWESE AY MAKOGE, a/k/a “Hype,” “2Hype;”
DEMENTROUS Von SMITH, a/k/a “Meecho,” “El Meecho;”
NADINE MAHORO MWAMIKAZI,

SKY TIFFANY LAWSON,

CHRISTOPHER THOMAS YANCY, a/k/a “Lil Bhris,” “Lil Chris;”
SAYQUAN LEON BRIDGES, a/k/a “Quan;”
CHRISTIAN MALIK ADREA, a/k/a “Leak,” “Lil Leak;”
STEPHAWN MALIK WATSON, a/k/a “O-Dawg;” and
AIYANNA MONE WASHINGTON, a/k/a “Yanna”

for the purpose of executing and attempting to execute such scheme to defraud, did knowingly
transmit and cause to be transmitted in interstate commerce by means of a wire communication,
certain signals, signs, and sounds, for the purpose of executing the scheme to defraud, as set forth

below:

COUNT | DEFENDANT | DATE | VICTIM | _ DESCRIPTION

Sending an electronic message with
Ps Makoge 7/24/2020 M.Q. the personally identifiable
information of M.Q.

. Sending an electronic message with
3 Makoge mee oan the personally identifiable
information of R.W.

Sending an electronic message with
4 Makoge 10/20/20 DL. the personally identifiable
information of D.L.

Sending an electronic message with
5 Makoge 11/1/2020 P.M. the personally identifiable
information of P.M.
Makoge

11/4/2020

Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 9 of 22

Withdrawal of money from an ATM

Makoge

11/23/2020

S.C.

Sending an electronic message with
the personally identifiable
information of S.C.

Makoge

11/24/2020

M.Q.

Sending an electronic message with
the personally identifiable
information of M.Q.

11/24/2020

S.C.

Sending an electronic message with
the personally identifiable
information of S.C.

Makoge

11/24/2020

S.D.

Sending an electronic message with
the personally identifiable
information of S.D.

Makoge

12/2/2020

S.D.

Sending an electronic message with
the personally identifiable
information of S.D.

Makoge

12/2/2020

S.C.

Sending an electronic message with
the personally identifiable
information of S.C.

Makoge

4/23/2021

M.Q.

Withdrawal of money from an ATM

Makoge

5/8/2021

Withdrawal of money from an ATM

Von Smith

8/23/2020

Sending an electronic message with
the personally identifiable
information of K.F. withdrawal of
money from an ATM

Von Smith

9/9/2020

Sending an electronic message with
the personally identifiable
information of T.E.

Von Smith

10/6/2020

Withdrawal of money from ATM

Von Smith

12/15/2020

K.P.

Withdrawal of money from ATM
12/2/2020

Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 10 of 22

Submission of a fraudulent UI
application

Lawson

10/30/20

Sending an electronic message with
the personally identifiable
information of P.M.

Yancy

7/5/2020

K.P.

Submission of a fraudulent UI
application

Yancy

7/14/2020

M.Q.

Sending an electronic message with
the personally identifiable
information of M.Q.

Yancy

7/14/2020

¥.Z.

Sending an electronic message with
the personally identifiable
information of Y.Z.

Yancy

7/14/2020

C.T.

Sending an electronic message with
the personally identifiable
information of C.T.

Bridges

7/6/2020

S.D.

Sending an electronic message with
the personally identifiable
information of S.D.

Adrea

10/20/2020

Possessing the personally identifying
information with intent to file a
fraudulent UI application

Adrea

12/19/2020

K.A.

Sending an electronic message with
the personally identifiable
information of K.A.

Watson

8/23/2020

BLP.

Sending an electronic message with
the personally identifiable
information of K.F.

Washington

7/26/2020

R.W.

Sending an electronic message with
the personally identifiable
information of R.W.

Washington

10/7/2020

R.W.

Withdrawal of money from an ATM

18 U.S.C. § 1343

10
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 11 of 22

COUNT THIRTY-ONE
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

Is The allegations set forth in Paragraphs 1 through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

2. Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant,

MICHAEL AKAME NGWESE AY MAKOGE,
a/k/a “Hype,” “2Hype,”

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, a debit card bearing the name of M.Q., S.C., Y.Z., S.D., and D.L. during
and in relation to Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349 and Wire
Fraud, in violation of 18 U.S.C. § 1343, as charged in Counts One, Two, Four, and Six through
Fourteen of this Indictment, respectively.

18 U.S.C. § 1028A(a)(1), (c)(S)

11
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 12 of 22

COUNT THIRTY-TWO
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

L. The allegations set forth in Paragraphs | through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

ie Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant,

DEMENTROUS VON SMITH,
a/k/a “Meecho,” “El Meecho,”

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, a debit card bearing the name of K.F., during and in relation to Conspiracy
to Commit Wire Fraud, in violation of 18 U.S.C. § 1349 and Wire Fraud, in violation of 18 U.S.C.
§ 1343, as charged in Counts One and Fifteen, Seventeen and Eighteen of this Indictment,

respectively.

18 U.S.C. § 1028A(a)(1), (c)(5)

12
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 13 of 22

COUNT THIRTY-THREE
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

La The allegations set forth in Paragraphs 1 through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

be Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant,

NADINE MAHORO MWAMIKAZI,

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, a text message with the name, date of birth, and social security number of
S.C., during and in relation to Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349
and Wire Fraud, in violation of 18 U.S.C. § 1343 as charged in Counts One and Nineteen of this
Indictment, respectively.

18 U.S.C. § 1028A(a)(1), (c)(5)

13
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 14 of 22

COUNT THIRTY-FOUR
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

1. The allegations set forth in Paragraphs | through 23 and25 through 34 of Count
One of this Indictment are incorporated here.

2: Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant,

SKY TIFFANY LAWSON,

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, the name, social security and date of birth of S.C., during and in relation
to Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349 and Wire Fraud, in violation
of 18 U.S.C. § 1343 as charged in Counts One and Twenty of this Indictment, respectively.

18 U.S.C. § 1028A(a)(1), (c)(5)

14
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 15 of 22

COUNT THIRTY-FIVE
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

1. The allegations set forth in Paragraphs 1 through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

ze Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant

CHRISTOPHER THOMAS YANCY,
a/k/a “Lil Bhris,” “Lil Chris,”

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, a debit card bearing the name of K.P.; and the name, date of birth and
social security number of M.Q. stored on the Notes section of his phone, during and in relation to
Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349 and Wire Fraud, in violation
of 18 U.S.C. § 1343 as charged in Counts One, Twenty-One and Twenty-Two of this Indictment,

respectively.

18 U.S.C. § 1028A(a)(1), (c)(5)

15
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COUNT THIRTY-SIX
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

1. The allegations set forth in Paragraphs | through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

2. Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant,

SAYQUAN LEON BRIDGES,
a/k/a “Quan,”

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, a screenshot of the UI benefits debit card account information in the name
of S.D., during and in relation to Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. §
1349 and Wire Fraud, in violation of 18 U.S.C. § 1343 as charged in Counts One and Twenty-Five
of this Indictment, respectively.

18 U.S.C. § 1028A(a)(1), (c)(5)
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 17 of 22

COUNT THIRTY-SEVEN
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

1. The allegations set forth in Paragraphs 1 through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

2. Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant,

CHRISTIAN MALIK ADREA,
a/k/a “Leak,” “Lil Leak,”

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, a debit card bearing the name of D.L., during and in relation to Conspiracy
to Commit Wire Fraud, in violation of 18 U.S.C. § 1349 and Wire Fraud, in violation of 18 U.S.C.
§ 1343 as charged in Counts One and Twenty-Six of this Indictment, respectively.

18 U.S.C. § 1028A(a)(1), (c)(5)
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 18 of 22

COUNT THIRTY-EIGHT
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

i. The allegations set forth in Paragraphs 1 through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

2. Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant,

STEPHAWN MALIK WATSON,
a/k/a “O-Dawg”

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, a screenshot bearing the name, date of birth and social security number of
K.F., during and in relation to Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349
and Wire Fraud, in violation of 18 U.S.C. § 1343 as charged in Counts One and Twenty-Eight of
this Indictment, respectively.

18 U.S.C. § 1028A(a)(1), (c)(5)

18
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COUNT THIRTY-NINE
(Aggravated Identity Theft)

The Grand Jury for the District of Maryland further charges that:

1. The allegations set forth in Paragraphs 1 through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

2. Between in or about February 2020 through in or about October 2021, in the
District of Maryland, the defendant,

AIYANNA MONE WASHINGTON,
a/k/a “Yanna,”

did, during and in relation to a felony violation enumerated in Title 18, United States Code, Section
1028A(c), knowingly possess and use, without lawful authority, a means of identification of
another person, to wit, name, social security number, and date of birth of M.Q., during and in
relation to Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349 and Wire Fraud,
in violation of 18 U.S.C. § 1343 as charged in Counts One, Twenty-nine, and Thirty of this
Indictment, respectively.

18 U.S.C. § 1028A(a)(1), (c)(5)

19
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 20 of 22

COUNT FORTY
(Stolen Keys Adopted by the Post Office)

The Grand Jury for the District of Maryland further charges that:

t. The allegations set forth in Paragraphs 1 through 23 and 25 through 34 of Count
One of this Indictment are incorporated here.

2. On or about October 5, 2021, in the District of Maryland, the defendant

CHRISTOPHER THOMAS YANCY,
a/k/a “Lil Bhris,” “Lil Chris,”

did knowingly and unlawfully possess a key that is suited to a lock adopted by the Postal Service
and in use of any lock box, lock drawer and other authorized receptable for the deposit or
delivery of mail matter, to wit: a series 258 USPS arrow key with intent to unlawfully or
improperly use said key.

18 U.S.C. § 1704

20
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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), 21 U.S.C. § 853(p), and 28 U.S.C. § 2461(c), in the event of a defendant's
conviction on any of the offenses charged in Counts One through Thirty of the Indictment.

Wire Fraud Forfeiture

2. Upon conviction of any of the offenses set forth in Counts One through Thirty,
the defendant,

MICHAEL AKAME NGWESE AY MAKOGE, a/k/a “Hype,” “2Hype;”
DEMENTROUS Von SMITH, a/k/a “Meecho,” “El Meecho;”
NADINE MAHORO MWAMIKAZI,

SKY TIFFANY LAWSON,

shall forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c),
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 obtained from his or her 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;

21
Case 1:22-cr-00219-LKG Document1 Filed 06/21/22 Page 22 of 22

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 that cannot be divided without

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).

Erek L. Barron
United States Iceman ®

SIGNATURE REDACTED

Foreperson

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