Indictment — United States v. Wylene Johnson et al., Eastern District of Pennsylvania (Document 1)

Summary

An Indictment against Wylene Johnson, Cookie Bundy, Hakeem Cooper, Barry Mitchell and Louis Barnett in the U.S. District Court for the Eastern District of Pennsylvania, Case 2:22-cr-00297-GEKP, filed 09/08/22 as Document 1. Counts One through Four charge mail fraud over Pandemic Unemployment Assistance checks and a debit card mailed to the defendants, and Count Five charges theft of public money under Sections 641 and 2. The grand jury alleges that the defendants filed approximately 90 PUA applications listing one Philadelphia mailing address and falsely stating job losses due to the COVID-19 pandemic. Count Six alleges a false EIDL application by Wylene Johnson, stating 13 other employees and $142,000 in sales, with a request for an emergency advance. The notice of forfeiture seeks the sum of $1,018,690.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Indictment — United States v. Wylene Johnson et al., Eastern District of Pennsylvania (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-2-22-cr-00297-dkt-1-e-d-pa-6a0d2ad595/, SHA-256 6affc2106db1006c11fdc925d15cc68e0be643c0765a3acbb995151bf2800a5b.

Full text

Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 1 of 20

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA CRIMINAL NO.

t' DATE FILED:

WYLENE JOHNSON VIOLATIONS:
COOKIE BUNDY f8 U.S.C. $ f34l (mail fraud - 4 counts)
HAKEEM COOPER 18 U.S.C. $ 64I (theft of public money -
BARRY MITCIIELL 4 counts)
LOUIS BARNETT 18 U.S.C. $ 2 (aiding and abetting)
Notice of forfeiture

INDICTM ENT
COUNTS ONE T HROUGH FOUR
(Mail Fraud)

TTIE GRAND JT'RY CHARGES THAT:

At all times material to this indictment:

INTRODUCTION

l. On March 13, 2020, the President declared the ongoing COVID-I9

pandemic to be an emergency under Section 501(b) of the Robert T. Stafford Disaster Relief and

Emergency Assistance Act.

2. On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security

Act (CARES Act) was signed into law. The CARES Act created the PUA (Pandemic

Unemployment Assistance) program, which provided unemployment benefits to individuals not

eligible for regular unemployment compensation or extended rmemployment benefits.

3. The PUA program was administered by the various states, including the

Commonwealth of Pennsylvani4 but its benefits were funded by the federal govemment. ln

Pennsylvania, the Pennsylvania Department oflabor and Industry (PA DLI) administered the
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 2 of 20

PUA program, on behalf of the United States Department of Labor, which was responsible for

overseeing the PUA program.

4. PA DLI required that a PUA claim be made online via the PUA website,

https://pua.benefits.uc.pa.gov. The applicant was required to enter personal identification

information (PII), including name, date ofbirth, social security number, email address, telephone

number, and a physical address. An applicant was also required to answer a series ofquestions

that enabled the PA DLI to determine the applicant's eligibility and payment amount. Once

awarded PUA benefits, the applicant was required to submit weekly certifications showing

continuing eligibility. While each state administered the application slightly differently, every

state referenced in this indictment required that the application for PUA benefits as well as the

weekly certifications be made online.

5. While each state administered its own PUA program, the application used

by each state was a standard online application form. The form consisted of27 different sections

including a range ofquestions within each section. Some ofthe questions asked for the

applicant's PII and biographical information while other questions dealt with the applicant's

eligibility for the program and work history. An applicant was required to provide his or her

current employment status and answer if he or she was able to accept ajob if offered. Ifthe

applicant could not accept ajob, the applicant was required to provide a reason for not being able

to accept ajob.

6. The applicant was also asked whether they were unemployed as a result of

a pandemic or major disaster. Ifthe applicant's employment had not been affected as a result ofa

pandemic or major disaster, the applicant was not eligible for PUA benefits. If the applicant's

2
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 3 of 20

employment had been affected by a pandemic or major disaster, the application was also

required to note in which state the applicant was affected by the pandemic or major disaster and

the nature of the pandemic or major disaster.

7. In the 'self-certification' section ofthe application, the applicant was

required to answer questions regarding the nature and impact ofa pandemic or major disaster on

the applicant's employment status. First, the applicant was required to disclose the pandemic or

major disaster which affected the applicant's employment. An applicant was only eligible to

receive weekly PUA benefits if the applicant was unemployed for reasons related to the COVID-

19 pandemic. Second, the applicant was required to disclose the date ofthe applicant's last day

of work. Finally, if the applicant quit their job due to COVID-I9, the applicant was required to

supply a reason for quitting.

8. As to all ofthese preceding questions, the applicant was required to

"acknowledge that I understand that making the certification is under penalty ofperjury and

intentional misrepresentation in self-certifring that I may fall in one or more of these categories

is fraud."

9. The applicant was also required to complete another certification, under

penalty ofperjury, that if offered ajob, the applicant must b€ able to accept it. An applicant was

required to read and understand the PUA Compensation Handbook, which indicated that any

eamings must be reported for each week a person works. The applicant was also required to

certifu once again as to the application that "all information is true and complete" and that if the

applicant provided false information the applicant could be subject to criminal prosecution.

-)
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 4 of 20

10. IfPA DLI or another state's administrative agency approved an application
for PUA benefits, the applicant was then eligible to receive benefits in the form of checks,

electronic fund transfers, or debit cards, and the checks and debit cards were mailed via the United

States Postal Service to the physical address that appeared on the application. When a state agency

approved an applicant's eligibility, the agency also esrablished the applicant's period ofbenefits,

amount ofweekly benefit, and maximum total benefit amount. However, even after this occurred,

the applicant did not receive the benefits unless the applicant performed the appropriate weekly

certifications.

11. The recipient ofPUA benefits received a unique applicant number that
corresponded to the applicant's initial application and weekly certifications. Payments for pUA

were based on a seven-day period, from Sunday through Saturday. Thus, the benefits recipient

was required to certiry every seven days that he or she: a) was ready, willing and able to work

each day; b) was seeking full time employment; c) did not refuse any job offers or referrals; and,

d) had reported any employment during the week and the gross pay or other payments received.

The weekly certification was required to be completed in a timely manner. A delay in the weekly

certificafion could result in a delay or denial of further payments.

12. From on or about May 1,2020,to on or about October 22,2020,
defendant WYLENE JOHNSON lived at 6338 Regent Street, Philadelphi4 Pennsylvania.

TIIE SCHEME

13. From on or about May 1,2020,to on or about September 6, 2021, in the
Eastem District of Pennsylvania, and elsewhere, defendants

WYLENE JOHNSON,
COOKIE BUNDY,

4
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 5 of 20

HAKEEM COOPER,
BARRY MITCHELL, and
LOUIS BARNETT,

and others known and unknown to the grand jury, devised and intended to devise a scheme to

defraud state and federal agencies, and to obtain money and property, specifically PUA benefits,

by means of false and fraudulent pretenses, representations, and promises, in violation of Title

18, United States Code, Section 1341.

MAI{NERAND MEANS

It was part of the scheme that:

14. Defendants WYLENE JOHNSON, COOKIE Bt_INDy, HAKEEM
COOPER" BARRY MITCHELL, and LOUIS BARNETT, as well as persons #t and #2, known

to the grand jury, associated with one another in and around the area of Oxford Village in

Philadelphi4 and on public social media platforms. Defendants JOHNSON and BtINDy

referred to each other as siblings on social media posts. Defendants JOHNSON, BtINDy,

COOPER, MITCHELL, and BARNETT, along with Person #1, posted commenrs and

photographs ofthemselves on public social media, including photographs ofthem together at

birthday parties and other social gatherings, sometimes wearing clothing bearing a common

insignia - all reflecting their common association.

15. Defendants COOKIE BLTNDY, HAKEEM COOPER, BARRY
MITCHELL, and LOUIS BARNETT filed and caused to be filed fraudulent pUA

applications in their names with their respective PII. All applications filed in the names of

defendants BUNDY, cooPER, MITCffiLL, and BARNETT listed a mailing address of 6338

Regetrt Street, Philadelphi4 Pennsylvania.

5
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 6 of 20

16. Defendant WYLENE JOHNSON filed and caused to be filed fraudulent
PUA applications in the names of other individuals with those individuals' respective PII and

fraudulent PUA applications in the names of other individuals using her own PII. The mailing

address listed on each ofthese applications was the home address of defendant JOHNSSN, 6338

Regent Street, Philadelphia, Pennsylvania.

17. After the fraudulent PUA applications had been filed, defendants
WYLENE JOHNSON, COOKIE BLTNDY, HAKEEM COOPER, BARRY MITCHELL, ANd

LOUIS BARNETT filed and caused to be filed the weekly certifications associated with each

respective application in order for PUA benefits to be issued on that application.

18. After PA DLI issued either a check, direct deposit payment, or a pUA
debit card for payment on each application, defendants WYLENE JOHNSON, COOKIE

BI-rNDY, HAKEEM cooPER, BARRY MITCHELL, and LoUIS BARNETT deposited the

checks into bank accounts, arranged for the direct deposits to be sent to a bank account which

they controlled, and,/or collected and possessed the puA debit card issued on the application.

Thereafter, defendants JOHNSON, BUNDY, COOPER, MITCHELL, and BARNETT made

direct expenditures using the PUA debit cards, withdrew the money from those cards at ATMs,

and/or transferred the money to financial accounts controlled by them.

19. On or about each ofthe following dates, in the Eastem District of
Pennsylvani4 and elsewhere, defendants

WYLENE JOHNSON,
COOKIE BUNDY,
HAKEEM COOPER,
BARRY MITCHELL, and
LOUIS BARNETT,

6
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 7 of 20

for the purpose of executing the scheme described above, knowingly caused to be delivered by

United States mail or a private carrier, according to the directions thereon the documents described

below, each mailing constituting a separate count:

COUNT DATE DESCRIPTIO\
I

1 May 26,2020 A PUA check mailed from Harrisburg,
Pennsylvania, addressed to defendant HAKEEM
I
COOPER at 6338 Regenr Street, Philadelphia.
lvania
2 May 27,2020 A PUA check mailed from Harrisburg,
Pennsylvania, addressed to defendant BARRY
MITCIIELL at 6338 Regent Street, Philadelphia,
lvania.
I
J June l. 2020 A PUA check mailed from Harrisburg,
Pennsylvania. addressed to defendant COOKJE I

I
BLTNDY at 6338 Regent Street. Philadelphia.
I 1

I January 27 ,2021 A PUA debit card mailed from either Shoreview,
Indiana or Minneapolis, Minnesota, addressed to
defendant LOUIS BARNETT at 4730 penn
Avenue, Philadelphia, lvania.

AII in violation of Title 18. United Stares Code, Section l34l

7
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 8 of 20

COUNT FIVE
(Theft of Public Money)

THE GRAND JURY FURTI{ER CHARGES THAT:

At all times material to this indictment:

1. Paragraphs I through 12 and 14 through 18 of Counts One Through Four

are incorporated here.

2. Defendants WYLENE JOHNSON, COOKIE BUNDY, HAKEEM

COOPE& BARRY MITCHELL, and LOUIS BARNETT filed and caused to be filed

approximately 90 PUA applications which listed 6338 Regent Street, Philadelphi4 pennsylvani4

as the mailing address, and falsely stated that the named applicant had lost his or her job
on a

particular date due to the COVID-I9 pandemic.

3. The statements on each application were false as the respective applicant

listed had not lost his or herjob due to the COVID-19 pandemic and the last day of work listed
on

each application necessarily was not the applicant's last day of work due to the covlD-Ig

pandemic. As a result of the false statements on each ofthe applications, pA DLI approved
the

applications and dispersed a total amounr of frrnds ofat least $954,6g5.

4. From on or about May 1,2020, to on or about September 6, 2021, in the

Eastem District of Pennsylvani4 and elsewhere, defendants

WYLENE JOHNSON,
COOKIE BUNDY,
HAKEEM COOPER,
BARRY MITCHELL, and
LOUIS BARNETT,

and others known and unknown to the grand jury, knowingly and willfinly stole and
converted,

and aided and abetted the stealing and conversion of, to their use and the use of another.
monev

8
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 9 of 20

and a thing of value of the United States, specifically, Pandemic Unemployment Assistance

lirnds under the care ofthe United States Department of Labor, in a value exceeding $1,000.

In violation of Title 1 8, United States Code, Sections 641 md 2.

9
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 10 of 20

COUNT SIX
(Theft of Public Monev)

TIIE, GRAND JURY FURTHERCIIARGES THAT:

At all times material to this indictment:

1. On March 27,2020, the Coronavirus Aid, Relief, and Economic Security

Act ("the GARES Act') (Pub. L. 116-136) became law and provided emergency assisrance for

individuals, families, and businesses affected by the coronavirus pandemic. The cARES Act

provided multiple programs for businesses including the Economic Injury Disaster Loan (..EIDL,')

program. The EIDL program provided low-rate emergency loan options for struggling
businesses

for amounts up to $500,000. This program was administered by the United States Small Business

Administration C'SBA'). The SBA was an executive branch agency of the united
states

govemment that provided support to entrepreneurs and small businesses. Applications
for the
EIDL program were made through an online SBA portal.

2. As part of the application progress, an applicant was required to submit

information about the applicant's business. This information included, .rmongst
other categories,

the organization type ofthe business, gross revenues for the twelve months preceding
January 31,

2020, cost of goods sold for the twelve months preceding January 31, 2020,
andthe number of

employees working at the business.

3. As part of the application, an applicant could also request an emergency

advance of$l0,000. The SBA paid this emergency advance within three days
ofthe applicant
submiuing the information. To receive this advance and the ultimate loan, the applicant
was

required to enter bank account information into which the advance funds and
loan were to be

deposited.

l0
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 11 of 20

4. Before an applicant could submit the application, the applicant was

required to certif,, under the penalty ofperjury and laws of the United States, that the

information on the application is true and correct.

5. The SBA proscribed limited uses for any funds, including the emergency

advance, dispersed under this program. The sBA required that the applicant only "use all

proceeds ofthis Loan solely as working capital to alleviate economic injury caused by disaster

occurring in the month of January 31, 2020 and continuing thereafter and to pay uniform

Commercial Code (UCC) lien filing fees."

6. On or about June 29,2020, defendant WYLENE JOHNSON submitted an

EIDL application. On the application, defendant JOHNSON falsely stated that she owned a sole

proprietorship located at her residential address in philadelphi4 pennsylvania. Defendant

JOHNSON also falsely stated that: a) her business had 13 other employees; and b) in the twelve

months prior to the pandemic hers business had $142,000 in sales and $1g,000 in cost of goods

sold. For deposit information, defendant JOHNSON provided her personal police and Fire

Federal Credit Union account ending in 2651.

7. In addition to the above-listed information on the application, defendant

WYLENE JOHNSON requested an emergency advance from the SBA.

8. Prior to submitting the applicatio4 defendanr WYLENE JOHNSON

certified that all information on the application was true and correct under the penalty ofthe laws

of the United States and perjury. The statements on the application were not true and correct but

false as the covlD-I9 pandemic did not cause any business intemrption to wyLENE
JOHNSON

and the business did not have the number ofemployees or prior revenue listed on the
application.

1l
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 12 of 20

9. On or about Jnly 2, 2020, defendant WYLENE JOHNSON received an

emergency advance of$10,000, which the SBA deposited into her Police and Fire Credit Union

personal bank account. This amount was revened by the SBA from her bank account on or about

luly 9,2020.

10. On or about July 9,2020, defendant WYLENE JOHNSON executed a
Loan Authorization and Agreement (*LA&A") with the SBA for an EIDL benefrt in the amounr

of approximately $52,005. As part of this LA&A, defendant JOHNSON certified rhat she would

spend the loan only on specified purposes. Defendant JOHNSON also specifically certified
the

following statement was true and accurate, "under penalty ofperjury ofthe united States of

Americ4 I hereby certiry that I am authorized to apply for and obtain a disaster loan on behalf of

Borrower, in connection with the effects of the COVID-I9 emergency."

I 1. In addition to the false statemenrs made on her initial application,

defendant WYLENE JOHNSON also made false statements when executing the LA&A.

Defendant JOHNSoN was not authorized under the EIDL program to apply for and obtain
a

disaster loan and she did not use the proceeds of the loan for authorized purposes. As
a result of

defendant JOHNSON's submission of an application with false statements and her execution
of
a false LA&A, on or about July 13,2020, the SBA deposited approximately
$52,005 into a pNC

bank account owned by defendant JOHNSON.

12. Thereafter, from on or about July 13, 2020, to on or about October 2,2020,
defendant WYLENE JOHNSON did not spend the EIDL funds on proper business uses
as required

by the application and LA&A. Rather, defendant JoHNsoN spenr funds on personal goods
and

items, including multiple expenditures at two different sporting goods stores, an electronics
store,

t2
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 13 of 20

a luxury handbag store, and on a vacation stay at an AirBnB location. Defendant JOHNSON also

withdrew approximately $40,000 in cash from the account after the July 13, 2020 SBA deposit.

By on or about october 2, 2020, no funds were left in defendant JoHNSoN's pNC account.

13. From on or about June 29, 2020, to on or about October 2, 2020, in the
Eastem District of Pennsylvani4 and elsewhere, defendant

WYLENEJOHNSON

knowingly and willfully stole and converted, to her use and the use of another, money and a

thing of value ofrhe United states, specifically, Economic Injury Disaster Loan funds rmder the

care of the United States Small Business Administration, in a value exceeding
$1,000.

In violation of Title 18. United States Code, Section 641.

13
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 14 of 20

COUNT SEVEN
(fheft of Public Money)

TIIE GRAND JI]RY FURTHER CHARGES THAT:

At all times material to this indictment:

l. Paragraphs I through 5 of Count Six are incorporated here.

2- on or about July 6,2020, defendant LOUIS BARNETT submitted an EIDL

application. on the application, defendant BARNETT falsely stated that he owned a sole

proprietorship located at his residential address in philadelphia, pennsylvania. Defendant

BARNETT also falsely stated that: a) the business activity was "agriculture;" b) his business
had

nine other employees; and c) in the twelve months prior to the pandemic his business had

$140,000 in sales and $18,000 in cost ofgoods sold. For deposit information, defendant

BARNETT provided his personal Police and Fire Federal Credit Union account ending
in 573 l.

3. In addition to the aboveJisted information on the applicatiorl defendant

LOUIS BARNETT requested an emergency advance from the SBA.

4. Prior to submitting the application, defendant LouIS BARNETT certified

that all information on the application w:rs true and conect under the penalty
of the laws of the
United States and perjury. The statements on the application were not true and conect
but false as
the COVID-I9 pandemic did not cause any business interruption to defendant
BARNETT and the
business did not have the number ofemployees or prior revenue listed
on the application.

5. on or about Jury 9, 2020, defendant Louls BARNETT received rhe
emergency advance of $9,000, which the SBA deposited into his wells Fargo personal
bank
account' Defendant BARNETT did not spend the emergency advance on proper
uses as authorized

by the SBA. Rather, he spent the emergency advance on personal items.

14
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 15 of 20

6. From on or about July 6,2020,to on or about September 1,2020, in the

Eastem District of Pennsylvani4 and elsewhere, defendant

LOUIS BARNETT

knowingly and willfully stole and converted, to his use and the use of another, money and a thing

of value of the United states, specifically, Economic Injury Disaster Loan funds under the care of

the United States Small Business Administration, in a value exceeding $1,000.

In violation of Title 18, United States Code, Section 641 .

t5
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 16 of 20

COUNT EIGHT
(Theft of Public Money)

TIIE GRAND JURY FURTIIER CHARGES TIIAT:

At all times material to this indictment:

l. Paragraphs 1 fhrough 5 of Count Six are incorporated here

2. On or about July 8,2020, defendant BARRy MITCHELL submitted an

EIDL application. On the application, defendant MITCTIELL falsely stated that he owned a sole

proprietorship located at his residential address in philadelphi4 permsylvania. Defendant

MITCHELL also falsely stated that: a) the business activity was "tattoo and piercing;', b) his

business had 12 other employees; and c) in the twelve months prior to the pandemic
his business

had $47,000 in sales and $ 12,000 in cost of goods sold. For deposit information, defendant

BARNETT provided his personal pNC bank account ending in 23g3.

3. In addition to the aboveJisted inforrnation on the applicatiorl defendant

BARRY MITCTIELL requested an emergency advance fiom the SBA.

4. Prior to submitting the apprication, defendant BARRy MITCHELL certified

that all information on the application was true and conect under the penalty of the
laws of the
United States and perjury. The statements on the application were not true and correct
but false as

the COVID-l9 did not cause any business interruption to defendant MITCHELL
and the business

did not have the number ofemproyees or prior revenue listed on the apprication.

5. on or about July 11, 2020, defendant BARRY MITCHELL received the
emergency advance of $3,000, which the SBA deposited into his personal pNC
bank account.
Defendant MITCHELL did not spend the emergency advance on proper
uses as authorized by the

16
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 17 of 20

SBA. Rather, he spent the emergency advance funds on personal items.

6. From on or about July 8,2020, to on or abour October l,2O2O, :rr.the

Eastem District ofPennsylvani4 and elsewhere, defendant

BARRYMITCHELL

knowingly and willfi.rlly stole and converted, to his use and the use of another, money and a thing

of value of the United states, specifically, Economic Injury Disaster Loan finds under the care of

the United States Small Business Administration, in a value exceeding $1,000.

In violation of Title 18, United States Code, Section 641.

t7
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 18 of 20

NOTICE OF RFEITURE

THE GRAND JURYTURTHER CHARGES THAT:

1. As a result ofthe violations of Title 18, United States Code, Sections 641

and l34l , as set forth in this indictrnent. defendants

WYLENE JOHNSON
COOKIE BUNDY,
HAKEEM COOPER,
BARRY MITCHELL, and
LOUIS BARNETT

shall forfeit to the United States of America any property that constitutes, or is

derived from, proceeds traceable to the commission of such offenses, including, but not limited

to, the srm of$1,018,690.

2 If any of the property subject to forfeiture, as a result of any act or omission

ofthe defendants:

(a) cannot be located upon the exercise ofdue diligence;

(b) has been transferred or sold to, or deposited with, a third party;

(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided

without difficulty;

it is the intent ofthe united States, pursuant to Title 2g, united states code, Section 2461(c)

incorporating Title 21, United States code, Section g53(p), to seek forfeiture
of any other
property ofthe defendants up to the value ofthe property subject to forfeiture.

18
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 19 of 20

All pursuant to Title 28, United States Code, Section 2461(c) and Title 18, Unired

States Code, Section 981(a)(1)(C).

A TRUE BILL:

Ati,a,.-l
JACQUELINE C. ROMERO
UNITED STATES ATTORIIEY

19
Case 2:22-cr-00297-GEKP Document 1 Filed 09/08/22 Page 20 of 20

UNITIID S'T{TIIS DISTRICT C0T]I{T

Eastern District of Pennsylvan ia

Crinrinal I)iv ision

THE UNITED STATES OF AMERICA

Wylene .lohnson, Cookic Bundy, I lakcem Coopcr, Barry Mitche ll, Louis Barnett

INDICl'MI'NT

('o rr nt s
l8 u.s.c. $ 1341, (mail fraud) 4 counrs and l8 U.S.c. {i 641 (rheft ol'public money) 4 counts

l:ilcd ur
oI A.t).20

( lcrk

llail, $

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