Indictment — United States of America v. Jamel Newman and Darren Robinson, CR 21-108JJM (D.R.I.)

Summary

A federal grand jury in the District of Rhode Island returned this indictment, Cr. No. 21-108JJM, against Jamel Newman and Darren Robinson. It alleges that from about April through December 2020 Newman, Robinson and Rashaad Hill collected regular and expanded pandemic unemployment insurance benefits from the Rhode Island Department of Labor and Training while filing claims, in their own names and other people's, with agencies in California, Arizona, Nevada and Massachusetts that falsely said the applicants had lived and worked in those states. The counts charge conspiracy to commit wire fraud, wire fraud, aggravated identity theft and theft of government money exceeding $1,000 in PUA and FPUC benefits. Count Sixteen charges Newman with possessing a Glock 19 pistol on April 6, 2021 after a misdemeanor domestic violence conviction. The indictment is dated October 27, 2021.

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UNITED STATES DISTRICT COURT
DISTRICT OF RHODE ISLAND

CR 21- 108JJM
UNITED STATES OF AMERICA
Cr. No.
v.
In violation of 18 U.S.C. § 1349
JAMEL NEWMAN, (Conspiracy to Commit Wire
Fraud); 18 U.S.C. § 1343 (Wire
RS He DETTE anc Frau) 18 U.S.C. § 641 (Theft of
DARREN ROBINSON, Government Money); 18 U.S.C.
§ 1028 (Aggravated Identity Theft);
and 18 U.S.C. § 922(¢)(9)
Defendants. (Possession of Firearm by
Prohibited Person)
Forfeiture
INDICTMENT
The Grand Jury charges that:
COUNT ONE

(Conspiracy to Commit Wire Fraud - 18 U.S.C. § 1349)
Introduction

At all times relevant to this Indictment:

L Defendants JAMEL NEWMAN, DARREN ROBINSON, and RASHAAD
HILL each resided in Rhode Island.

2 The Unemployment Insurance Program (“UI Program”) was a joint
federal-state partnership administered on behalf of the U.S. Department of Labor by
agencies in each state. In Rhode Island, the UI Program was administered by the Rhode
Island Department of Labor and Training (RIDLT). In California, Arizona, Nevada, and

Massachusetts, the UI Programs were administered by the California Employment
Development Department (CAEDD), the Arizona Department of Economic Security
(AZDES), the Nevada Department of Employment, Training and Rehabilitation
(NVDETR), and the Massachusetts Department of Unemployment Assistance
(MADUA), respectively.

3, In March 2020, the Families First Coronavirus Response Act (FFCRA) and
Coronavirus Aid, Relief, and Economic Security (CARES) Act provided additional
funding for state UI agencies to respond to the COVID-19 pandemic. The CARES Act
allowed states to expand the scope of workers who were eligible to receive state UI
benefits, to extend the period of time for which workers could be eligible for UI
benefits, and to allow workers who may have exhausted UI benefits under traditional
programs to receive benefits. The CARES Act further expanded the ability of states to
provide benefits to unemployed workers by creating three new unemployment
programs, namely, the Pandemic Unemployment Assistance (PUA) program, which
permitted states to provide benefits to individuals who were self-employed, seeking
part-time employment, or otherwise would not qualify for regular unemployment
benefits, the Federal Pandemic Unemployment Compensation (FPUC) program, which
provided an additional benefit, initially in the amount of $600 and later, in the amount
of $300, in federal benefits to individuals collecting traditional UI program benefits, and
the Pandemic Emergency Unemployment Compensation (PEUC) program, which
provided additional weeks of benefits for individuals who had otherwise exhausted
their entitlement to regular UI benefits (collectively referred to herein as “expanded
pandemic UI benefits”) PUA and FPUC benefits were 100% federally funded benefits

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paid through state UI agencies.

4, To receive regular UI and expanded pandemic UI benefits from a state UI
agency, an applicant could file a claim, via the internet, with the state UI agency from
which he was eligible to seek benefits or could file an application by downloading or
requesting an application and mailing it into the state UI agency. An applicant was not
permitted to seek regular UI and expanded pandemic UI benefits and expanded
pandemic UI benefits in more than one state at the same time.

The Conspiracy

x Beginning on a date unknown to the Grand Jury but not later than in or
about April 2020 and continuing through in or about December 2020, in the District of
Rhode Island and elsewhere, the Defendants,

JAMEL NEWMAN,

RASHAAD HILL, and

DARREN ROBINSON,
did knowingly, willfully, and unlawfully combine, conspire, and agree with each other
and other persons, known and unknown to the Grand Jury, to commit wire fraud,
contrary to 18 U.S.C. § 1343, that is, did knowingly and with intent to defraud, devise
and intend to devise a scheme to defraud and to obtain money from multiple state UI
agencies, by means of materially false and fraudulent pretenses, representations, and

promises, knowing that they were false and fraudulent when made, through the

transmission in interstate commerce of wire communications.
The Object of the Conspiracy

6. The object of the conspiracy was for the Defendants to unlawfully enrich
themselves by filing claims for regular UI and expanded pandemic UI benefits with
RIDLT, and while seeking and receiving benefit payments from RIDLT, filing
applications for benefits with other state UI agencies in their names and the names of
other persons, and in those applications submitted to other state UI agencies, falsely
claiming that the applicant had resided and worked in states other than Rhode Island
and was eligible for regular UI benefits and expanded pandemic UI benefits in those

states,

Manner and Means of the Conspiracy
Va Beginning in or about April 2020 and continuing through in or about
December 2020, the Defendants, NEWMAN, HILL, and ROBINSON, engaged in
communications relating to the filing of on-line applications for regular UI and
expanded pandemic UI benefits in Rhode Island, and in states outside of Rhode Island,
and filed applications for such benefits in their own names, and in the names of other

individuals.

Acts in Furtherance of the Conspiracy

8. On or about April 8, 2020 and April 30, 2020, NEWMAN filed an
application with RIDLT for expanded pandemic UI benefits. NEWMAN trefiled for
benefits with RIDLT on or about September 15, 2020 and September 23, 2020. On his
applications, NEWMAN listed a phone number of 401-XXX-4202.

9, On or about August 23, 2021, HILL filed a claim with RIDLT for UI

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benefits, and listed his address as XX Ellery Street, Providence, RI, and his phone

number as 401-XXX-1493.

10.

It was further part of the scheme and artifice to defraud that Defendants

NEWMAN, ROBINSON, and HILL began filing fraudulent applications to obtain

regular UI and expanded pandemic UI benefits in other states outside of Rhode Island,

including the following applications, and exchanged text messages about applications

to various state UI agencies:

a.

On or about April 30, 2020, NEWMAN filed an application for
expanded pandemic UI benefits with MADUA, falsely claiming that he
had worked in Massachusetts and had been self-employed.

On or about May 1, 2020, HILL filed an application for regular and
expanded pandemic benefits with MADUA.

On or about May 2, 2020, NEWMAN and HILL exchanged text
messages about payment dates for MADUA claims.

On or about May 10, 2020, ROBINSON filed an application for
expanded pandemic UI benefits with MADUA.

On or about May 15, 2020, an application was filed with MADUA in the
name of P.G., listing a phone number, 401-XXX-4202, which was used
by NEWMAN on claims filed in his name.

On or about June 16, 2020, NEWMAN filed an application for expanded
pandemic UI benefits with AZDES, falsely claiming that he had worked
in Arizona and was self-employed with “Sideline business” and

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provided an Arizona mailing and residential addresses.

. Onor about June 18, 2020, HILL filed an application for expanded
pandemic UI benefits with AZDES, falsely claiming that he had worked
in Arizona and was self-employed with a “Sideline business” and
provided an Arizona residential addresses.

. Onor about June 18, 2020, HILL and NEWMAN exchanged text
messages in which they shared personal identifying information (PII) of
N.M.

On or about June 18, 2020, HILL attempted to file an online application
with AZDES in the name of N.M, recorded his online efforts to file the
application, and discussed the application with NEWMAN via text
messages. The application filed in the name of N.M. listed an address
of XX 86 Ellery Street, Providence, Rhode Island, and a phone number
of 401-XXX-1493, an address and phone number, respectively, listed on
claims filed by HILL in his name.

On or about June 21, 2020, an application was filed with AZDES in the
name of K.J., and payments were made to a Sutton Bank account in
ROBINSON’s name.

. Onor about June 25, 2020, NEWMAN and HILL exchanged text
messages in which NEWMAN sent HILL a screen shot of an AZDES
benefit summary pages and discussed when the benefits would be paid.
On or about June 25, 2020, ROBINSON and HILL exchanged text

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messages in which ROBINSON sent HILL a screen shot of an AZDES
benefit summary pages and discussed what ROBINSON should enter
on the online application form. HILL stated that he was “waiting for
Melz to send” him information.

. On or about June 25, 2020, ROBINSON filed an application with
AZDES, falsely claiming that he had worked for all of 2019 in Arizona
and provided an Arizona residential address.

. Onor about June 30, 2020, HILL and ROBINSON exchanged text ~
messages in which they discussed filing UI claims and which states
were paying on claims.

. Onor about July 1, 2020, NEWMAN and HILL exchanged text
messages about occupations to list in Nevada applications.

. Onor about July 1, 2020, HILL filed an application for PUA benefits
with NVDETR.

. Onor about July 15, 2020, HILL and NEWMAN exchanged text
messages and exchanged PII of R.W.

. Onor about July 22, 2020, an application was filed with CAEDD for
R.W., listing an address of XX Ellery Street, Providence, RI, an address
used by HILL in filing claims in his name.

. Onor about July 17, 2020, NEWMAN filed an application for expanded
pandemic UI benefits with CAEDD, falsely claiming that he worked in

California.
t.

aa.

On or about July 20, 2020, HILL filed an application for expanded
pandemic UI benefits with CA EDD, false claiming that he worked in
California.

On or about July 23, 2020, HILL and ROBINSON exchanged text
messages in which HILL stated that he would be filing an application
and would record his screen to show ROBINSON, and ROBINSON
responded to send the video via Snapchat to prevent a “paper trail;”
On or about July 24, 2020, ROBINSON filed an application for
expanded pandemic benefits with CAEDD, falsely claiming that he had
worked in customer service and as a nail technician in California.

On or about July 26, 2020, NEWMAN made cash advance withdrawals,
using a debit card issued by CAEDD at the Twin Rivers Casino,
Lincoln, Rhode Island.

On or about July 27, 2020, HILL and ROBINSON exchanged text
messages discussing how to file an application with CAEDD.

On or about July 29, 2020, HILL and ROBINSON exchanged text
messages discussing that ROBINSON had filed a Nevada application,
and that it had been rejected.

On or about October 24, 2020, HILL and NEWMAN exchanged text
messages and exchanged PII of R.C.

On or about November 18, 2020, NEWMAN and HILL exchanged text
messages regarding logging into the AZDES website and discussed

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checking what they with “Darren.”

bb. On or about November 18, 2020, ROBINSON and HILL exchanged text
messages in which ROBINSON informed HILL that he had been paid
by Arizona.

cc. On or about December 24, 2020, NEWMAN and HILL exchanged text
messages with a screenshot of an order for a fake California license in

the name of an individual, R.C.

All in violation of 18 U.S.C. § 1349.

COUNTS TWO - TEN

(18 U.S.C. § 1343 - Wire Fraud)
11. The allegations contained in paragraphs 1 through 10 of this Indictment
are re-alleged and incorporated by reference as though fully set forth herein.

Scheme to Defraud and to Obtain Monies

12, Fromat least in or about April 2020, and continuing until in or about
December 2020 in the District of Rhode Island and elsewhere,
JAMEL NEWMAN,

RASHAAD HILL, and
DARREN ROBINSON,

attempted to commit and did commit wire fraud, that is, did knowingly and with intent
to defraud, devise and intend to devise a scheme to defraud and to obtain money from
multiple state UI agencies, by means of materially false and fraudulent pretenses,
representations, and promises, knowing that they were false and fraudulent when

made, through the transmission in interstate commerce of wire communications.

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The Object of the Scheme to Defraud and to Obtain Monies

13. The object of the scheme was the same as the object of the conspiracy to
commit wire fraud. Accordingly, paragraph 6, is re-alleged and incorporated herein by
reference as though fully set forth herein.

Manner and Means of the Scheme to Defraud and to Obtain Monies

14. | The manner and means of the scheme to defraud were the same as the
manner and means of the conspiracy to commit mail fraud. Accordingly, paragraph 7 is
re-alleged and incorporated by reference as though fully set forth herein.

Execution of the Scheme to Defraud and to Obtain Monies

15. Onor about the dates listed below, in the District of Rhode Island and
elsewhere, for the purpose of executing aforesaid scheme and artifice to defraud and to
obtain money, and attempting to do so, knowingly transmitted and caused to be
transmitted by means of wire communication in interstate commerce to wit, using a
device accessing the internet, the filing of an online application for regular UI and
expanded pandemic UI benefits from the below listed state UI agencies, each

application constituting a separate count, as more particularly described below:

Count Defendant Date of Application | State UI Agency
2 NEWMAN April 30, 2020 MADUA

3 ROBINSON May 10, 2020 MADUA

4 NEWMAN June 16, 2020 AZDES

5 HILL June 18, 2020 AZDES

6 ROBINSON June 25, 200 AZDES

7 HILL July 1, 2020 NVDETR

8 NEWMAN July 17, 2020 CAEDD

9 HILL July 20, 2020 CAEDD

10 ROBINSON July 24, 2020 CAEDD

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All in violation of 18 U.S.C. § 1343.

COUNT ELEVEN

(Aggravated Identity Theft - 18 U.S.C. §§ 1028A, 2)

16. The allegations contained in paragraphs 1 through 10 of this Indictment
are re-alleged and incorporated by reference as though fully set forth herein.

17. Onor about May 15, 2020, in the District of Rhode Island and elsewhere,
defendant,

JAMEL NEWMAN,

did knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, to wit the name and social security number of P.G.,
during and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to wit,
conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349 and 18 U.S.C. § 1343,
knowing that the means of identification belonged to another actual person.

All in violation of 18 U.S.C. §§ 1028A(a)(1) and 2.

COUNT TWELVE

(Aggravated Identity Theft - 18 U.S.C. §§ 1028A, 2)
18. The allegations contained in paragraphs 1 through 10 of this Indictment
are re-alleged and incorporated by reference as though fully set forth herein.

19. Onor about June 18, 2020, in the District of Rhode Island and elsewhere,

Defendants,

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RASHAAD HILL and
JAMEL NEWMAN,

did knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, to wit the name and social security number of N.M..,
during and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to wit,
conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349 and 18 U.S.C. § 1343,
knowing that the means of identification belonged to another actual person.

All in violation of 18 U.S.C. §§ 1028A(a)(1) and 2, and Pinkerton v. United States,

328 U.S. 640 (1946).

COUNT THIRTEEN

(Aggravated Identity Theft - 18 U.S.C. §§ 1028A, 2)
20. The allegations contained in paragraphs 1 through 10 of this Indictment
are re-alleged and incorporated by reference as though fully set forth herein.
21. Beginning on or about July 15, 2020 and continuing through July 22, 2020,
in the District of Rhode Island and elsewhere, Defendant,

RASHAAD HILL and
JAMEL NEWMAN,

did knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, to wit the name and social security number of R.W.,
during and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to wit,
conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349 and 18 U.S.C. § 1343,

knowing that the means of identification belonged to another actual person.

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All in violation of 18 U.S.C. §§ 1028A(a)(1) and 2, and Pinkerton v, United States,

328 U.S. 640 (1946).

COUNT FOURTEEN

(Aggravated Identity Theft - 18 U.S.C. §§ 1028A, 2)

22. ‘The allegations contained in paragraphs 1 through 10 of this Indictment
are re-alleged and incorporated by reference as though fully set forth herein.

23. Onor about June 12, 2020, in the District of Rhode Island and elsewhere,
defendants,

DARREN ROBINSON,

did knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, to wit the name and social security number of K,J.,
during and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to wit,
conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349 and 18 U.S.C. § 1343,
knowing that the means of identification belonged to another actual person.

All in violation of 18 U.S.C. §§ 1028A(a)(1) and 2.

COUNT FIFTEEN

(Theft of Government Money - 18 U.S.C. § 641)
24. The allegations contained paragraphs 1 through 10 of this Indictment are
re-alleged and incorporated by reference as though fully set forth herein.
25. Fromat least in or about April 2020, and continuing until in or about
December 2020, in the District of Rhode Island and elsewhere, the Defendants,

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JAMEL NEWMAN,
RASHAAD HILL, and
DARREN ROBINSON,
did willfully and knowingly attempt to and did steal and purloin money of the United
States in an amount exceeding $1,000, to wit, funds paid as expanded pandemic UI

benefits, specifically, PUA and FPUC benefits.

All in violation of 18 U.S.C. § 641.

COUNT SIXTEEN

(Possession of Firearm by a Prohibited Person - 18 U.S.C. § 922(¢)(9))

26. On or about April 6, 2021, in the District of Rhode Island, the Defendant,
JAMEL NEWMAN,

knowing that he had been previously convicted of a misdemeanor crime of domestic
violence, to wit: Domestic Violence - Simple Assault and/or Battery on or about
September 17, 2019 (Case No. 61-2019-09766) and Simple Assault on or about February
28, 2019 (Case No. P2-2018-03267A), did knowingly possess a firearm, a Glock 19 Gen 5
9x19mm semi-automatic pistol, S/N BHNZ980, containing 8 rounds of 9x19mm
ammunition, said firearm and ammunition having been shipped and transported in

interstate commerce.

All in violation of 18 U.S.C. § 922(g)(9).

FIRST FORFEITURE ALLEGATION

Upon conviction of any of the Conspiracy to Commit and Wire Fraud offenses

alleged in Counts One through Ten of this Indictment, Defendants JAMEL NEWMAN,

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RASHAAD HILL, and DARREN ROBINSON shall forfeit to the United States of
America, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), all right, title, and
interest in any and all property, real or personal, which constitutes or is derived from
proceeds traceable to a violation of 18 U.S.C. § 1343, including but not limited to the
following:

A sum of money equal to the total amount of any property, real or personal,
which constitutes or is derived from proceeds and/or traceable to a violation of 18
US.C. §§ 1343 or 1349.

If any of the above-described forfeitable property, as a result of any act or omission
of the defendant, cannot be located upon the exercise of due diligence, has been
transferred, sold to, or deposited with a third party, has been placed beyond the
jurisdiction of the court, has been substantially diminished in value, or has been
commingled with other property which cannot be divided without difficulty, it is the
intent of the United States, pursuant to 21 U.S.C. § 853(p), as incorporated by 28 U.S.C.
§ 2461(c), to seek forfeiture of any other property of said defendant up to the value of the
forfeitable property described above.

All in accordance with 18 U.S.C. § 981(a)(1) as incorporated by 28 U.S.C. § 2461(c),

and Rule 32.2(a), Federal Rules of Criminal Procedure.

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SECOND FORFEITURE ALLEGATION

Upon conviction of Count Fifteen alleged in this Indictment, Defendant JAMEL
NEWMAN, shall forfeit to the United States pursuant to 18 U.S.C. § 924(d) and 28 U.S.C,
§ 2461(c), Glock 19 Gen 5 9x19mm semi-automatic pistol, containing 8 rounds of 9x19mm

ammunition.

All in accordance with 18 U.S.C. § 924.

A TRUE BILL:

<

RICHARD B. MYRUS
ACTING UNITED STATES ATTORNEY

DENISE MARIE BARTON

G, MICHAEL SEAMAN
STACEY P. VERONI

Assistant U.S. Attorneys
JOHN MOREIRA

Special Assistant U.S, Attorney

LEE H. VILKER
Assistant U.S. Attorney
Deputy Criminal Chief

Date: October 27, 2021

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