Information — United States v. Semaje Reffigee, Eastern District of Michigan (ECF No. 1)

Summary

A criminal information in United States of America v. Semaje Reffigee, Case No. 2:22-cr-20355-MFL-EAS, filed July 8, 2022 as ECF No. 1 in the U.S. District Court for the Eastern District of Michigan. Count One charges conspiracy to commit wire fraud under 18 U.S.C. § 1349. The information alleges that Reffigee, a contract Unemployment Insurance Examiner for the State of Michigan from October 2020, accepted bribes from outside actors to re-activate claims flagged for fraud and approve fraudulent unemployment claims through June 2021. It alleges that Reffigee re-activated or approved over 35 fraudulent claims valued at more than $300,000. The forfeiture allegation includes $2,800 in U.S. Currency, and the signature block names United States Attorney Dawn N. Ison.

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“Information — United States v. Semaje Reffigee, Eastern District of Michigan (ECF No. 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-2-22-cr-20355-dkt-1-e-d-mich-91b16bf12d/, SHA-256 42bff2346baf8b21a22101c8b90e6fbfe225543f75705a9b7ab1e335443771ea.

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Case 2:22-cr-20355-MFL-EAS ECF No. 1, PageID.1 Filed 07/08/22 Page 1 of 9

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN

United States of America, Case: 2:22−cr−20355
Assigned To : Leitman, Matthew F.
Plaintiff, Referral Judge: Stafford, Elizabeth A.
Assign. Date : 7/8/2022
v. Description: INFO USA V.REFFIGEE (NA)

Semaje Reffigee, Violations:
18 U.S.C. § 1349
Defendant.
________________________________/

INFORMATION

THE UNITED STATES ATTORNEY CHARGES:

GENERAL ALLEGATIONS

At all times relevant to this Information:

1. In response to the novel coronavirus disease (Covid-19) pandemic, the

federal government took a number of steps to provide urgently needed financial

assistance to the States.

2. The Families First Coronavirus Response Act (FFCRA), which became law

on March 18, 2020, provided additional flexibility for State unemployment

insurance agencies and additional administrative funding to respond to the

Covid-19 pandemic.

3. The Coronavirus Aid, Relief, and Economic Security (CARES) Act was

signed into law on March 27, 2020, and further expanded the ability of the States

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to provide unemployment insurance (UI) for many workers impacted by the

COVID-19 pandemic, including workers who are not ordinarily eligible for

unemployment benefits.

4. The Federal Pandemic Unemployment Compensation (FPUC) program was

created under the aforementioned statutes and allowed eligible individuals who are

collecting certain UI benefits, including regular unemployment compensation, to

receive an additional $600 in federal benefits per week for weeks of

unemployment ending on or before July 31, 2020.

5. Additionally, the Pandemic Emergency Unemployment Compensation

(PEUC) program was created and allowed those who have exhausted benefits

under regular unemployment compensation or other programs to receive up to

13 weeks of additional, federally funded benefits

6. In order to obtain any of the above-referenced benefits, an individual needed

to initiate a claim. The overwhelming majority of unemployment claims were filed

online through state-organized websites. In most cases, in order to be eligible for

unemployment benefits, a worker must demonstrate a certain level of earnings in

several quarters immediately preceding the application. The amount of

unemployment benefits that a claimant might be eligible for depends on a variety

of factors, including, but not limited to, the length of his or her previous

employment and the amount of wages he or she earned. However, under the

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programs outlined above, certain individuals may have become eligible for UI

benefits in the first instance, or eligible for a greater amount of UI benefits than

they would have been if not for various federal programs.

7. Different states have different ways of providing claimants with UI benefits.

Multiple states, including Michigan, provide benefits through the use of a prepaid

debit card, issued by Bank of America and sent to the claimant through the mail. If

a claim is approved, unemployment benefits are loaded onto the debit card(s)

electronically, and additional benefits are loaded onto the card(s) electronically

every two weeks. Alternatively, a claimant can provide a bank routing number and

bank account in which to have their unemployment benefits directly deposited

electronically. Additional benefits are then deposited into the bank account

electronically every two weeks.

8. In October 2020, defendant Semaje Reffigee accepted a contract position to

work for the State of Michigan as an Unemployment Insurance Examiner (UIE). A

UIE services claimants, employers, and the public regarding the SOM’s UI

programs. SOM officials detailed that UIEs are responsible for reviewing,

processing, and verifying the legitimacy of various UI claims.

9. Reffigee worked as a UIE in a full time telework capacity, from her

residence in Detroit, Michigan. Reffigee used computer equipment provided by

her employer to access the SOM UIA’s Michigan Integrated Data Automated

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System (MiDAS) system. The SOM’s MiDAS system is the state’s primary

computer system utilized to intake, adjudicate, and pay PUA claims.

10. Between October 2020 and June 2021, Reffigee worked with outside actors,

known and unknown to law enforcement. Those actors entered numerous false

claims into the SOM’s UIA system, many of which were filed using stolen

identities. These actors communicated with Reffigee via cellular telephone calls

and texts. Reffigee accepted bribes in return for approving many of these claims.

COUNT ONE
18 U.S.C. § 1349 – Conspiracy to Commit Wire Fraud

Semaje Reffiee

11. The allegations in paragraphs 1 - 10 are hereby repeated, realleged, and

incorporated by reference as if fully set forth herein.

12. Beginning on a date unknown to the government, but at least as early as

October 2020, and continuing through at least June 2021, in the Eastern District of

Michigan, Southern Division, and elsewhere, Defendant Semaje Reffigee, did

knowingly, intentionally, and willfully combine, conspire, confederate, and agree

with multiple individuals, known and unknown to the government, to commit wire

fraud. That is, members of the conspiracy, with the intent to defraud, knowingly

devised and executed a scheme and artifice to defraud and obtain money and

property by means of materially false and fraudulent pretenses and representations.

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Case 2:22-cr-20355-MFL-EAS ECF No. 1, PageID.5 Filed 07/08/22 Page 5 of 9

13. The purpose of the scheme and artifice to defraud was for members of the

conspiracy to unlawfully obtain state and federal unemployment insurance (UI)

benefits. In executing this scheme, members of the conspiracy caused the

transmission of writings, signals, and sounds by means of wire communication in

interstate commerce.

14. It was part of the scheme and artifice that members of the conspiracy

submitted false and fraudulent UI benefit claims to the State of Michigan, in the

name(s) of various individuals, without those individuals’ knowledge or approval.

15. It was further a part of the scheme and artifice that members of the

conspiracy would use these individuals’ Social Security Numbers and other

personally identifiable information (PII) in the course of the UI benefit claim

submission process.

16. It was further a part of the scheme and artifice that, for each of the submitted

UI benefit claims, members of the conspiracy would falsely certify that the

purported claimant was unemployed due to Covid-19.

17. It was further a part of the scheme and artifice that, for each of the submitted

UI benefit claims, members of the conspiracy would either (1) cause one of the

issuing banks, to include Bank of America, to mail a debit card to an address

within their control, or (2) cause one of the issuing banks to deposit benefits into

an account controlled by members of the conspiracy. These debit cards (or bank

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accounts) were then loaded, electronically, with state and federal UI benefits by the

various state agencies responsible for administering their respective UI programs,

causing wire transmissions in, and affecting, interstate commerce.

18. It was further a part of the scheme and artifice that once members of the

conspiracy obtained these debit cards, they would use them to make withdrawals

from various ATMs in the Eastern District of Michigan, again causing wire

transmissions in, and affecting, interstate commerce.

19. It was further a part of the scheme and artifice that defendant Semaje

Reffigee would, at the direction of members of the conspiracy, abuse her position

as a UIE to both (1) re-activate claims that had previously been flagged for fraud

within the MiDAS system, and (2) go outside her assigned workflow to approve

fraudulent claims in the first instance.

20. In total, Reffigee re-activated or approved over 35 fraudulent claims valued

at more than $300,000.

21. All in violation of Title 18, United States Code, Section 1349.

FORFEITURE ALLEGATIONS

22. The allegations set forth in Count One of this Information are hereby

incorporated by reference for purposes of alleging forfeiture pursuant to the

provisions of Title 18, United States Code, Section 981(a)(1)(C) together with Title

28, United States Code, Section 2461(c).

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23. As a result of the forgoing violation of Title 18, United States Code, Section

1349, as charged in Count One of this Information, the Defendant shall forfeit to

the United States any property, real or personal, which constitutes, or is derived

from, any proceeds obtained, directly or indirectly, as a result of such violation(s),

pursuant to Title 18, United States Code, Section 981(a)(1)(C) together with Title

28, United States Code, Section 2461(c), including, but not limited to, $2,800 in

U.S. Currency.

24. Substitute Assets: If the property described above as being subject to

forfeiture, as a result of any act or omission of the Defendant:

a. Cannot be located upon the exercise of due diligence;

b. Has been transferred or 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 of America shall be entitled to forfeiture of substitute property

pursuant to Title 21, United States Code, Section 853(p), and Title 28, United

States Code, Section 2461(c).

25. Money Judgment: Upon conviction of the violations alleged in Count One

of this Information, the United States will seek a forfeiture money judgment

against the Defendant in an amount equal to the total amount of proceeds he
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obtained as a result of his violations of Title 18, United States Code, Section 1349

as alleged in this Information.

Dawn N. Ison
United States Attorney

s/John K. Neal
JOHN K. NEAL
Chief, White Collar Crimes

s/Ryan A. Particka
RYAN A. PARTICKA
Assistant U.S. Attorney

s/Sarah Youngblood
SARAH YOUNGBLOOD
Assistant U.S. Attorney

Dated: July 8, 2022

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(Companion Case information MUST be completed by AUSA and initialed.)

United States District Court Criminal Case Cover Sheet Case Number
Eastern District of Michigan 2:22−cr−20355

NOTE: It is the responsibility of the Assistant U.S. Attorney signing this form to complete it accurately in all respects.

Companion Case Number:
Companion Case Information
This may be a companion case based upon LCrR 57.10 (b)(4)1: Judge Assigned:

Yes No AUSA’s Initials: R.A.P

Case Title: USA v. Semaje Reffigee

County where offense occurred : Wayne

Check One: Felony Misdemeanor Petty

Indictment/ ✔ Information --- no prior complaint.
Indictment/ Information --- based upon prior complaint [Case number: ]
Indictment/ Information --- based upon LCrR 57.10 (d) [Complete Superseding section below].

Superseding Case Information

Superseding to Case No: Judge:

Corrects errors; no additional charges or defendants.
Involves, for plea purposes, different charges or adds counts.
Embraces same subject matter but adds the additional defendants or charges below:

Defendant name Charges Prior Complaint (if applicable)

Please take notice that the below listed Assistant United States Attorney is the attorney of record for
the above captioned case.

July 8, 2022 s/Ryan A. Particka
Date Ryan A. Particka
Assistant United States Attorney
211 W. Fort Street, Suite 2001
Detroit, MI 48226-3277
Phone:(313) 226-9635
Fax: (313) 226-2873
E-Mail address: ryan.particka@usdoj.gov
Attorney Bar #:

1 Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, or (2) the same
or related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be companion cases
even though one of them may have already been terminated.
5/16

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