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Information — United States v. Rochelle L. Turner, Western District of Tennessee (Document 1)

Summary

A criminal information in United States of America v. Rochelle L. Turner, filed May 8, 2025 as Document 1 in No. 2:25-cr-20103-SHL in the U.S. District Court for the Western District of Tennessee, Western Division. Count 1 charges making false claims under Title 18, United States Code, Section 287. The information alleges that from on or about March 11, 2020 to on or about May 13, 2020 Turner submitted false letters, purporting to be from employers, to the Tennessee Emergency Cash Assistance program funded by the Department of Health and Human Services, stating that Turner and others had lost employment because of the COVID-19 pandemic. An attached notice of penalties lists not more than 3 years, a $100,000 fine, or both, and the signature block names Acting United States Attorney Reagan Taylor Fondren.

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“Information — United States v. Rochelle L. Turner, Western District of Tennessee (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-2-25-cr-20103-dkt-1-w-d-tenn-25387a16a9/, SHA-256 e1a0f0c176f8f8a7820004fbfb2bc063797b7a05e65f6264df3154757dd86b46.

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Case 2:25-cr-20103-SHL Document1 Filed 05/08/25 Pagelof4 PagelD1

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION

UNITED STATES OF AMERICA, _)
v. } 48U8.C. § 287
ROCHELLE L. TURNER
Defendant.

INFORMATION

BACKGROUND

1. The United States Department of Health and Human Services (“HHS”) funded the
State of Tennessee Department of Human Services (“TDHS’) Temporary Assistance for
Needy Families (“TANF”) Emergency Cash Assistance (“ECA”) program. The ECA
program provided financial assistance to families that had been significantly affected by

the COVID-19 pandemic because of lost employment.

2. The defendant ROCHELLE L. TURNER engaged in a scheme to submit false,

fictitious, and fraudulent letters to the ECA program purporting to be from employers

verifying that she and other individuals had lost their employment because of the COVID-

19 pandemic.
COUNT 1
3. From on or about March 11, 2020, to on or about May 13, 2020, in the Western
District of Tennessee,

ROCHELLE L. TURNER
made and presented to the federally funded Tennessee Emergency Cash Assistance

program claims upon and against the United States Department of Health and Human
¥Case 2:25-cr-20103-SHL Document1 Filed 05/08/25 Page2of4 PagelD2

a

Services(“HHS”) knowing that these claims were false, fictitious, and fraudulent; in

violation of Title 18, United States Code, Section 287.

DATED: 3/u]as

REAGAN TAYLOR FONDREN
ACTING UNITED STATES ATTORNEY
= a

* Case 2:25-cr-20103-SHL Document1 Filed 05/08/25 Page3o0f4 PagelD3

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION

UNITED STATES OF AMERICA, )

Plaintiff Criminal No.
v. 18 U.S.C. § 287
ROCHELLE L. TURNER,

Defendant.

NOTICE OF PENALTIES
COUNT 1
[nmt 3 yrs, $100,000 fine, or both; nmt 1 yr supervised release; $100 special
Case 2:25-cr-20103-SHL Document1 Filed 05/08/25 Page4of4 PagelD4

UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
Vv. Criminal No. 25-1-006

ROCHELLE L. TURNER,

Defendant.

ELEMENTS OF THE OFFENSE

To sustain a conviction under 18 U.S.C. section 287, the government must
prove: 1) the defendant made a claim against an agency of the United States; 2) the
claim was false or fraudulent; 3) the defendant knew the claim was false or

fraudulent; and 4) the fraudulent claim was material to the federal agency involved.


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SHA-256
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archive.org
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