Information — United States v. Maurice Mills (District of New Jersey)

Summary

This information, filed in the U.S. District Court for the District of New Jersey in United States v. Maurice Mills, charges wire fraud under 18 U.S.C. § 1343 after the defendant waived prosecution by indictment. It describes the Pandemic Unemployment Assistance and Federal Pandemic Unemployment Compensation programs created by the CARES Act, signed on or about March 27, 2020. It charges that from at least about August 2020 through about September 2020 Mills obtained other individuals' personal identification information, used it to apply for unemployment insurance benefits from the State of New York, and caused the state to pay more than $450,000. The count rests on a UIB application sent from New Jersey to New York on or about September 25, 2020. A forfeiture allegation seeks proceeds under 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c).

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2020R01360/ADK

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA : Hon.
Vv. : Criminal No. 21-
MAURICE MILLS > 18U.5.C. § 1343
18 U.S.C. § 2

INFORMATION

The defendant having waived in open court prosecution by

indictment, the Acting United States Attorney for the District of New

Jersey charges:

BACKGROUND

1. At various times relevant to this Information:

a. Defendant MAURICE MILLS ("MILLS") was a resident of
New Jersey and New York.

b. On or about March 27, 2020, the Coronavirus Aid, Relief,
and Economic Security Act (the “CARES Act”) was signed into law. The CARES
Act created a new temporary federal unemployment insurance program called
Pandemic Unemployment Assistance (“PUA”). PUA provided unemployment
insurance benefits (““UIBs”) for individuals who were not eligible for other types
of unemployment (e.g., the self-employed, independent contractors, gig
economy workers). The CARES Act also created a new temporary federal

program called Federal Pandemic Unemployment Compensation (“FPUC”) that
provided an additional $600 weekly benefit to those eligible for PUA and regular
UIBs.

Cc. The New York State Department of Labor administered and
managed the regular unemployment and PUA programs in the State of New
York. Thus, subject to certain eligibility requirements, a person who was
unemployed, but who used to be employed by an employer in the State of New
York, could apply to receive UIBs from the State of New York.

THE SCHEME TO DEFRAUD

2. From at least in or about August 2020 through in or about
September 2020, in the District of New Jersey and elsewhere, the
defendant,

MAURICE MILLS,
did knowingly and intentionally devise and intend to devise a
scheme and artifice to defraud the State of New York and individuals,
and to obtain money and property from the State of New York, by
means of materially false and fraudulent pretenses, representations,
and promises, and, for the purpose of executing and attempting to
execute such scheme and artifice to defraud, did transmit and cause
to be transmitted by means of wire communications in interstate and
foreign commerce, certain writings, signs, signals, pictures, and
sounds, including a wire communication from inside of New Jersey

to outside of New Jersey, as more fully set forth below.
GOAL OF THE SCHEME TO DEFRAUD

3. The goal of the scheme and artifice to defraud was for
MILLS to enrich himself by obtaining money from the State of New
York by submitting fraudulent UIBs in the names of other
individuals.

MANNER AND MEANS OF THE SCHEME TO DEFRAUD

4. It was part of the scheme and artifice to defraud that:

a. MILLS obtained personal identification
information, including names, belonging to other individuals.

b. MILLS submitted applications for UIBs to the
State of New York using other individuals’ personal identification
information.

c. MILLS caused the State of New York to approve
and provide more than $450,000 in response to the false UIB

applications described herein.
5. On or about September 25, 2020, for the purpose of
executing the scheme and artifice to defraud, in the District of
New Jersey, and elsewhere, the defendant,

MAURICE MILLS,
knowingly and intentionally transmitted and caused to be
transmitted by means of wire communication in interstate and
foreign commerce, certain writings, signs, signals, pictures, and
sounds, namely a UIB application, from a location in New Jersey to
a location in New York.

In violation of Title 18, United States Code, Section 1343.
FORFEITURE ALLEGATION

1. The allegations contained in this Information are incorporated
by reference as though set forth in full herein for the purpose of alleging
forfeiture pursuant to Title 18, United States Code, Section 981(a)(1)(C), and
Title 28, United States Code, Section 2461 (c).

2. Upon conviction of the offense charged in this Information, the
government will seek forfeiture from defendant MILLS, in accordance with Title
28, United States Code, Section 2461(c), and Title 18, United States Code,
Section 981(a)(1)(C), of any and all property, real or personal, that constitutes
or is derived from proceeds traceable to the violations of Title 18, United States
Code, Section 1343.

3. If by any act or omission of defendant MILLS any of the
property subject to forfeiture herein:

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 which cannot

be subdivided without difficulty,
it is the intent of the United States, pursuant to Title 21, United States Code,
Section 853(p), as incorporated by Title 28, United States Code, Section
2461(c), to seek forfeiture of any other property of defendant MILLS up to the

value of the property described in this forfeiture allegation.

RACHAEL A. HON[illegible]
ACTING UNITED STATES ATTORNEY


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