Police Criminal Complaint, Commonwealth of Pennsylvania, Pittsburgh Municipal Court
Summary
A Pennsylvania police criminal complaint in Pittsburgh Municipal Court, Allegheny County, sworn by affiant John Dilucente for the Attorney General, against Rochelle Oaks, complaint number OCW-20-0012. It charges corrupt organization offenses under 18 Pa. C.S. §911(b)(3) and (b)(4), theft by unlawful taking during a disaster, criminal conspiracy and theft by deception of more than $2,000. It alleges that Oaks, Linda Slade, Stacy Robinson, Keith Brown and others worked together to defraud the Pennsylvania Department of Labor of Pandemic Unemployment Assistance Funds, with the offense dated on or about 06/03/2020.
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COMMONWEALTH OF PENNSYLVANIA POLICE CRIMINAL COMPLAINT
COUNTY OF: ALLEGHENY COMMONWEALTH OF PENNSYLVANIA
MDJ: PITTSBURGH MUNICIPAL COURT VS.
Magisterial District Number: 05-0-03 DEFENDANT: (NAME and ADDRESS):
Address: 660 FIRST AVENUE ROCHELLE OAKS
PITTSBURGH, PA 15219 First Name Middle Name Last Name Gen.
2540 IRWIN AVE PITTSBURGH, PA 15214
Phone: 412.350.6715
NCIC Extradition Code Type
Felony - Full Extradition
Distance: _______
DEFENDANT IDENTIFICATION INFORMATION
Docket Number Date Filed OTN/LiveScan Number Complaint/Incident Number Request Lab Services?
______ G 885185-0 OCW-20-0012 Yes
GENDER FEMALE DOB 07/13/1954 POB Add’l DOB Co-Defendant(s)
RACE BLACK First Name Middle Name Last Name Gen.
ETHNICITY AKA
HAIR COLOR BLK (BLACK) EYE COLOR BRO (BROWN)
WEIGHT (lbs.)
DNA DNA Location 165
FBI Number MNU Number Ft. HEIGHT In.
Defendant Fingerprinted 5 04
Fingerprint Classification
DEFENDANT VEHICLE INFORMATION
Plate # State Hazmat Registration Oth. NCIC Veh. Code Reg.
Comm'l School
Sticker (MM/YY) Same
Veh. Ind. Veh.
as Def.
VIN Year Make Model Style Color
Office of the attorney for the Commonwealth Approved Disapproved because:
(The attorney for the Commonwealth may require that the complaint, arrest warrant affidavit, or both be approved by the attorney for the Commonwealth prior
to filing. See Pa.R.Crim.P. 507).
name of the attorney for the Commonwealth) (Signature of the attorney for the Commonwealth) (Date)
I, JOHN DILUCENTE PAAG563
(Name of the Affiant) (PSP/MPOETC -Assigned Affiant ID Number & Badge #
of ATTORNEY GENERAL PA0222400
(Identify Department or Agency Represented and Political Subdivision) (Police Agency ORI Number)
do hereby state: (check appropriate box)
1. X I accuse the above named defendant who lives at the address set forth above
I accuse the defendant whose name is unknown to me but who is described as
I accuse the defendant whose name and popular designation or nickname are unknown to me and whom I have,
therefore, designated as John Doe or Jane Doe
with violating the penal laws of the Commonwealth of Pennsylvania at 301 PITTSBURGH CITY
(Subdivision Code) (Place-Political Subdivision)
In Allegheny County 02 on or about 06/03/2020 12:00
(County Code)
AOPC 412A - Rev. 07/18 Page 1 of 5
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if
appropriate. When there is more than one offense, each offense should be numbered chronologically.
(Set forth a brief summary of the facts sufficient to advise the defendant of the nature of the offense(s) charged. A citation to the statute(s) allegedly violated,
without more, is not sufficient. In a summary case, you must cite the specific section(s) and subsection(s) of the statute(s) or ordinance(s) allegedly violated. In
addition, social security numbers and financial information (e.g. PINS) should not be listed. If the identity of an account must be established, list only the last four
digits. 204 PA.Code §§213.1 – 213.7.)
Inchoate Attempt Solicitation Conspiracy
Offense 18 901 A 18 902 A 18 903
X 1 911 B3 of the 18 1 F1
Lead? Offense# Section Subsection PA Statute (Title) Counts Grade NCIC Offense Code UCR/NIBRS Code
PennDOT Data Accident
Safety Zone Work Zone
(if applicable) Number
Statute Description/Acts of the accused associated with this Offense:
18 911B3 CORRUPT ORGANIZATION F1 1 COUNT
The actor, employed by or associated with an enterprise, conducted or participated, directly or indirectly,
in the conduct of such enterprise's affairs through a pattern of racketeering activity, namely, Rochelle Oaks,
Linda Slade, Stacy Robinson, Keith Brown and others known and unknown operated a cheme to defraud the
Pennsylvania Department of Labor of Pandemic Unemployment Assistance Funds in violation of 18 Pa. C.S.
§911(b)(3).
Inchoate Attempt Solicitation Conspiracy
Offense 18 901 A 18 902 A 18 903
2 911 B4 of the 18 1 F1
Lead? Offense# Section Subsection PA Statute (Title) Counts Grade NCIC Offense Code UCR/NIBRS Code
PennDOT Data Accident
Safety Zone Work Zone
(if applicable) Number
Statute Description/Acts of the accused associated with this Offense:
18 911B4 CORRUPT ORGANIZATION F1 1 COUNT
The actor conspired with Rochelle oaks, Linda Slade, Stacy Robinson, Keith Brown and others known
and unknown operated a scheme to defraud the Pennsylvania Department of Labor of Pandemic
Unemployment Assistance Funds to violate any of the provisions of subsections (1),(2) or (3) of Section
911(b) of the Pennsylvania Crimes Code, in violation of 18 Pa. C.S. §911(b)(4).
AOPC 412A - Rev. 09/08 Page 2 of 5
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
Inchoate Attempt Solicitation Conspiracy
Offense 18 901 A 18 902 A 18 903
3 3921 A of the 18 1 F2
Lead? Offense# Section Subsection PA Statute (Title) Counts Grade NCIC Offense Code UCR/NIBRS Code
PennDOT Data Accident
Safety Zone Work Zone
(if applicable) Number
Statute Description/Acts of the accused associated with this Offense:
18 3921A THEFT BY UNLAWFUL TAKING F2 1 COUNT
The actor unlawfully took, or exercised unlawful control over movable property, namely Pandemic
Unemployment Assistance Funds from Pennsylvania Department of labor with the intent to deprive the
owner thereof and the offense was committed during a manmade disaster, a natural disaster or a
war-caused disaster, in violation of 18 Pa. C.S. §3921(a).
Inchoate Attempt Solicitation X Conspiracy
Offense 18 901 A 18 902 A 18 903
4 903 A1 of the 18 1 F2
Lead? Offense# Section Subsection PA Statute (Title) Counts Grade NCIC Offense Code UCR/NIBRS Code
PennDOT Data Accident
Safety Zone Work Zone
(if applicable) Number
Statute Description/Acts of the accused associated with this Offense:
18 903A1 CRIMINAL CONSPIRACY F2 1 COUNT
The actor, with the intent of promoting or facilitating the crime of 18:903:A1 conspired and agreed with
Linda Slade, Stacy Robinson, Keith Brown and others known and unknown that they or one or more of them
would engage in conduct constituting such crime or an attempt or solicitation to commit such crime, and in
furtherance thereof did commit an overt act in violation of 18 Pa. C.S. §903 (a)(1).
Inchoate Attempt Solicitation Conspiracy
Offense 18 901 A 18 902 A 18 903
5 3922 A1 of the 18 1 F3
Lead? Offense# Section Subsection PA Statute (Title) Counts Grade NCIC Offense Code UCR/NIBRS Code
PennDOT Data Accident
Safety Zone Work Zone
(if applicable) Number
Statute Description/Acts of the accused associated with this Offense:
18 3922A1 THEFT BY DECEPTION F3 1 COUNT
The actor intentionally obtained or withheld property, namely, Pandemic Unemployments Assistance
Funds with a total value greater than $2,000 belonging to Pennsylvania Department of Labor by deception, in
violation of, 18 Pa. C.S. §3922.
AOPC 412A - Rev. 09/08 Page 3 of 5
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
Inchoate Attempt Solicitation Conspiracy
Offense 18 901 A 18 902 A 18 903
6 4911 A2 of the 18 1 F3
Lead? Offense# Section Subsection PA Statute (Title) Counts Grade NCIC Offense Code UCR/NIBRS Code
PennDOT Data Accident
Safety Zone Work Zone
(if applicable) Number
Statute Description/Acts of the accused associated with this Offense:
18 4911A2 TAMPERING WITH PUBLIC RECORDS OR INFORMATION F3 1 COUNT
The actor made, presented or used a record, document or thing knowing it to be false, and with intent
that it be taken as a genuine part of any record, document or thing belonging to, or received or kept by, the
government for information or record, or required by law to be kept by others for information of the
government, namely Pandemic Unemployment Assistance Application, with the intent to defraud or injure
another, in violation of 18 Pa. C.S. §4911(a)(2) and (b).
AOPC 412A - Rev. 09/08 Page 4 of 5
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
2. I ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges I have
made.
3. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and
belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S.§4904)
relating to unsworn falsification to authorities.
4. This complaint is comprised of the preceding page(s) numbered through
5. I certify that this filing complies with the provisions of the Case Records Public Access Policy of the Unified Judicial
System of Pennsylvania that require filing confidential information and documents differently than non-confidential
information and documents.
The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth
of Pennsylvania and were contrary to the Act(s) of the Assembly, or in violation of the statutes cited.
(Before a warrant of arrest can be issued, an affidavit of probable cause must be completed, sworn to before the
issuing authority, and attached.)
, 03/29/2021 /JOHN DILUCENTE/
(Signature of Affiant)
(Date)
AND NOW, on this date I certify that the complaint has been properly completed and verified.
An affidavit of probable cause must be completed before a warrant can be issued.
(Magisterial District Court Number) (Issuing Authority)
SEAL
AOPC 412A - Rev. 09/08 Page 5 of 5
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
AFFIDAVIT of PROBABLE CAUSE
1. WHEN:
a) Date when Affiant received information:
b) Date when the source of information (Police Officers, Informant, Victim, Co-Defendant, Defendant, etc.) received information:
2. HOW:
a) How Affiant knows this particular person commited crime: (personal observation, defendant's admissions, etc.):
b) How the source of information knows this particular person committed the crime:
c) How both Affiant and/or source of information knows that a particular crime has been commited:
3. WHAT CRIMES:
18 4911 A2 TAMPERING WITH PUBLIC RECORDS OR INFORMATION
18 911 B4 CORRUPT ORGANIZATION
18 903 A1 CRIMINAL CONSPIRACY
18 3921 A THEFT BY UNLAWFUL TAKING
18 3922 A1 THEFT BY DECEPTION
18 911 B3 CORRUPT ORGANIZATION
4. WHERE CRIME(S) COMMITTED:
PA DEPARTMENT OF LABOR & INDUSTRY 301 5TH AVENUE SUITE 330 PITTSBURGH, PA 15222
5. WHY AFFIANT BELIEVES THE SOURCE OF INFORMATION:
Source is presumed reliable, i.e. other Police Officer, Eyewitness, Victim of Crime, etc.
Source has given information in the past which has led to arrest and/or conviction
Defendant's reputation for criminal activity
This source made declaration against his/her penal interest to the above offense
Affiant and/or other Police Officers corroborated details of the information
Page 1 of 7
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
AFFIDAVIT OF PROBABLE CAUSE
Your Affiants, Special Agents John DiLucente and Greg Matthews of the Pennsylvania Office of Attorney General (OAG), being
duly sworn to law, depose and say:
I. AFFIANTS’ BACKGROUND
Pedigrees
Your Affiant, Agent John DiLucente, is a Special Agent employed by the Pennsylvania Office of Attorney General, Bureau of
Criminal Investigation assigned to the Financial Crimes Section, and is empowered by law to conduct investigations and make
arrests relating to public corruption, white-collar crimes, theft, fraud, election code violations and other violations of Pennsylvania
Law. Your Affiant has conducted numerous investigations involving financial crimes. Your Affiant has been so employed since by
the Internal Revenue Service Criminal Investigation Division for 27 years, prior to that position worked in the civil division of the IRS
for 4 years and is currently assigned to the Financial Crime Section in Pittsburgh, Pennsylvania.
Your Affiant, Supervisory Special Agent Gregory Matthews, is a Supervisory Special Agent with the Pennsylvania Office of
Attorney General, currently assaigned to the Bureau of Criminal Investigations (BCI), Western Region Office. Your Affiant has been
a Special Agent with the Attorney General's Office since 2015 and a Supervisory Special Agent since 2018. Prior to being
assigned to BCI your Affiant was assigned to the Medicaid Fraud Unit. Prior to 2015 your Affiant was a member of the Allegheny
County Bureau of Police for approximately twenty-eight (28) years, the majority of that time assigned to the Detective Division.
Your Affiant’s law enforcement duties and responsibilities, in part, arise from the governing provisions of the Commonwealth
Attorney’s Act in regard to criminal investigation referrals from Commonwealth agencies, to include any such referral(s) from
any/all District Attorneys within the Commonwealth. The information contained in this affidavit was learned directly by your Affiant,
or relayed by other law enforcement officers and/or other individuals who are known to your Affiant and will be available to testify at
any necessary court proceeding.
Based upon your Affiants’ law enforcement experience and training, your Affiants are familiar with the manner in which various
crimes are committed in the Commonwealth relating to public corruption, white collar crimes, theft and fraud. Based upon the
foregoing training and experience, your Affiants have special expertise regarding the practices of, and techniques used by, these
offenders.
During the course of this investigation, witnesses have provided information that will be contained in this affidavit. Your Affiants has
specifically ascertained these witnesses’ identities. Your Affiants has verified the witness identities through positive proof of
identification. These witnesses have indicated below that they have personal knowledge regarding the criminal incident that
transpired or information that they have relayed and provided to Agents and your Affiants as more fully detailed below. Because of
the concerns for the witnesses’ personal safety, their identities are being withheld for the purpose of this affidavit to preserve the
integrity of the investigation. The witnesses will be referred to as Witness followed by a numerical indicator corresponding with that
particular witness. These witnesses will be available for any further court proceedings.
All of the information contained in this affidavit was learned directly by your affiants or related to your affiants by other agents,
police officers or investigators involved in this investigation.
II. BACKGROUND OF INVESTIGATION
On March 27, 2020, the CARES Act was signed into law, which included Title II, Subtitle A, “Relief for Workers Affected by
Coronavirus Act.” Section 2102 of the CARES Act created a temporary federal program called Pandemic Unemployment
Assistance (PUA) that in general provides up to 39 weeks of unemployment benefits and provides funding to the states for
administration of the program. The PUA program provides unemployment assistance to individuals not eligible for regular
unemployment compensation (UC) or extended benefits under state or Federal law, including those who have exhausted all rights
to such benefits. While the U.S. Department of Labor (USDOL) oversees the Pandemic Unemployment Assistance (PUA)
program, the Pennsylvania Department of Labor & Industry administers the program in Pennsylvania.
PUA is only for individuals who are unemployed due to COVID-19 reasons and does not cover individuals without an attachment to
the labor market or those who are unemployed for non-COVID-19 reasons. This benefit is only for individuals who would otherwise
be working but are unable to because of the current pandemic. According the Pennsylvania Department of Labor & Industry’s
website, the following groups are explicitly defined as being ineligible to receive PUA: Inmates; Retirees with no job and no job
Page 2 of 7
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
offer; Individuals who were not working at all or did not have a job offer; Children who were not working in actual employment;
Individuals being paid to file other people’s PUA application; College Students with no job and no job offer; Individuals on Social
Security Disability with no work attachment; Claimants who work as an employee and qualify under regular Unemployment
Compensation; Individuals living in a halfway house on lock-down; and Landlords. Additionally, the Pennsylvania Department of
Labor & Industry’s website states that “Knowingly making false statements or omitting material facts to obtain PUA benefits to
which you are not entitled will result in a disqualification and repayment of all overpaid PUA and corresponding FPUC benefits. You
may also be subject to criminal prosecution.” On June 1, 2020, The Pa. Office of Attorney General received a referral letter from
the Governor’s office referring investigation and prosecution of PUA related fraud based upon the findings of an audit conducted by
the Pa. Dept. of Labor & Industry.
III. Fraudulent Claim
ANONYMOUS E-MAIL
On July 14, 2020 an anonymous email was sent to the Office of Attorney General providing information about people assisting
others with the filing of Pandemic Unemployment Assistance (PUA). In the email the author advises that a female named Slade
(later identified as Linda Slade) has bragged about making no less than $50,000 of untaxed cash payments as a result of helping
people file their claims and then withholding login credentials. After she files the claim she refuses to relinquish the username and
password until you pay her $1,000 cash payment. The emailer identified her vehicle as a small car with a License plate #
JLV9540. This license plate is registered to Slade Janeen Slade at 1337 Preston St, Pittsburgh, PA 15205.
The Pennsylvania Office of Attorney General contacted the Pennsylvania Department of Labor and Industry to request the
application and payment information regarding Slade. Pennsylvania Department of Labor and Industry records show that Slates’
application for PUA was submitted on June 3, 2020 at 11:12:14 P.M. PA Dept. of Labor also provided (30) additional PUA claims
using the same IP address. Twenty nine (29) of these PUA claims were filed between June 3rd and June 5th 2020. An
investigative search revealed that the IP Address came back to the Double Tree Hotel in Coraopolis, PA. Supervisory Special
Agents John DiLucente and Greg Matthews subsequently attempted to interview individuals whose PUA claim was filed using the
IP address from the Double Tree hotel.
On September 9, 2020, agents interviewed Oaks at her residence located at 2540 Irwin Ave, Pittsburgh, PA 15214. During the
interview Oaks stated that she did file her unemployment compensation for herself and her husband Benjamin Oaks. Oaks was
asked where she physically filed the claims and she said right here at home on her personal laptop computer. Oaks was asked if
she filed any additional applications for anyone else and she said yes, she filed for Slade, her friend, as well. She said she filed in
the first week of June 2020. We advised Oaks that we had information that her claim was filed someplace in the Coraopolis area
and she replied, no I filed them all here at my house. Oaks was asked again if she may have filed for up to thirty individuals and
she paused and said thirty is a big number, maybe in the twenties. Oaks was asked to name the individuals she filed claims for
and she said she could not remember. SA DiLucente asked if she filed a claim for Ivy Wofford and Oaks said yes she was just
here a few weeks ago. Oaks added that everyone she filed a claim for came to her house so she could ask questions for the
application process. Oaks said she never charges a fee for filing these applications. SA DiLucente then asked Oaks if she filed
claims for Angelic Lewis, Rosalyn Burton, or Charles Hunter at which point she said no. She could not recall any other names.
OAKS was re-interviewed on September 28, 2020 in the presence of counsel. During the interview Oaks stated she had five (5)
different college degrees and her prior employment included working for the Pittsburgh public school district as a teacher. She
also worked for the Penn Hills school district. In the beginning of 2020, Oaks was working for Kelly Services fulltime when she
became sick in February 2020 related to her diverticulitis condition. Oaks heard through a friend that she may be eligible for the
PUA money. She was told Stacy Robinson is a person that can help determine if you’re eligible for PUA money and could assist
with the application process. Oaks obtained Robinson’s cell phone number, called her and left a message (Oaks provided
Robinson’s cell phone number as 412-606-7558). During this same time frame (early June 2020), Oaks said that there was a
mouse in her house and she decided to move to a hotel until her husband killed the mouse. Oaks checked into the Double Tree
hotel in Coraopolis, PA on June 2, 2020 at 7:48 pm. And her room was on either the second or third floor. She provided the hotel
receipt to investigators. Oaks said she chose this hotel because she had Hilton Hotel points and the rate was only $57 per night.
Page 3 of 7
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
Oaks said that she decided to go to the hotel because she needed to study for the Notary test and was freaked out about the
mouse at her house. The next day, June 3rd, Oaks met a few friends in Green Tree for lunch. This is when Robinson returned
Oaks call. Oaks proceeded to return to the hotel and called Robinson back to discuss the PUA money. Robinson informed Oaks
that she did qualify for the PUA money and proposed that she would walk her through the application process if she would do
some additional applications for other people on behalf of Robinson. Robinson told Oaks that she would pay her for doing the
applications and that it was legal to prepare other people’s applications for money. Oaks agreed and Robinson then gave her the
names and phone numbers of several individuals that needed their unemployment applications completed. Within ten minutes of
hanging up with Robinson, Oaks began to receive text messages from an unknown person related to the applications. Oaks
immediately called Robinson who said that was her boyfriend Keith Brown texting her and that he works with her (Robinson). After
speaking with Stacy Robinson (on June 3rd), she decided to call her friend Linda Slade and tell her that she might qualify for the
unemployment money. Slade has a business where she cleans house for a living. Slade immediately drove to the hotel to meet
with Oaks where Oaks talked Slade through the unemployment application process. Slade and Oaks both had their personal
computers while in Oaks hotel room. After Oaks and Slade completed Slade’s application, Slade returned home and Oaks began
to call people on her list provided by Stacy. When Oaks called the individuals, she explained that she received their phone
number from Stacy Robinson and that she was able to prepare there unemployment applications. Oaks said she would ask each
person questions from the application such as; what is your address, DOB, zip code, SSN, where did you work, when was the last
day you worked, etc. Oaks stayed at the Double Tree hotel from June 2nd through June 5th. The next day (June 4th), Slade
returned to the hotel with her laptop where she and Oaks worked on unemployment applications. Slade was working on her own
list while Oaks was working off the list provided by Robinson. Oaks said she did not think Slade was charging her family members
for doing their applications but was not sure if she charged non-family members. Slade does not know Stacy Robinson or Keith
Brown. Oaks said that she and Slade worked on applications throughout the day and Slade eventually returned home. Oaks
spent the night at the hotel and checked out the next day (June 5, 2020). Oaks said she eventually began to meet with Brown who
she described as 5’10” or 5’11” tall, medium build and his nickname was “killer”. His cell phone number is 412-759-4296. Oaks
said she used to meet him in the Manchester section of Pittsburgh and she recalled he may have been driving a car with New York
plates. She described the car as grey and not a newer car. He normally parked his car near the new houses located close to the
post office just off of California Avenue. Oaks would meet with Brown to pick up the money owed to her by Robinson for doing
unemployment applications. Oaks said that she estimates meeting with Brown approximately twelve (12) times. At each meeting
Brown would hand Oaks cash, sometimes the cash was inside an envelope. Oaks explained that the cash she received depended
upon the amount Robinson charged each individual for their unemployment application prepared by Oaks. If Robinson charged a
person $1,000 for the preparation of their unemployment application, Oaks would receive $600 and she understood Brown would
get $400. If Robinson charged $700, Oaks received $400 and Brown would get $300. If Robinson charged $500, Oaks received
$300 and Brown received $200. Oaks described Stacy Robinson as a black female, 5’9”, in her 40’s, single (Brown is her
boyfriend). She lives at 1502 Arch St, the corner of Arch and Jacksonia.
Oaks said that believes she prepared approximately fifty (50) unemployment applications during the time period of June 3rd
through July 25th. She believes that she prepared about twenty (20) applications while staying at the hotel and the other thirty (30)
were completed at her residence. Oaks does not know her IP address at her residence. Agent DiLucente showed Oaks a
spreadsheet containing names of individuals that applied for unemployment money using the IP address of the Double Tree hotel
during the time frame Oaks was a guest at the Double Tree. Oaks wrote a check mark next to the names that she remembered
preparing their unemployment application. The names Oaks checked were: Matthew Burton, Rosalyn Burton, Jerome Davis
(cousin), Nashead Goodwine (former student), Charles Hunter, Stephanie Johnson, Tameron Jones (former student), Angelic
Lewis, Tyrone Maddox-Washington, Julius Marbury, James McArthur (Oaks knows from South park), Frederick Mossette,
Benjamin Oaks (Oak’s husband), Terrell Page, Jennifer Simmons (Oaks has known forever), Melvin Walker, Sandra Washington,
Tyrone Washington, Vanessa Washington, Duvon Wiley (Oaks is friends with his mother), Ivy Wofford (Jerome Davis’ girlfriend). It
was pointed out to Oaks that a few of the names on the list; Melaiya Jones and Julius Marbury, had their applications prepared
using the Double Tree IP address on dates well after June 5th when Oaks checked out of the hotel. The exact dates were June
25th and July 13th for Melaiya Jones and July 12th for Julius Marbury. Oaks was at a loss of why that would be; she was
Page 4 of 7
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
adamant that she was only at the Double Tree hotel from June 2nd thru June 5th. She insisted that she did not return to the hotel
in order to prepare anymore unemployment applications.
Oaks was asked specifically about her dealings with Nashead Goodwine relative to the preparation of his unemployment
application. Although Oaks remembers Nasheed as a former student from about five years ago she got Nasheed’ s name from
Robinson relative to him wanting his unemployment application prepared. Oaks said that Nasheed never paid her, he may have
paid Stacy but she’s not sure. Oaks said that she got Angelic Lewis’ name from Robinson as well. Oaks said that she and Slade
talk every day. During the time they were preparing unemployment applications (June and July 2020) they discussed various
items on the applications they were preparing. Oaks said that Kim Powe was bringing names of people to her that wanted
unemployment applications prepared. Oaks has known Powe over the years.
Oaks said that when she received money for preparing unemployment applications it was either from Keith or directly form the
individual person. It was not until an individual received their benefits money that they would either pay Keith or Oaks directly.
Once a person paid for the application service provided by Oaks she would give them their user name so that they could re-up their
weekly applications on their own. At that point Oaks was out of the loop.
TEXT MESSAGES - During the meeting Oaks provided investigators with photocopies (12 pages) of text messages between her
and Keith Brown (aka “Killer”). Contained within the text messages between Oaks and Brown are discussing numerous things
such as: individuals, the individuals’ phone numbers, whether someone or another “Qualified”, their application is complete, they
received their money, Ms. Rosalyn needs a ride to the bank, discussing if Robinson completed some of the applications, Leona
got hers she is giving Slade the $$$ tomorrow, here is a list of those that should pay today Phillip Davis, Dennis Burton, Andrew
Boyd, Brian Jones, Sam Tuck, Elizabeth Reid, Stephanie Johnson, Phillip Burton, Cheryl Thompson, you gave me $2000 who was
that for? Phillip, Dennis or his mother in law?
Keith Brown (aka “Killer”) – Agents DiLucente, Terry Sweeney and Matthews attempted several times to contact Brown at his last
known address of 3592 Brighton Rd, Apt #7, Pittsburgh, PA with no success. On March 15, 2021 agent DiLucente called Brown’s
cell phone provided by Oaks (412-759-4296). Brown said he never filed any PUA or unemployment applications, he said Stacy
Robinson filed them. Brown said “Stacy is deceased” and was his girlfriend. Brown was asked if he knew Oaks and he said “yes,
she also filed PUA applications”. Brown was asked what his role was in the PUA application business between Robinson and
Oaks. Brown said that he was basically “watching Oak’s back”. He said he met Oaks near California Ave three or four times. He
said he would jump in the car and ride around town with her while she collected money from people for whom she filed PUA
claims. Brown admitted that he was paid at least $1,000 in cash for watching over Oaks.
Stacy Robinson – Agents DiLucente and Matthews attempted on numerous occasions throughout September and October 2020 to
interview Robinson at her address of 1502 Arch St, Pittsburgh, PA. After several attempts, agent DiLucente left his business card
in the door with a message for Robinson to call. A few days later, a female stating she was Stacy’s sister called agent
DiLucente’s cell phone and said “Stacy had recently died”. Documents provided by the Dept. of Labor show that Robinson
prepared eighty-one (81) PUA claims from the IP Address of 73.40.212.145. Agents have not yet received all of the documentation
from the PA Dept. of Labor, therefore the total amount of the (81) PUA claims is unknown at this time.
Linda Slade was interviewed on January 8, 2020. Slade said that in early June 2020 she met her friend Rochelle Oaks at a park in
Green Tree. While at the park Oaks received a telephone call from “Baldie” Goodwine and abruptly left. Later that evening Oaks
called Slade and told her about the PUA claims and that she may be eligible to file and get money. Oaks asked Slade to bring
her laptop and meet her at a hotel near Robert Morris (which is where the Double Tree hotel is located). When Slade arrived at
Oaks’ hotel room, she explained to Slade that a women she recently met, Stacy Robinson, can help you get money through the
unemployment compensation. Oaks explained to Slade how to fill out the application and what answers to submit. Oaks also
told Slade that Robinson is looking for more names of people interested in filing for Pandemic Unemployment Assistance (PUA).
Slade said she stayed at the hotel with Oaks for a few hours that night, prepared a handful of applications and then went home.
The following Sunday evening, Oaks called for Slade and several others to meet at her house. This is when Oaks told Slade that
Robinson knows someone in the unemployment office that showed her how the beat the system. Slade said that she knows
Gerry Davis (Oaks’ cousin) was sending people’s names to Oaks. Oaks explained to Slade that she needed to get her own
names to file these PUA claims. Slade said they (her and Oaks) were charging individuals between $500 (for friends) and $1,000
Page 5 of 7
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
(for others) for each application they filed. Marsha Oaks (Oak’s sister in law) was sending Oaks names as was her son Corey
Oaks, her nephew Jack Morris, her daughter Angela Hoffman, and Kim Powe. Slade said that sometime around October 2020,
Oaks called her and told her that Robinson was in the hospital, left the hospital and eventually died. Slade also knew that Oaks
was dealing with Robinson’s boyfriend, Keith (aka Killer). Slade said she prepared between forty (40) and fifty (50) PUA Claims.
Slade identified four (4) PUA claims she filed while at the Double Tree Hotel using the IP Address of 12.230.204.2. Pennsylvania
Dept. of Labor records show that Slade prepared an additional fifty-seven (57) PUA claims at her residence using the IP Address of
24.131.194.173. The total PUA claims filed by Slade is sixty-one (61) and the total of those PUA payouts total $925,273.
Agents DiLucente, Sweeney and Matthews interviewed approximately thirty (30) individuals that had their PUA applications
filed by Oaks and Slade. Although many of the witnesses did not want to cooperate, investigators did speak with several that
provided information relative to the filing of their PUA application. A handful of individuals interviewed appear to qualify for the PUA
benefits; they include Angelic Lewis (hair stylist), Tyrone Washington (jitney driver), Tameron Jones (Taco Bell), Darnell Adams
(ticket scalper), Gerald Colwell (ticket scalper), Lorenzo Towns (cut hair in the neighborhood). All of these individuals received
PUA funds and their applications were prepared by either Slade or Oaks. Another group of people interviewed Cheryl Boswell,
Rosalyn Burton, and Samuel Kyles all stated that they don’t know Slade or Oaks, never filed a PUA application and never received
any PUA money. PA Dept. of Labor records indicate that all three of these individuals received PUA benefits and their applications
were prepared by either Slade or Oaks. A third group of individuals interviewed provided information that clearly shows the
disregard for the PUA application process by both Oaks and Slade. Inell Dixon (age 75) met Slade through her friend Jennifer
Simmons. Dixon said that Simmons refers to Slade as her daughter (although they are not biologically related). Simmons gave
Slade Inell Dixon’s home phone number, Slade called Dixon and told her that “there is all this money out there and everyone is
getting it”. Dixon asked Slade if it was legal to apply for this money and Slade said “Yes, all the white people are getting it so why
shouldn’t we”. Slade asked Dixon for her SSN, address and cell phone number. Dixon was never asked about her employment
history nor was she asked if she was unemployed due to the Pandemic. Dixon told investigators that she didn’t know this money
was related to unemployment because she knew she wouldn’t qualify. Slade charged Dixon $1,000 cash to file her PUA
application and also offered to file her weekly updates to her application for an additional $100 per month. Slade did the weekly
updates for two months then stopped. Sometime in the fall, Slade contacted Dixon and told her that two white guys visited
Jennifer Simmons (same apartment complex as Dixon) and they were asking questions about PUA applications. At this time
Slade asked Dixon if she worked and Dixon said no. Slade told Dixon that if anyone asks, tell them you babysit your
grandchildren. Additional individuals; Allen Travillion (age 74 last employed 6 years ago), Pierre Brown (age 68 last employed 8
years ago), Sandra Washington (age 74 last employed several years ago), Vanessa Washington (age 65 last worked 6 years ago),
Latrese Jones (age 39 still employed and worked thru the pandemic), Jerome Davis (age 69 hasn’t worked in 25 years, disabled),
James McArthur (age 85 retired hasn’t worked in 20 years), Melvin Walker (age 59 hasn’t worked in 5 years), Diana Andrews (age
75 hasn’t worked in 11 years), Ivy Wofford (age 72, retired hasn’t worked in 25 years), and Wilford McCoy (age 64 hasn’t worked in
4 years) all provide similar testimony. They all confirmed that either Slade or Oaks prepared their PUA applications, they all
received PUA money, they haven’t’ worked in several years and were not qualified, they were not asked specific questions about
their work history and were not asked if they were unemployed due to the Pandemic. After reviewing these PUA applications it
was determined that the preparers, both Slade and\or Oaks answered the question “Are you unemployed as a direct result of a
pandemic or major disaster” with a “Yes” answer indicating that these individuals were all unemployed due to the Pandemic. Even
though they knew or should have known the employment circumstances of the individuals your affiant met with to interview on this
case.
CONCLUSION
Records received from the PA Dept. of Labor at this point show that Oaks prepared (31) PUA Applications producing
$249,227 in payments and Slade prepared (61) PUA applications producing $925,273. It is believed that Oaks prepared many
more applications that have not been documented to date. In addition, records received showed that Stacy Robinson (now
deceased) prepared (81) known applications. The details of these records have been requested but not yet received. It is clear
that $1,174,500 was paid out by the PA Dept. of Labor just for the combined (92) application prepared by Oaks and Slade. It is
estimated that the eventual total for all applications prepared by Oaks, Slade and Robinson will exceed $2 million. In addition it
Page 6 of 7
POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number
G 885185-0 OCW-20-0012
Defendant Name First: Middle: Last:
ROCHELLE OAKS
should be noted that the majority of the individuals (over 70%) whose applications were prepared in this case either had no work
history with the PA Dept. of Labor and/or did not qualify for PUA benefits. The text messages between Oaks and Keith Brown
further illustrate the efforts that were taken to facilitate this conspiracy between Oaks, Slade, Brown and Robinson. After
investigators began interviewing PUA claimants, at least one person (Inell Dixon) was contacted by Slade and instructed to lie
about their employment history if approached by anyone. Based upon the aforementioned facts contained herein, and a
combination of your Affiants’ training, education and experience, and knowledge of this investigation, your Affiants believe that
Oaks and Slade committed the following PA Crimes Code violations as listed: PACC 911(B3) Corrupt Organization, PACC
911(B4) Corrupt Organization, PACC 903(A1) Conspiracy, PACC 3921(A) Theft by Unlawful Taking, PACC 3922(A1) Theft by
Deception, grading a Felony of third degree due to a disaster (Pandemic) and PACC 4911 (A1) Tampering with Public Records or
Information.
I, JOHN DILUCENTE , BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY
THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY
KNOWLEDGE, INFORMATION AND BELIEF.
I CERTIFY THAT THIS FILING COMPLIES WITH THE PROVISIONS OF THE CASE RECORDS PUBLIC ACCESS
POLICY OF THE UNIFIED JUDICIAL SYSTEM OF PENNSYLVANIA THAT REQUIRE FILING CONFIDENTIAL
INFORMATION AND DOCUMENTS DIFFERENTLY THAN NON-CONFIDENTIAL INFORMATION AND DOCUMENTS.
/JOHN DILUCENTE/
(Signature of Affiant)
Sworn to me and subscribed before me this day of , .
Date , Magisterial District Judge
My commission expires first Monday of January,
SEAL
Page 7 of 7
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