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Police Criminal Complaint, Commonwealth of Pennsylvania: Robert Palmer (Dauphin County)

Summary

A police criminal complaint against Robert Palmer, an inmate at SCI Huntingdon, filed in Dauphin County, Pennsylvania, with Hon. Sonya M. McKnight as the magisterial district judge. It lists offenses under the Pennsylvania Crimes Code, including corrupt organizations, criminal conspiracy and theft by unlawful taking. In the affidavit of probable cause, SA Chris Weaver and SA Katie Grady state that Palmer sent Elise J. Ballard the names, dates of birth and Social Security numbers of 20 inmates through prison messages, and that Pandemic Unemployment Assistance (PUA) applications in those names drew $148,247.00. They state that a PUA application in Palmer’s name was submitted while Palmer was incarcerated and paid $15,660.00, that Ballard put $2205.00 on Palmer’s JPay account, and that the PUA funds linked to Palmer totaled $163,907.00.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

  COMMONWEALTH OF PENNSYLVANIA
  COUNTY OF:DAUPIIIN
                                                                                      A&A                        POLICE CRIMINAL COMPLAINT
                                                                                                                 coMMoNWEALtirS: PENNSYLVANTA
  Magisterial District Number: L2-2-04
  MDJ: Hon. Sonya M. McKnight
                                                                                   ffi
                                                                                  DEFENDANT:                                            WAME and ADDRESS/:
  Address: 1805 North Cameron St.                                                 ROBERT                                                         PALMER
              Harrisburg, PA L7L03                                                riritvame                                 miaatewame W                                                  Ge
                                                                                                                                                                                          n
                                                                                  SCI HUNTINGDON, 1100--r
                                                                                                        Pile Street
  relephone : (7 L7)233-3599                                                      HUNTINDON, PA 16654
                                                                              NCIC Extradition Code Tvoe
  lxl 1-Fetony Fufl                               lJ S-Felony Pending Extradition                E C-Misdemeanor Surrounding States
  [ 2-Felony Limited                                                                                                                                          E Distance:_
                                                  E 6-Felony Pending Extradition Determ.                E O-tvtisOemeanor No Extradition
  E 3-Felony Surrounding States                   E R-tvtisOemeanor Full                                I e-UisOemeanor Pending Extradition
  fl +-Felony No Extradition                      E g-tvtisOemeanor Limited                             E f-UisOemeanor Pending Extradition

                                                                                                                                                              Request Lab
  'd]!"iE'et                                 Date Filed
                                             t fioetpoe f{ t0a?3€-o
                                                                      Offl/LiveScan Number                        ComplainUlncident Number
                                                                                                                    occ-20-0075
                                                                                                                                                             Services?
                                                                                                                                                                E ves EX No
  GENDER                ooe LAl29lL99L                           Pa                                              Add't   DoB I I                             Co-Defendant(s) tr
  Ex vtate                        First Name                                              Middle Name                                  Last Name                                   Gen.

  E Female              AKA

  RACE                  E wnite                             Asian                                   { Black                           Native American           Unknown
  EI   HNIGITY LI Hispanic               ffi Non-Hispanic                                           tr unknown
          E cpy (Gray) E nEo (Red/Aubn.)         E soY (sandy)                                      I alU 1slue1 E plE (purpte)                              E eno (Brown)
 |il,         EI elr (Btack) E oNc (oranse)                            E wnt(white)                 f]xxx (Unk./Batd) E cnr,l (Green)                        D pttx (pint<)
              E elf{ (Btonde / Strawberry)
 Eye          E elx (Btack)                     E eLu (etue)   EI ano (Brown)                              E enru (Green)                               flGnv lcrayy
 Color        E rnz (Hazet)                     E unn (Maroon) fl erux leinr;                              fl tvtut- (Mutticotored)                     E xxx (Unknown)
 DNA                           tr YES n                                                                                                                        I werenr (ros.y
 FBI Number                                                           MNU Number
                                                                                                                                                                 180
 Defendant Fingerprinted I            tr veS EX NO                                                                                                               Ft. HEIGHT ln.
 Fingerprint Classification :
                                                                                                                                                                5             11
                                                                       DEFENDANT VEHICLE INFORMATION
                                     State      Haz                   Registration              I    Comm,lVeh.              SchoolVeh. I Oth. NCIC Veh. Code
 Plate #                                        mat
                                                 u           sticker (MM/YY)          I         I       tnd. tr                       trl               -
                                                                                                                                                                               same
                                                                                                                                                                                   Reg.

                                                                                                                                                                              as Def.
 VIN                                                      Year         Make                           Mode!                               Style              Color                 tr
 Office of the attorney for the Commonwealth                          E Approved tr Disapproved because:

 to filing. See Pa.R.Crim.P. 507).

 HEATHER A. CASTELLINO, SDAG
                                                                                                                                                                / lrsl zaz/
                                                                                                                                                                          (Date)


                      WEA
       (Name of the Affiant)
                                                 TIE                                                              E#
                                                                                                              (PSP/MPOETC -Assigned Affiant lD Number & Badge #

            Pennsvlvania                                                                                         PAA2Z2400
    (ldentify Department or Agency Represented and potitiCat suoovision)                                      (Police Agency ORI Number)
    do hereby state: (check appropriate box)
     [l I accuse the above named defendant who lives at the address set forth above
     E I accuse the defendant whose name is unknown to me but who is described as

        E I accuse the defendant whose name and popular designation or nickname are unknown to me and whom I have
      therefore desionated as John Doe or Jane Doe
      with violating the penal laws of the Commonwealth of Pennsylvania at                                     [301]
                                                                                              pA DeDt Of Labor And Industrv,
 651 Boas St, Harrisburg,           Pa                                     (su-6-divmT-c5ilej) (PEd?6tiliEaT$iEdivEi6n-i--

          in DAUPHIN County                          t22)                        on or about JUryE_4.?020 TO SEPTEMBER 1, 2020
                                                      O*tV CoO"l

AOPC 4t.2A- Rev. TlLS                                                                                                                                                     Page     tor l3
  Docket Number:                          Date Filed:                       OTN/LiveScan Number
                                                                                                       ffi poltcE cRTMINAL coMpLAtNT
  U-ll-lt                            First:
                                              /t
                                                                                Middle:
                                                                                                                               GomptainUlncident Number
                                                                                                                               occ-20 -0025
  Defendant Name:                                                                                                      Last:
                                     ROBERT                                                                            PALMER


  The acts committed bV the ai
  when there is more than one offense, each offense should be numbered chronololically.
  (set forth a btietsummary ot the factg suffcloirt to adviso the defendad of rho           ;;t;;t".r"it*f"i"rr"ri';l. A citadon to the statuto(s) a egedty viotated,
  without morE, is not sutficlent ln a summary casq you-must cttethe Bpeclflc sociion(s) ano suuseciJniij oi itre
                                                                                                                                  or oroln"nce(s) aflegedty vtotated.
  The ago of the victh at tho time ot the offonse may bo lncluded lf known,lr addition,3;cht E!"urtty nrinl"o ina"t"tut"(il
                                                                                                                         nnaniiil inrormation 1e.g, ptNs) Bhoutd not
  bo listed. lftho identity ofar account must be ostablish6d, list onlythe tast tour digits. 2oil elcoa6 gj zii,f
                                                                                                                               --is.if---'
                  E Attempt                    E Solicitation I conspiracy                                              Number of Victims Age 60 or Older
                         18901 A                   18902      A              18903

    tr        1
              offense
                          911                      b3               WArrrLE tB                         1                F1
  Lead?                         section                Subsection                 PA Statute (Title)                                 NGIC Offense
                                                                                                                                            Code      UCR/NIBRS Code



  StatuteDescription(inc!udethenameofsIoNs
 Acts of the accused associated witfr
                                                             of Dauphin, Huntinsdon, cambria, Enn#vjnia airo ersewtrer", .onou.i or pu'ti.ipate, direcry or indirecuy
 :0.'zL.:Ls:1"19-".1""1-Trj,-1l}'l-T_"-9!ntie:
 in the conduct of such enterprise's affaiB-through a pattem   of racketeenng activity, that is,-ouring ttre periooiii sei iortt ner"in. Defendant was associated
 with an enterprise constituting a group of individuals associated in fact, attiough ;6t a tegil entiti, eng:aged in
                                                                                                                     iommeice ano mnsisting of Elise J. Ballard, and-
 othgr:' anq
             ryleldalt did mnduct or participate. directy or indirectly, in the c6nduct of tie ar"i.i or ini"nt"rprise ir'iorin u p.tt", ir r"creteerin! actl,ity
 as defined ln 18 Pa.C.S. 5911(h) consisting of (See Continuation of Oifenses)




                                               fl Solicitation E Gonspiracy                                            Number of Victims Age 60 or Older
                                                  18 902 A       18 903


          2
          Offense#
                          911                      b   4            ffiflffi#f, rrrir rs               1               F1
                                                                                                                                     NCtC
                                                   Subsection                    PA Statute (Title)                                                  UCR/NIBRS Code



 StatuteDescription(includethenameofstatuIoNs
 Acts of the accused associated w
 Dauphin,,Huntngdon, Cambria, Pennsrvania and elsewhere, consplred to violate the provisions of section 9u(b)1:)
                                                                                                                          or tne crires coa", ra ea.c.s.
 5911(bX3), pertaining to corrupt organizations, that is, during thi periods as set forth h;;r, b"e.aj,ii, *itt''trG-;,nieni or promoting or racititating the
 commiscion of the crime of conupt organizations, did conspire and agree with other indiviaua'ts, that thei; oi
                                                                                                                   oni oi mor. oi trer, ,-rrite employedby or
 associated with the enterprise set forth herein, would coMuct or participate, direcdy or inairectty, in tire i6naua
                                                                                                                     or ttreifairs ot uje enterprise tirroujtr a
 pattern of racketeering activitv as defined in 18 Pa.c.s.
                                                           5911(h), in violatiorlof section 911(bX4) of the crimes coae, ie pa.c.s. Sgr(t)(i).



                     EI Attempt                E soticitation            I Conspiracy                  j   r,f   umUer of Victims Age 60 or Otder
                          18901 A                  18 902 A                 18 903

   tr         3            392L                    a                                                   1                F2
                     #                )n               Subsection

                                                            E lnterstate | tr Safety Zone I                                                            n Work Zone
          Description(includethenameofstatuteorordinance;'rtterravuNLAWFULTAKINm

Acts of the accused associated with tfris Otf
         d:fly:,!iT.*:TJ'-1"-P*19:lt
[Tj]                                           l",TTitted
property, hardship, suffering or possible loss of life.
                                                          the offense durins a Natural Disaser invotving a catastopne wtricrr reiuni in iuostanuui d;;s; to




AOPC 4I,2A - Rev. 7lL8
                                                                                                                                                            PageZ of lJ
  Docket Number:                       Date Filed:                       OTN/LiveScan Number
                                                                                                      ffi poltcE cRtMtNAL coMpLAtNT
                                                                                                                               GomplainUlncident Num ber
   blt-71                            First:
                                            lt                                                                                 occ-20-0025
                                                                            Middle:                                    Last:
                                     ROBERT                                                                            PALMER




    tr        4           | zszt                 a                                                        1              F2
                                                                                             rifle)           counts       irade          NCIC Offense Code            I ICR/NIFIR.Q Carta
        PennDOT Data
         (if applicable)                                                                          ! lnterstate I                      tr Safety Zone I                 I W.ork Zone
  StatuteDescription(includethenameofstatu

 Acts of the accused associated with this Offe
 Theft By unlawful Taking or Disposition, fitle 18 section 3921(a), did agree with one or more other persons lhat they or
                                                                                                                          one or more of them would engage in
 conduct whidl constitrtes a crime or did agree to aid suci othdiperson or persons in the ptanninq oi commi;on
 to mmmit such crime, that      it
                                                                                                                                      ;iffi
                                                                                                                            crime or of an attempt or solicitalon
                                  between June of 2020 and september of 20i0, within fte Ciunties-of oauptrir, ttuniinloon, camuria, eennsytvania and
 elsevvhere, Defendant did agree with other individuals that they, or one or more of them, woutd
                                                                                                 engage in conductco;*tutinq the crime oi theft by unlawful
 taking in^violation of Title 18, and in pursuance of such mnspiiacy one or more overt acts were co;;ifted, in violation
                                                                                                                         of section 903 of the crimei code, ta
 Pa-C.S. 6903.




    tr          5             3922               a3                                                       1               F3
                                 Section             Subsection                                                                ar{a           NCIC l1ffanca   llada    I lrlD/I\ttoErc


                                                                                         |
                                                                                         I        tr lnterstate                       E Safety zone I                  I Work Zone
 StatuteDescription(includethenameorstitute@EFTBYDEcEPrIoN

 Acts of the accused associated with this Offense: m
 deceives if he/she intentionally fails to conect a false impression vrhich the deceiver previously created or reinforced,
                                                                                                                           oi whictr the deceiver knows to be
 influencing another to whom he stands in a fiduciary or confidential relationship.




   tr       6             3922                   a3               oi,ihil,-'l TITLE 18                1                 F3
 Lead?
                    Fei,-.,,,,,, q     .

                                                                                                E tnterstate I                    I Safety Zone I                     I work Zone


Acts of the accused associated with tfris
I-"I-BL^TSfUy,
constitutes             I!:  1& 91ctol ?92lax3),
                                                     did asree with one or more other persons that they or one ir more of them woutd engase in conduct which
              a crime or did agree to aid such other person or persons in the planning or commission of such crime or of an attempt or soiic-itation
                                                                                                                                                     to commit
       crime, that iE between June of 2020 and september of 2020, within tie cou;ties of Dauphin, Huntingdon, cambrii,
!uc-h                                                                                                                       iennsytvania and etsewhere,
Defendant did agree with other indMduals that they, or one or more of them, would engage in co,iaua                    ioistitrift.ii"irire
                                                                                                                                oittret uy aeceptjon, inviolation
of litle 18, and in pursuance of such conspiracy one or more overt acts were'committed-, ii violation of Seaion 90j oi ttre crimes cooe,'lg pa:c.s. '5903.




AOPC 4L2A - Rev. TlLg
                                                                                                                                                                          RaseS ofL7
   Docket Number:                   Date Filed:                     OTN/LiveScan Number
                                                                                                 ffi poLrcE cRtMtNAL coMpLAtNT
                                                                                                                       Gom plainUlncident Number
   u-ll-11                       First:
                                          /t                                                                           occ-20-0025
                                                                        Middle:                               Last:
                                 ROBERT                                                                       PALMER




    u        7        | sszs                   a                                                  1             F3
                !E!___-_=*!9I-__ Subsection                               pA sbMa 0,i

                                                                                             fl lnterstate I                  n Safety Zone I           n Work Zone
  StatuteDescription(includethenameofstatuRoPERTY
  Acts of the accused associated with this O
  knowing that it had been stolen or believing that it has pmbably been sblen, unless the property is received, retained,
                                                                                                                                 or disposed with intent to restore it to




    n        B         | 7sL2                  a                                                  1             F3
                             Section               Subsection                                                         irade      NCIC Offanse Cada       I l(]P/NlRElq


                                                                                    |         tr lnterstate                   E Safety zone I           n work Zone
 Statute Description lincluO                                                        MrNAL usE oF A


 ActSoftheaccuSedassociatedwiththisoffense:Intt,utu,eaoo,e,*,eddefendantdid,ono,affi
 communicafon fucility to commit, cause or.facilitate the commission or the attempt thereof of any crime under this tide or under the pA
                                                                                                                                         Controlled Subsbnce,
 Drug, Device and Cosmetic Act 64-L972, all of which is in violation of the Tiue 1g pA CS
                                                                                          57512.




                                                                                   Iitle)        Counts          )rade NCIC Offens Codr                 UCR/NIBRS Code

                                                                                            EI lnterstate            E Safety Zone                     E Work Zone
 statute Description (include the name of statute or oroinane,el

ACrs oT rne accuseo assoctated wtth this offense




AOPC 4t2A - Rev. Tltg                                                                                                                                      Puge    4 or l-J
                                                               e polrcE cRTMTNAL coMpLArNT
                                                                              OFFENSE CONTINUATION PAGE
 Docket Number:          Date Filed:
 b-/l-At                   tt
                                                                                   ComplainUl ncident Num ber
                                                                                   occ-20-002s
                       First:                      Middle:                 Last:
                       ROBERT                                              PALMER


                                OFFENSE DESCRIPTION CONTINUATION

 Offense # 1:

 A.     Multiple acts of Criminal Conspiracy to commit violations of the Chapter 39 of the Pennsylvania Crimes
 Code, 18 Pa.C.S.A. 9903,

 A.       Multiple acB of violation of the Chapter 49 of the Pennsylvania Crimes Code, including 18 pa. C.S. A.
 s4911,

 B.     Multiple acts of violation of Chapter 39 of the Pennsylvania Crimes Code, including 18 pa. C.S.A. g 3921
 and 18 Pa. C.S.A. g 3922;

 in violation of Section 911(bX3) of the Crimes Code, 18 pa.C.S. 9911(b)(3).




AOPC 4t2A- Rev. OT ILS                                                                                   Page   I ot L7
                                                                                             POLICE CRIMINAL COMPLAINT
  Docket Number:              Date Filed:                  OTN/LiveScan Number                       GomplainUlncident Number
  b-ll*Al                   First:
                                     tt                                                              occ-20-0a25
                                                             Middle:                         Last:
                            ROBERT                                                           PALMER

     2. I ask that a warrant of anest 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
                                                                                                                              S
       to unsworn fulsification to authorities.

    4. This complaint conslsts of the preceding page(s) numbered 1 through             lf.
    5. I certify that this filing complies with the provisions of the case Reco rds Pubtic Access poticy of the unified Judicial
       System of Pennsylvanla that require flling confidential information and documents differenflyihat non-confidential
      Information and documents.

    The acts committed by the accused, as l;sted 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 violatio; of the statuies iiteO.
    (Before a warrant of arrest can be issued, an affidavit of pr6bable cause must be completed, sworn to
                                                                                                          before the
    issuing authority, and attached.)



    (Date)                                        (Year)

    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.




AOPC 4tZA- Rev. TlLS                                                                                                               e,age   Q of l)
                                                                     #     poLtcE cRIMINAL coMpLAlNT
    'ff')/:fi              Date Filed:

                        First:
                               tt
                                                 OTN/LiveScan Number                 ComplainUlncident Number
                                                                                     occ-20-aa25
                                                    Middle:                  Last:
                        ROBERT                                               PALMER



                                         AFFIDAVIT of PROBABLE CAUSE
    OnMarch 27,2020,lhe CARES Act was signed inlo law, which included Title II, Subrtifle 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 unernployment benefits
   and provides fimding to the states for administration of the program. The PUA program provides unemployment
   assistance to individuals not eligible for regular unemplolment compensation (UC)        u 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 UnemploS'rnent Assistance (pUA) prograrn, tle pennsylvania DeparEnent
   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 indMduals
   without an attachment to the labor market or those who are memployed 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 to the Pennsylvania Departrnent of Labor & krdustry's website, the following goups are expticifly
   defined as being ineligible to receive PUA: lnmates; Retirees with no job and no job 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 witlr no work attachment; Claimants who work as an employee and qualifu under
  regular Unemployment Compensation; Individuals living in a halfiray 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 entifled will result in a
  disqualification and repayment of all overpaid PUA benefits. You may also be subject to crimina.l
  prosecution." On June 1,2020, The Pa. Office of Attomey General received a referral letter from the Governor,s
  ofEce referring investigation and prosecution ofPUA related fraud based upon the findings ofan audit conducted
  by the Pa. Dept. oflabor & Industry.


  In June of 2020 the Deparknent of Correction identified possible PUA fraud involving inmates at SCI Rockview
  and other state correctional institutions. The Department of Corrections identified Elise J. Ballard through prison
  inmate messages as possibly being part of the PUA fraud. The Department of Corrections identified messages
  between SCI Rockview inmate John Jones and Elise Ballard where 10 inmate names, DOB's, and SSN,s were
  being provided.


AOPC 411C - Rev. 07 l1^g                                                                                        Pas+of   p
  Docket Number:
                                                                     & polrcE cRTMTNAL coMpLArNT
  b-//-Il                  Date Filed:

                         First:
                                lt
                                                 OTN/LiveScan Number

                                                    Middle:                  Last:
                                                                                     ComplainUlncident Number
                                                                                     occ-20-0025
                         ROBERT                                              PALMER



 The Deparhnent of Conections identified that Elise Ballard was also connected through prison messages and
 prison account payments with SCI Huntingdon inmate Robert E. palmer.


 Your aJfiant was aware of a pattem of recent fraud scheme from previous PUA fraud investigations that inmates
 were contacting individuals outside of ttre prison using the State Correctional Institution communication system
and providing them with names, DOB's, and SSN's of inmates and having the person on the outside file for pUA.

 Since the inrnates were incarcerated, the person on the outside needed to complete the PUA application and also
have an address for the PUA funds to be sent. Affiant also leamed from previous investigations involving pUA
fraud, that the pa1'rnents would be sent to the imate at the address provided on the application in the form of a US
Bank Debit card and on some occasion's actual checks from the PA Treasury. Once the PUA funds were received
money would be placed on the fumate's prison financial account "JPay'' by the person receiving the funds and the
person who submitted the application if different from the person who received the funds would receive a
payment. JPay is the name of the intemal prison money transfer service to deposit money on inmate's commissary
or trust account.


On 8127120, Affiant traveled to Johnstown, PA and made contact with Elise Ballard at her residence 718 Linden
Avenue, Johnstown, PA.


Ballard was home and agreed to talk in her living room. Ballard was advised that she was being contacted
regarding inmates obtaining unemployment and asked if she was in possession of any unemployment debit cards.
Ballard stated that she did have debit cards and was involved in filing for PUA unemploynent for inmates. During
this conversation Ballard was sitting at a desk with a functioning desktop computer. Ballard reached into the desk
drawer and handed your Affiant a US Bank Debit card in tle name of Albert Williams, an inmate at SCI
Huntingdon. Ballard stated that she had received approximately five, US Bank Debit cards at her address and used
them all and either threw them away or misplaced them. Ballard agreed to go to the Johnstown Police Department
to sit down and discuss her role in the PUA unemployment fraud. Ballmd drove herself to the Johnstown police
Department to be interviewed.



AOPC 4L2A- Rev. TlLg                                                                                            easefl af$
  Docket Number:
                                                                       & polrcE cRTMTNAL coMpLArNT
   b-il-ar                  Date Filed:

                          First:
                                   tt
                                                     OTN/LiveScan Number

                                                        Middle:              Last:
                                                                                     ComplainUlncident Number
                                                                                     occ-20-0025
                          ROBERT                                             PALMER

 Elise Ballard was read her Miranda wamings and agreed to answer questions and make a statement. The interview
 was also recorded. Ballard stated that she had a boyfriend, two brottrers, and several good ftiends in state
 conectional facilities. Ballard stated that Robert Palmer is her boyfriend arid is in SCI Huntingdon; John Jones is
 her best friend in SCI Rockview Ballard stated that she had been asked by Palmer and Jones to file unemployment

 applications for them. Ballard stated that she understood that frling the applications was not allowed and was
 fraud. Ballard stated that she thought the pandemic @UA) money was available to anyone who applied and
 considered it like stimulus money that everyone could get. Ballard stated that she filled out numerous applications
for numerous inmates aad could not recall how many applications she completed. Ballard could not recall how
much money she received from the debit cards. Ballard stated that she put most of the money on inmate accolrnts
through the prison JPay accounts and sent larger amounts to inmates through MoneyGram. Ballard was shown her
communications with inmates and admitted that she had exchanged the messages and information for other
inmates during conversations with inmates. Ballard stated that she only had five of the debit cards mailed to her
address in inmate names and the rest of the applications she completed were sent to each inmate,s residence.
Ballard stated that she did not receive any payment from the other inmates for filling out the applications. Ballard
was questioned about the other inmate's names and stated several times that she could not recall the numbers and
amounts involved with the debit cards. Ballard stated that there were "too many to remember,,. Ballard reported
that she lived alone at the 718 Linden Avenue address. Ballmd reported that her home intemet was through
Atlantic Broadband and that the account was in her name or in Robert palmer's name.


Your Affiant's reviewed the Depaxhnent of Corrections inmate financial JPay accounts for inmates John Jones and
Robert Palmer. Elise Ballard was listed on the JPay accounts as putting $3680.00 on John Jones and $2205.00 on
Robert Palmer's imate accounts in June, July and August of 2020. The deposits into the inmate accotmts
coincided with the PUA payments placed on the debit cards for those inmates. The JPay system identifies the
name and the IP of the person making the deposit and the IP associated with the majority of the deposits made
                                                                                                                       by
Elise Ballard came from IP address I 3 8 .207 .247 .124 .


Upon reviewing prison messages between Elise Ballard and her boyfriend Robert Palmei, an additional 20 names
with DOB and SSN's were found" It was determined that inmate Robert Palmer provided 20 inmate names along



AOPC 4t2A- Rev. TltB                                                                                            ease   $ of I
                                                                     # polrcE cRTMTNAL coMpLArNT
                                                                                     Com plainUlncident Number
                                                                                     acc-20-0025
                                                                             Last:
                                                                             PALMER

 with DOB's, and SSN's to Elise Ballard through prison messages. The 20 names provided by palmer to Ballard
 coincide with completed PUA applications submitted by Baltard.


 Your AfEant's requested additional information from the PA Departrnent of Labor and Industry, specific to Elise
 Ballard. Labor and Indusay was able to search for the names ofthe inmates associated with Ballard, applications
 completed with similar IP addresses associated with Ballard, and for addresses associated with Ballard. The
 Deparknent of Labor and Industry found 42 names associated with the search criteria related to Elise Ballard;
                                                                                                                       3l
 of the PUA applications were completed using IP address I 3 8 .207 .247 .124 . Your AfErant conducted
                                                                                                         a search and
 determined that IP address 138.207.247.124 is owned by Atlantic Broadband. A search of Atlantic
                                                                                                           Broadband
records determined that IP address 138.207.247.124 belonged to subscriber Robert palner at 7lg Linden
                                                                                                                 Avenue,
Johnstown, PA.


As a result of the search by the Departrnent of Labor and Industry, the names provided by inmates John Jones
                                                                                                                     and
Robert Palmer, were identified as having PUA applications completed. Additional names who had pUA
applications completed were found associated with Elise Ballard. The total for all the PUA applications
                                                                                                           completed
by Elise Ballard was 31 applications. Robe( Palmer provided 20 of the names and those 20 names totaled
$148,247.00 in PUA firnds issued. John Jones provided 10 of the names and ttrose l0 names totaled $66,915.00 in
PUA funds issued' Not all applications that were submitted by Ballard were approved for pUA payments. One
name SCI Huntingdon inmate Albert Williams could not be determined how Ballard received it. Albert
                                                                                                Williams
was the name on tle debit card in the possession of Elise Ballard on 8127120. Checks with SCI Huntingdon
determined that Albert Williams was the cellmate of Robert Palmer at SCI Huntingdon from April of 2020
                                                                                                                    until
September of 2020. Albert Williams received $10,920.00 in PUA funds. The total for all the pUA
                                                                                                     funds associated
with the 31 PUA applications completed by Ballard was 5226,082.00.


The Peffrsylvania Oflice of Attorney Geneml contacted the Perursylvania Departrnent of Labor and
                                                                                                        Industry and
requested the application and payment information regarding Robert E. Palmer ancl John R. Jones pUA
                                                                                                          claims.


The Pennsylvania Department of Labor and Industry records show that Robert Palmer had an application
                                                                                                            for pUA
submitted on Jrure 11, 2020. On the application it was reported that Palmer's last day of employnent was

iropc +rzl - n ev.7llr                                                                                           nselool3
   Docket Number:
                                                                      & poLrcE cRTMTNAL coMpLArNT
  b-//-2/                   Date Filed:

                          First:
                                 lt
                                                   OTN/LiveScan Number

                                                      Middle:                  Last:
                                                                                       ComplainUlncident Number
                                                                                       oce-20-on)6
                          ROBERT                                              PALI4ER

  12/112019. Your Affiant notes tlat Palmel s73s incarcerated on the date his application
                                                                                                        was submitted.
 Additionally, records show that Palmer's application was submitted by an individual using the address
                                                                                                             71g Linden
 Ave, Johnstown, PA' Pennsylvania State Correctiona.l Institution records show that Robert palmer has
                                                                                                                      been
 incarcerated in SCI Huntingdon from I 1/1/16 thru present.


 The Pennsylvania Deparhnent oflabor and Industry also provided information regarding pUA payments
                                                                                                                  made to
 Robert E. Palmer. Records show that Palmer received payments on 6/12120 (check), 6117120 (debit
                                                                                                           card), 6120120
 (debit card), 6/23/20 (debit cad), 6129120 (debit card), 719120 (debit card), and 7 /t5120 (debitcard).
                                                                                                           The total for
 all the payrnents was $15,660.00. The payments were tom tie last day of work Iisted on palmer,s
                                                                                                          application to
 present' These payments directly coincide with the time tlat Palmer was incarcerated
                                                                                              at SCI Huntingdon. The
 PUA payments were made using check and a US Bank pre-paid debit card with the last four numbers
                                                                                                              0310. The
Purnsylvania Department of Labor and Industry records show that Palmer's pUA US Bank debit
                                                                                                       card was mailed
to the Linden Ave, Johnstown, PA address.


The SCI Huntingdon inmate money account "JPay" showed that Palmer received money on his
                                                                                                    account from Elise
Ballard on 6113120, 6116120,6/19/20, 6/23/20, 6127/20,7121120,7t30/20,8/3t20,           arrtd, 8t3t/20. The total amount

deposited, on Robert Palmerts JPay account by Elise Ballard was $2205.00.


The total amount of PUA funds that were associated with the 20 names Robert Palmer provided
                                                                                                       Ballard through
the state correctional Institution communication system and the puA funds he received was
                                                                                                 $163,907.00.


The Pennsylvania Department of Labor and Industry records show tiat John R. Jones had an application
                                                                                                                for pUA
submitted on June 12, 2020' On the application it was reported that Jones last day of employrnent
                                                                                                      was l2/29/2OIg.
Your A{Iiant notes t}at Jones was incarcerated on the date his application was submitted. Additionally,
                                                                                                                  records
show that Jones application was submitted by an indivitlual using the address 718 Linden Ave, Johnstown, pA.
Pennsylvania State Correctional Institution records show that John R. Jones has been incarcerated
                                                                                                                  in SCI
Rockview from 2 17 I 17 thru present.




AOPC ALZA - Rev. I ILS
                                                                                                                  PaeelJ ofA
  Docket Number:           Date Filed:            OTN/LiveScan Number
                                                                      & poLrcE cRTMTNAL coMpLArNT
  u-l/-Al                First:
                                  lt
                                                     Middle:                  Last:
                                                                                      ComplainUlncident Number
                                                                                      occ-20-0025
                         ROBERT                                               PALMER

 The Pennsylvania Department of Labor and Industry also provided information regarding the payrnents made to
 Jones. Records show that Jones received payments on 6113/20 (check),6t23/20 (debit card), 6129/20 (debit card),

 and 7 /15/20 (debit card). The total for all the payments was $21,630.00. The payrnents were from the last day of

 work listed on Jones application to present. These payrnents direcfly coincide with the time that Jones was
 incarcerated at SCI Rockview. The PUA payrnents were made using check and a US Bank pre-paid debit card with
 the last four numb erc 1629. The Pennsylvania Deparftnent of Labor and Industry records show that Palmer,s pUA
US Bank debit card was mailed to the 718 Linden Ave, Johnstown, pA address.


The SCI Rockview inmate money account "JPay" showed that Palmer received money on his account from Elise
Ballard on 6123120, 6126120, 6127/20, 717120, and 7125/20. The total amount deposited, on Robert Palmer's Jpay
account by Elise Ballard was $3680.00.



The total amount of PUA funds that were associated with the 10 names John Jones provided Ballard through the
State Correctional Institution communication system and the PUA funds he received was $88,545.00.



On 11117/20, your Affrants traveled to Johnstown, PA and conducted a second interview of Elise Ballard at 718
Linden Ave., Johnstown, PA.


Ballard was read her Miranda wamings and agreed to answer questions and make a statement. The interview was
also reeorded.



Ballard was questioned about the additionat names and applications reported by tlle Department of Labor and
Industry. Ballard admitted to completing all the applications from the list of 3 I PUA applications. Ballard stated
that she personally received 24 of the PUA US Bank debit cards that were sent to Johnstown addresses. Ballard
stated that she used her address and friends addresses in Johnstown to get the debit cards. Ba.llard stated that the

debit cards mailed to other cities were sent to the individual inmate's families and she had no firther involvement.
Ballard was asked what she did with all the debit cards she received. Ballard stated that once she received a debit
card she would withdraw the money and transfer the money to inmate prison accounts. Ballard stated that she
disposed of several of the debit cards and some still had balances on the cards. Ballard stated that she knew what

AOPC 4tZA- Rev. TlLS                                                                                             PageiZot Q
                                                                            POLICE CRIMINAL GOMPLAINT
  Docket Number:            Date Filed:               OTN/LiveScan Number                   ComplainUlncident Number
  Cr- yh el                        /t                                                       occ-20-0025
                          First:                        Middle:              Last:
                          ROBERT                                             PALMER

 she was doing was wrong and regretted completing the applications. Ballard stated that she was ,Just trying to help

 people out".




l, sA cHRIs WEAVER/SA KATIE GRADY, BEING DULY swoRN AccoRDtNG To THE LAw, DEpoSE AND
                                                                                     sAy
THAT THE FAcrs sET FoRTH tN THE FoREGoTNG AFFtDAvtr ARE TRue lruo conRecf ro me BEsr
                                                                                     oF My
KNOI'VLEDGE, INFORMATION AND BELIEF.

I CERTIFY THAT THIS FILING COMPLIES WTH THE PROVISIONS OF THE CASE RECORDS PUBLIC
                                                                                     ACCESS
POLICY OF THE UNIFIED JUDICIAL SYSTEi' OF PEA'A'SYLVANIA THAT REQUIRE FILING CONFIDENTIAL
INFORMATION AND DOCUMENTS DIFFERENTLY THAT NON.CONFIDENTIAL INFORMATION AND DOCUMENTS.




Sworn to me and subscribed before me this

                   Date                                                                           District Judge
                                                                                                 ..ttr,
                                                                                                 r!srii
My commission expires first Monda         January,I                                    ,i
                                                                               r','.




AOPC 4t,2A- Rev. Tltg
                                                                                                                       Page   E of -13


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