Police Criminal Complaint: Commonwealth of Pennsylvania v. Tyreese Lewis (Dauphin County)

Summary

This Pennsylvania police criminal complaint, sworn by affiant Kathryn Grady, charges Tyreese Lewis with corrupt organizations, theft by unlawful taking, theft by deception, access device fraud and identity theft. It alleges that during the COVID-19 State of Emergency, Lewis filed fraudulent applications for the Pandemic Unemployment Assistance benefit program through the PA Department of Labor and Industry website for himself and others, knowing that he was not qualified to do so. The complaint says the fraudulent applications resulted in benefit payments of approximately $147,250. The affidavit says a Dauphin County probation officer who supervised Lewis and monitored his Facebook and Instagram accounts reported that Lewis appeared to be recruiting people for the filings. It asks for arrest warrants for Tyreese Lewis, Dorien Ervin and Kymaury Goldsby.

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ti POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTN/LiveScan Number Complaintincigent Number. :
Middle: Last:
LEE LEWIS

Fhe 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‘citatlon to the statute(s) allegedly violated,
without more, is not sufficlent. in a summary case, you must cite the specific section(s) and subsectlon(s) of the statute(s) or ordlnance(s) allegediy violated.
The age of the victim at the fime of the offense may be included if known, 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.)

:| (J Attempt 1 Solicitation [1 Conspiracy Number of Victims Age 60 or Older
Lead? Offense Sectlon Subsection PA Statute (Title) Counts Grade NoIc offe nse UCR/NIBRS Code
ifapplicabl eh (1 interstate (CD Safety Zone C1] Work Zone

Statute Description (include the name of statute or ordinance): CORRUPT ORGANIZATIONS

Acts of the accused associated with this Offense: In that the Defendant being 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, prise’s affalrs through a pattern of

racketeering activity, that is, during the perfods as set forth herein. TO WIT; Tyreese Lewis, while associated with an enterprise, conducted and/or
participated, directly or indirectly, in the conduct of the enterprise's affalrs through a pattern of Theft by Unlawful Taking, Theft by Deception, Access Device

Fraud, and/or Identity Theft,

[] Attempt CJ Solicitation [1] Conspiracy Number of Victims Age 60 or Older
Offenseit Section Subsection PA Statute (Tiley) Counts Grade “NCIC Offense UCR/NIBRS Code
gs ié CO interstate CI Safety Zone {-] Work Zone

Statute Description (include the name of statute or ordinance): CORRUPT ORGANIZATIONS

Acts of the accused associated with this Offense: In that the Defendant, while employed by or assoclated with an enterprise, conspired to conduct
or participate, directly or indirectly, in the conduct of such enterprise's affairs through a pattern of racketerring activity, TO WIT: Tyreese Lewis conspired with
Kymaury Goldsby, Dorien Ervin, and/or other Identified and unidentified co-consplrators to participate In the conduct of the enterprise's affalrs through a
pattern of Theft by Unlawful Taking, Theft by Deception, Access Device Fraud, and/or Identity Theft,

C1 Attempt [] Solicitation CJ Conspiracy Number of Victims Age 60 or Older
18907 A 18 902A 18 903
Section Subsectlon PA Statute (Title) Counts Grade NGIC Offense Code UCRINIBRS Gade
bs Numbe [1] Interstate (] Safety Zone 1 Work Zone

“Statute Description (include the name of statute or ordinance): THEFT BY UNLAWFUL TAKING

Acts of the accused associated with this Offense: In that the Defendant, took or exercised unfawfut contro} over, movable properly of another with
Intent to deprive him thereof. The Defendant commited the offense during a Natural Disaster involving a catastrophe which results in substantial damage to
property, Hardship, suffering or possible loss of life, TO WIT: Tyreese Lewis, during the COVID-19 State of Emergency, filed fraudulent applications for
Pandemic Unemployment Assistance benefit program through the PA Department of Labor and Industry website for himself and others, knowing that he was
not qualified to do so, and were the fraudulent applications resulted in benefit payments of approxinately $147,250,

AOPC 412A ~ Rev. 7/18 Page a of @
#@ POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTNiLiveScan Number Complaintincident Number..." -
| First: Middle: Last:
TYREESE LEE LEWIS

Number of Victims Age 60 or Older

(i Attempt LI Soticttation Conspiracy
18 907A 18902 A 18 903
ad? ~ Offensett ; Subsection PA Statute (Title} Counts Grada NCIC Offense Gode UCRINIBRS Code
[] Interstate (C1 Safety Zone (J Work Zone

Statute Description (include the name of statute or ordinance): CONSPIRACY ~ THEFT BY UNLAWFUL TAKING

crime of Theft by Unlawful Taking or Dispoition, Title 18 Section 3921(a),
conduct which constitutes a crime or did agree to ald such other person or perso

co-conspirators, that they, or one or more of them, would engage In conduct consituting the crime of theft by taking,
of such conspiracy one or more overt acts were committed,

Acts of the accused associated with this Offense: In that the Defendant did, with the intent of promoting or facilitating the commission of the
agree with one or more persons that they or one or more of them would engage In
ns In the planning or commission of such crime or of an attempt ar solicitation

to commit such crime. TO WIT: Tyreese Lewis, during the COVID-19 State of Emergency, agreed with Kymaury Goldsby, Dorlen Ervin, and/or other Identified
in violation of Title 18, and In pursuance

Number of Victlms Age 60 or Older

[1 Attempt (1 Solicitation [J Conspiracy
ead? Offensedt_ Subsectlon PA Statute (Tite) Counts Grade NGIG Offense Code UCRINIBRS Gode

CI Safety Zone

UC Interstate

splice be

[J Work Zone

Statute Description (include the name of statute or ordinance); THEFT BY DECEPTION

false impression, including false impressions as to faw, value, |
for the Pandemic Unemployment Assistance program through the
not qualified to do so and that the information provided was false,
and correct, and where the fraudulent applications resulted in benefit payments of approximatetly $147,250.

Acts of the accused associated with this Offense: In that the Defendant, did intentionally obtain property of another by deception by creating a
ntention or other state of mind. TO WIT: Tyreese Lewis intentionally filed fraudulent applications

PA Department of Labor and Industry website for himself and others, knowing that he was
and where the Defendant certified on the application that the Information provided was true

[1 Attempt [J Solicitation | J Conspiracy Number of Victims Age 60 or Older
18 907A 18 902A 18 903
Lead? __Offense Subsection PA Statute (Title) Counts Grade NGIG Offense Code UGRINIBRS Code
[_] Interstate [-] Safety Zone [J Work Zone

Statute Description (include the name of statute or ordinance): CONSPIRACY ~ THEFT BY DECEPTION

crime of Theft by Deception, agree with one or more other persons that they o
agree to ald such other person or persons in the planning or commission of such ctime or of an attempt or sol

Lewls agreed with Kymaury Goldsby, Dorien Ervin,

conduct constituting the crime of theft by unlawful taking, and in pursuance of such conspiracy one of more aver acts were committed,

Acts of the accused associated with this Offense: In that the Defendant did, with the Intent of promoting or facilitating the commission of the
¥ one oF more of them would engage In conduct which constitutes a crime or did
icitatlon to commit such crime, TO WIT: Tyreese

and/or other identified and unidentified co-conspirators, that they, or one ar more of them, would engage In

AOPC 412A — Rev. 7/18
#8 POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTNiLiveScan Number Complaintiincident Number - st
| First: Middle: Last:
TYREESE LEE LEWIS
XJ Attempt C1 Solicitation Conspiracy Number of Victims Age 60 or Older
18 907A 18 902A 18 903
Section Subsection / PA Statute (Title) Counts Grade NGIC Offense Coda UCRINIBRS Code

C1 Interstate [1 Safaty Zone () Work Zone

Statute Description (include the name of statute or ordinance): CRIMINAL ATTEMPT - THEFT BY DECEPTION

Acts of the accused associated with this Offense: In that the Defendant did, with intent to commit the crime of Theft by Deception, performed an

act constituting a substantial step toward the committing of the crime of Theft by Deception. TO WIT: Tyreese Lewis Intentlonally fled fraudulent applications
for Pandemic Unemployment Assistance benefits and Economie Impact Disaster Loans, knowing that he was not quallfted to do so and that the information he
provided was false, and where the Defendant certifled on the application that the informatlon provided was true and correct, ‘in an attempt to obtain an excess

of $2,000 in funds that he was not entitled to receive.

[1] Attempt [7] Solicitation Ci Conspiracy Number of Victims Age 60 or Older
18901 A 18 902A 18 903

PA Statute (Tite) Counts Grade NCIC Otfanse Code UCRINIBRS Gade
(1 Interstate I"] Safety Zone [7] Work Zone

Sectlon Subsection

Statute Description (include the name of statute or ordinance): IDENTITY THEFT

ciated with this Offense: in that the Defendant possessed or used, through any means, Identifying Information of another
urpose. TO WIT: Tyreese Lewis used personal Identifying Information, Including soclal

sent, in order to fraudulently obtain Pandemic Unemployment Assistance and Economic

n approximately $66,420,

Acts of the accused asso
person without the consent of that person to further an unlawful p
security numbers, belonging to other persons and without thelr con:
Injury Disaster Loans, The Defendant used the unauthorized personal identifying Information to obtal

CI Interstate [1 Safety Zone [1 Work Zone

CL] Attempt [] Solicitation [Jj Conspiracy Number of Victims Age 60 or Older
18907A 18902 A 18 903
Offenseil Subsectlon : PA Statute (Thile) Counts Grade NCIC Offanse Code UCRINIBRS Code

Acts of the accused associated with this Offense: In that the Defendant used an access device to obtain ar In an attempt to obtain property or
services with knowledge that his use of the access device Is unauthorized by the Issuer or device holder, TO WIT: Tyreese Lewls used personal Information of
other Individuals In order to fraudulently receive Pandemic Unemployment Assistance benefits, where sald benefits were In excess of $500, and were fssued to

and accessed by the Defendant using a US Bank deblt card,

Page of ip

AOPC 412A — Rev. 7/18
#@) POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTNiLiveScan Number Complaintincident Number... 6
First: Middle: Last:
TYREESE LEE LEWIS

2. | ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges | have
made,

3. | 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 consists of the preceding page(s) numbered 1 through Ss.

5. | 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 that 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 he issued, an affidavit of probable cause must be completed, sworn to before the
issuing authority, and attached.)

AND NOW, on this date ~) , 7s ° a | | 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)

AOPC 412A ~ Rev. 7/18 | =“ ee paced or
th POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTNiLiveScan Number Gomplaintincident, Number BR

First: Middle: Last:

TYREESE LEE LEWIS

AFFIDAVIT of PROBABLE CAUSE

AFFIDAVIT OF PROBABLE CAUSE
Your Affiant, Special Agent Kathryn Grady of the Pennsylvania Office of Attorney General (OAG), being
duly sworn to law, depose and say:

I, AFFIANT’S BACKGROUND

Your Affiant, Agent Kathryn Grady, is a Special Agent employed by the Pennsylvania Office of Attorney
General, Bureau. of Criminal Investigation, and is empowered by law to conduct investigations and make arrests
relating to white-collar crimes, theft, fraud, and other violations of Pennsylvania Law. Your Affiant currently holds
the designation of “Certified Fraud Examiner” and has conducted numerous investigations involving financial

crimes. Your Affiant has received training in electronic surveillance by the Pennsylvania State Police in accordance
with the Pennsylvania Wiretapping and electronic Surveillance Control Act. This training resulted in the issuance
of a class “A” certification, authorizing your Affiant to conduct criminal investigations using various wiretapping
equipment, as authorized by Chapter 57 of the Pennsylvania Crimes Code. Your Affiant was certified to employ
such techniques while conducting criminal investigations, maintaining “A” certification number A-5948, Your
Affiant has been so employed since January 2018 and is currently assigned to the Financial Crime Section in
Harrisburg, Pennsylvania. Prior to employment with the Pennsylvania Office of Attorney General, your Affiant was
employed as a Security Investigator at First National Bank of Pennsylvania (formerly Metro Bank) and conducted
fraud investigations with the Pennsylvania Office of Inspector General.
Based upon your Affiant’s law enforcement experience and training, your Affiant is familiar with the manner
in which various crimes are committed in the Commonwealth relating to public corruption, white collar ctimes, theft
and fraud. Based upon the foregoing training and experience, your Affiant has special expertise regarding the

practices of, and techniques used by, these offenders.

AOPC 411€ — Rev. 07/18 ° Page 4 of £3
tas POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTN/LiveScan Number Complaintincident Number * |
|| FCC-21-0004

First: Middle: Last:

TYREESE LEE LEWIS

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 (L&I) 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
to L&l’s website, the following groups are explicitly defined as being ineligible to receive PUA: “Inmates; 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 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, L&I’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’ benefits. You may also be subject to criminal prosecution.” On June 1, 2020, the
Pennsylvania Office of Attorney General (OAG) 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 L&L,
Pagecd of 1.2

AOPC 412A — Rev, 7/18
Mh POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTNiLiveScan Number. Complaint/ineldent Number

First: Middle: Last:
TYREESE LEE LEWIS

Wl. INVESTIGATION

The OAG received information in reference to alleged fraudulent PUA benefit filings involving an individual
identified as Tyreese Lewis, A Dauphin County probation officer, who supervised Lewis and actively monitored
his Facebook and Instagram. accounts, contacted your Affiant and provided information that Lewis appeared to be
attempting to recruit individuals for the purpose of filing PUA benefit applications on their behalf on social media.
Lewis’s social media accounts were identified on Instagram and Facebook. The usernames for Lewis were identified
as “bubba.tmnch,” “bubba.trnch.7,” and “bubba.za.”

Your Affiant reviewed the following Instagram story posted by Lewis under username “bubba.trnch” on August
19, 2020: “Ifyou did pa pua an they paid the weeks an you never got your card hit me ASAP.” The background of
the message contained a screen shot of L&I’s website, which included filing dates, the transaction identification
number, and the weekly claim amounts. The transaction identification numbers, which are internal numbers assigned
by L&I to identify and track applications, were 1991218 and 1856477, Your Affiant also reviewed a similar post
on Facebook made by Lewis under username “bubba.tench.7” on September 13, 2020, The background of the post
was a copy of an e-mail sent by L&I in order to notify the recipient (the recipient’s email address was blocked) that
claim weeks ending for August 1, August 8, and August 15 were available for submission under the PUA program,

Further, on August 18, 2020, under Facebook username “bubba.za’”, Lewis posted a screen shot of an application
for a COVID-19 Economic Injury Disaster Loan Application. The caption on this post stated “Hit Me ASAP if you
wanna make this free money,” The COVID-19 Economic Injury Disaster Loans (EIDL) are administered by the
U.S. Small Business Administration. The purpose of the EIDL is to provide economic relief to small businesses and

nonprofit organizations that are currently experiencing a temporary loss of revenue to the pandemic.

AOPC 412A ~ Rev. 7/18 Page 2 of L2
4 POLICE CRIMINAL COMPLAIN]

Docket Number: Date Filed: OTNi/LiveScan Number Complaintiincident Number . —
Middie: Last:
LEE | LEWIS

IV. FRAUDULENT PUA APPLICATIONS

a, Application Information

The PA Department of Labor and Industry provided your Affiant with PUA claim documentation related to
the identification numbers 1991218 and 1856477, which were shown in Lewis’s August 19, 2020 social media post.
According to the records, these identification numbers corresp ond to a PUA application that was submitted on Tune
22, 2020 using a social security number belonging to Israel Blankenship. The IP addressed used to submit the
application was 73, 130,137.208, Blankenship is a Kentucky resident and has no known connection to Pennsylvania,
Your Affiant learned that, while PUA benefits were issued for this application, the funds were never withdrawn.
However, the investigation revealed that the IP address used for this application was identical to the IP address on
six other applications, including an application for Tyreese Lewis,

Lewis’s application was submitted on June 5, 2020, From June 11, 2020 to February 24, 2021, Lewis
received $12,450 in benefits. Your Affiant requested information pertaining to Lewis’s employment history in order
to verify the validity of his application, Your Affiant learned that Lewis last worked in the third quarter of 2019,
Based on the qualification requitements, Lewis would not have been tied to the job market, and therefore ineligible
to receive PUA benefits.

In addition to Lewis’s own fraudulent application, multiple other PUA benefit applications believed to be
linked to Lewis were identified based on the same IP address, mailing address, email address, or telephone number
submitted on the applications. Further, a review of additional PUA applicant information, bank records, and
surveillance video identified two additional individuals — Kymaury Goldsby and Dorien Ervin - as participating in
the activity surrounding the fraudulerit applications. The records show that these applications’and payments for PUA

benefits were submitted between May 26, 2020 and January 25, 2021, The applications are identified below in

TABLE 1,

AOPC 412A — Rev. 7/18 ““pageL of 13
8% POLICE CRIMINAL COMPLAIN]

Docket Number: Date Filed: OTNiLiveScan Number Complaintincident Number
FCC-21-0004 ©
Middle: Last:
LEE LEWIS
TABLE 1
: Phone Number Total
Received
1017 Topview Drive, ort.
5/26/2020 Dorlen Ervin Harrisburg, PA 17112 717-857-4485 73,130.129.61 $20,900
Tyreese 821 Squire Rd, 704.
6/5/2020 Lewis Harrisburg, PA 17144 717-704-6397 73.130,137,208 $20,550
Danielle 301 N Progress Ave,
6/5/2020 H3, Harrisburg, PA 717-599-4687 73.130,137.208 $26,865
Watlington
17109
Kymaury 5 Jury Street, ola.
6/5/2020 Goldsby Highspire, PA 17034 717-914-7362 73.130.137.208 $3,975
Zyaire 2445 Walnut Street, B, ane.
6/9/2020 Monesratt Harrisburg, PA 17113 717-356-0407 773.130.137.208 $12,690
Jullan 114 Radle Rd, ADK
6/20/2020 Jackson Harrisburg, PA 17142 717-425-8870 73.130.137,208 | $8,915
223 N 40® Street, Apt
6/20/2020 Jalre Cotton 101, Harrisburg, PA 717-992-5477 98.235.217,52 $13,800
17111
Isreal 301 N Progress Ave, ;
6/22/2020 Blankenship H3, Hatrishros PA 717-316-5625 773.130.137.208 $17 ,A75
301 N Progress Ave,
6/29/2020 Mack Daman H3, Harrisburg, PA 443-405-2952 107.77.203.170 $0
17169
301 N Progress Ave,
7/2/2020 Jessika Baker H3, Harrisburg, PA 443-405-2952 73.130.137.208 $0
17109
Brittne 301 N Progress Ave,
7/15/2020 Y H3, Harrisburg, PA 443-405-2952 96,240,151.154 $0
Hutchins 17109
Coy 193 S Front Street,
7/16/2020 Thompson Apt 4, Ha PA 717-210-2148 73.130,137.208 $22,080
Robert 301 N Progress Ave,
7/17/2020 H3, Harrisburg, PA 412-637-4456 73,130.137.208 $0
Burgos 17109
301 N Progress Ave,
7/17/2020 Marle Delfin H3, Harrisburg, PA 223-443-5567 73.130,137.208 $0
17109

Your Affiant believes that, similar to the Blankenship application identified in Lewis’s social media post, several

of the applications linked to Lewis were filed without the knowledge or permission of the applicant. Specifically,

‘AOPC 412A — Rev. 7/18 |

Pages. of 13
Docket Number: Date Filed: OTNiLiveSoan Number Complaintincident Number

wards Last:
LEE LEWIS

the application submitted on July 15, 2020 using a name and social security number belonging to Brittney Hutchins,
lists the address of 301 N. Progress Ave, H3, Harrisburg, PA, Hutchins is a Maryland resident with no work history
or identifiable connection to Pennsylvania, The application for J essica Baker, which lists the same address — 301 N.
Progress Ave, 13, Harrisburg, PA - was submitted with a social security number belonging to a Jackie Hohney of
San Diego, California. Your Affiant spoke with Coy Thompson, who confirmed that he did not apply for PUA
benefits and had no knowledge of the filing. Thompson stated he currently collects Veteran Affairs benefits because
he is disabled. The IP address used for the applications of Blankenship, Baker, and Thompson is the same as that of
both Lewis and Goldsby,

Your Affiant made contact with the property manager for the apartment complex at 301 N. Progress Avenue,
H3, Harrisburg, PA. According to the property manager, Danielle Watlington was a resident of the apartment during
the time of the PUA applications. An application in Watlington’s name was submitted on June 5, 2020, on the same
date and with the same IP address as the applications for Lewis and Goldsby. However, at no time did any of the
other individuals identified in TABLE 1 reside at that location,

b. Financial Records / Surveillance Video

Your Affiant reviewed the payout information for each application as provided by L&I. Upon approval, the
initial payment would be made via check, and the remaining payouts were disbursed through Electronic Funds
Transfer (EFT) or check payments. The applicant would determine the preferred method of disbursement. In June
2020, the PA Department of Treasury made the decision to issue US Bank Debit Cards for all approved payments.
The US Bank Debit Cards work like a pre-paid card, the applicants can only use the funds available based on
approved disbursements by Lé&i. T he PA‘Department of Treasury provided your Affiant with the'last four digits of

the debit cards issued to the applicants outlined in TABLE 1. Baker is the only applicant who did not have a debit

card issued.

AOPC 412A — Rev, 7/18 - Page of 19
49 POLICE CRIMINAL COMPLAINI

Docket Number: Date Fited: OTNiLiveScan Number Complaintiincident Number...)
FCC-21-0004 no
Middle: Last:
LEE LEWIS

Your Affiant reviewed the transaction logs provided by US Bank for the applications identified in the
investigation, Your Affiant identified several financial accounts which were attached to the PUA benefits. Lewis
indicated on his PUA benefit filing that the funds could be directly deposited into Members 1“ Federal Credit Union
bank account 717878, an account verified as belonging to Tyreese Lewis, A review of the US Bank records revealed
that debit cards issued to both Lewis and Watlington transferred funds to Members 1% FCU bank account 717878.

The US Bank ACH detail records for Watlington’s account identified additional ACH transfers to financial
accounts identified as follows: Takena, Wells Fargo Bank Account Number 7215774071 and Andrew, Cash App

account number 1315354241649. Records revealed Cash App account number 1315354241649 is owned by
Tyreese Lewis, with additional display names of Andrew Swanger and Champ Kimbell. Your Affiant reviewed
records for Wells Fargo Bank account 7215774071, which is owned by a Takena Glascoe, Glascoe’s monthly
statements are mailed to 347 N Railroad Street, Palmyra, PA 17038. On February 10, 2021, Glascoe attempted to
make two wite transfers to Tyreese Lewis’s Members 1* Federal Credit Union account 717878. The wire transfers
were for $1,800 and $1,500 respectively. The transfers were cancelled and the funds withdrawn from the account
through ATM withdrawals in the Philadelphia, PA area, These withdrawals correlate with the same locations of
ATM withdrawals from Lewis’s Members 1‘ Federal Credit Union account.

The US Bank ACH detail records for an application submitted in the name of Zyaire Monserrat show transactions
to Cash App account numbers 1309358053282 and 13929436242590, There were no names associated with these
account numbers, the description is listed as “Cash App Personal Checking”. Additionally, Cash App account
umber 13929436242590 was provided on fraudulent EIDL application information for PUA fraud victim Brittney
Hutchins (outlined in a subsequent section of this affidavit).

Your Affiant was able to obtain video surveillance from some of the US Bank debit card transactions between

June 28, 2020 and February 24, 2021 which occurred at Sheetz in the greater Harrisburg area, Your Affiant identified

AOPC 412A — Rev. 7/18 — Page 1 of 12
8% POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTNiLiveSean Number CGomplaint/incident Number
Middle: Last:
LEE LEWIS

Lewis has having accessed funds for the US Bank debit card issued for his claim, as well as for the claim of Danielle
Watlington. Your Affiant also identified a second individual, Dorien Ervin, as using the US Bank debit card issued
to Coy Thompson. In addition to footage of fund withdrawals for Thompson, Ervin also withdrew funds linked to
his own account. Yout Affiant learned that Ervin applied for PUA benefits on May 26, 2020. According to Labor
and Industry records, Ervin last worked for Arooga’s in the first quarter of 2020, Your Affiant confirmed with
Arooga’s, Ervin’s last date of employment was February 28, 2020, which was prior to the restaurant shutting down
due to COVID.

Your Affiant also identified a third individual, Kymaury Goldsby, who is seen in video surveillance using the
debit card that was issued to Zyaire Monsserat. Goldsby applied for PUA benefits on the same date as Lewis - June
5, 2020 — from the same IP address. Your Affiant discovered Goldsby was employed during the second quarter of
2020 at Chipton Ross Staffing Agency. Your Affiant spoke with a representative from Chipton Ross Staffing who
confirmed Goldsby was briefly employed with them and was not laid off due to COVID.

c. Social Media |

Your Affiant obtained and reviewed social media records connected to Lewis from
Facebook, Inc. Throughout the time of the fraudulent applications, Lewis sends and receives numerous messages to
multiple other users relating to obtaining identifications to use for filing fraudulent PUA benefit claims, with one
specific reference to using identities of California residents, Additionally, Lewis appears to provide advice and/or
assistance to others in submitting fraudulent PUA claims, some of which provide Lewis with the personal
identification information for individuals that your Affiant confirmed had applications submitted in their names.

Specifically, in a message sent by Lewis on July 10, 2020, he identifies his address as 193 S. Front Street,
Harrisburg — the address used to file PUA benefit claims for Coy Thompson. On August 11, 2020, Lewis sent a

video message through his Instagram account “bybba.trach” to user “lilrekk”. The video message shows stacks of

AOPC 412A ~ Rev. 7/18 ~ Page % of k>
*8 POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTN/LiveScan Number Complalnt/incident Number, ve
i] FCC-21-0004
First: Middle: Last:
TYREESE LEE LEWIS

cash with the caption, “If you did PENNSYLVANIA UNEMPLOYMENT ALLYA WEEKS GIT PAID BUT YOU
NEVER GOT YA CARD HIT ME ASAP BRO”,

On September 26, 2020, Lewi messaged Instagram user “1gkeemo” in yeference to PUA benefit filings, The
user “1 geekmo” told Lewis he had cards and names for Pennsylvania, California, Arizona, and Michigan,

Your Affiant reviewed additional messages in which individuals reached out to Lewis through Instagram’s
direct message system seeking direction on filing for PUA benefits. Lewis indicated to these individuals that he
could fix any application, Lewis and these individuals also discussed payment for his assistance in filing or fixing
the PUA applications. On March 20, 2021, Lewis told user “_linggg0” that if they paid him $300, he would give
them “a real method”. Lewis claimed he was making $10,000 to $20,000 per month.

d. IP Addresses

Your Affiant compared the IP logs provided by US Bank, Pa, Department of Labor, and Facebook, Inc. and was
able to identify matching IP addresses among the claimants on multiple occasions using multiple IP addresses with
different subscribers. The initial IP address used to file the majority of the applications was identified as Comcast
Cable IP Address 73,130.137.208, for which the subscriber information was no longer available. This IP Address
was used to register or access the applications for Ervin, Lewis, Watlington, Goldsby, Monseratt, J ackson,
Blankenship, Baker, Thompson, Burgos, and Delfin. Significantly, one of the addresses used to access the benefit
accounts of Britney Hutchins, Tyreese Lewis, Symaury Goldsby, Mack Damani, Courtney Thompson, and Danielle
Watlington was Comcast Cable IP address 174,54,220,234, The subscriber for this IP address was identified as

Dorien Ervin located at 806 S 27" Street, Harrisburg, PA 17111. Ervin was the individual seen on surveillance

footage using the US Bank card assigned to Thonipson’s PUA claim,

Page 4 of Is

AOPC 412A — Rev. 7/18
das POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTN/LiveScan Number . Complaintincident Number ~~
Middle: Last:
LEE LEWIS

e, US Bank / PUA Registrant Telephone Numbers

Based on records obtained by your Affiant from US Bank and the OJG-SBA, it was determined Lewis used the
telephone numbers 717-704-6397 (which was tied to his original PUA application) and 717-443-4747, Lewis began
using telephone number 717-443-4747 on September 20, 2020, Telephone number 717-443-4747 was added to the

US Bank records for Watlington after the US Bank issued a debit card for her PUA claim,

V. FRAUDULENT EIDL APPLICATIONS
a. US Small Business Administration Economic Relief Application Information

Based upon on the August 18, 2020 post by Lewis, which showed a screen shot of an EIDL application that
was approved for $35,000, your Affiant contacted the Office of Inspector General for U.S. Small Business
Administration (OIG-SBA) and obtained several EIDL loan records. There were a total of six SBA applications
identified as having been submitted by Lewis. The applications were filed on behalf of Champs Auto Sales, Barber
Cutz, Brittney Hutchins, and Tyreese Lewis. Lewis indicated he was the owner of Champs Auto Sales, Barber Cutz,
and that he was the sole proprietor for 3 businesses using his own name, OIG-SBA identified an additional
application in the name of Brittney Hutchins, indicating she was an. Uber driver. Based on the records provided, it
was determined the same email address and Cash APP account numbers were used to complete the application,
which were also found on the PUA applications. On the business application for Champs Auto Sales, the business
address used was 210 Hale Ave, Harrisburg, PA 17104. Champs Auto Sales is not a registered business per the PA
Depattment of State website. The address of 210 Hale Ave is for the apartment complex Magnolia Gardens. Barber
Cutz is also not a registered business per the Pennsylvania Department of State website. The address provided for
» the business was 505 N Ave, Harrisburg, PA 17103.” The additional applications filed by Lewis in his givert name,
used the mailing address of 821 Squire Rd, Harrisburg, PA 17111. This is the address used on Lewis’s Pennsylvania

driver’s license. The application filed on behalf of Hutchins used mailing address 310 N Progress Ave C16,
Page lb. of 1%

AOPC 412A ~ Rev, 7/18
ith POLICE CRIMINAL COMPLAIN}

Docket Number: Date Filed: OTN/LiveScan Number Complaintincident Number
Lf FCC~21-0004 _
First: Middle: Last
TYREESE LEE LEWIS

Harrisburg, PA 17109. The address is for Pines Apartment Complex. Your Affiant contacted the leasing office for
Pines Apartment Complex and verified that Hutchins has never been a tenant at the apartments.

b. Social Media

Similar to the messages sent in reference to the PUA claims, Lewis exchanged numerous messages with
specific reference to SBA loans. In an Instagram messages sent by Lewis on December 27, 2020 to user
“uncleron.ns”, he wrote on December 27, 2020, that “sha clapping I got the method.” Lewis sent a screen shot of a
“submitted SBA loan application, with the applicant name and loan number redacted. Lewis told “uncleron.ns” to
call him to talle about the SBA loans and provided the telephone number 717-443-4747, which belongs to Lewis,
There were additional individuals who messaged Lewis in reference to filing for SBA loans. Lewis indicated in
both text and audio messages that the SBA loans are based on credit ratings and he could easily get them money
from the program. Lewis indicated in the multiple direct message conversations that he knew how to file for SBA
loans, The users indicated they would pay him for filing for the loans,

¢, Financial Records

Your Affiant reviewed the transaction logs provided by US Bank for the applications identified in the
investigation, Your Affiant identified several financial accounts which were attached to the SBA EIDL loans, Lewis
indicated on his SBA loan applications that the funds could be direct deposited into Members 1* Federal Credit
Union bank account 717878, the same account in which he received PUA benefit disbursements. The US Bank ACH
Details reflect transactions from Watlington’s account to Cash APP account number 1315354241649, which was
identified as being owned by Lewis. There were no names associated with these account numbers, the description.

“is listed as “Cash App Personal Checking”. Cash App account number 13929436242590 was provided on the EIDL

application for Brittney Hutchins. However, unlike the PUA applications, Lewis’s applications were denied due to

poor credit score ratings.

‘AOPC 412A — Rev. 7/18
ti POLICE CRIMINAL COMPLAIN]

Docket Number: Date Filed: OTN/LiveScan Number Complaintiincident Number = *
First: Middle: Last:

TYREESE LEE LEWIS

VI. CONCLUSION

Based on the facts and circumstances of this investigation, and your Affiant’s training and experience involving
thefts and white collar crime investigations, your Affiant believes that Tyreese Lewis, Dorien Ervin, and Kymaury
Goldsby participated in the filing of fraudulent applications for Pandemic Unemployment Assistance benefits. The
investigation, which included records provided by the PA DOL, Department of Corrections, Pennsylvania Treasury,
and documentation obtained via Search Warrant, revealed Lewis, Ervin, and Goldsby conspired to file approximately
{7 applications, to include their own, for persons that were not eligible for the PUA program based on the
requirements set forth in the Cares Act. The PUA applications and weekly certifications specifically state that all
information provided must be “true and complete.” The certification also requires, the acknowledgement that any
false statements made on the application is a ctiminal offense. ‘The theft of funds from the fraudulent PUA
applications total approximately $147,250. |

The investigation also revealed attempts by Lewis to fraudulent obtain Small Business Administration EIDL
loans, which totaled approximately $33,500, Lewis filed approximately 6 SBA loan applications for himself and
one for Britney Hutchins. The loans were denied due to poor credit score ratings.

The information above is based upon information gathered during the course of this investigation, which your
Affiant believes to be true and correct to the best of their knowledge. Based upon the aforementioned facts, your

Affiant respectfully requests an arrest warrant be issued for the defendants Tyreese Lewis, Dorien Ervin, and

Kymaury Goldsby.

‘AOPC 412A — Rev, 7/18 — Pagel a. of 1.2
4 POLICE CRIMINAL COMPLAINT

Docket Number: Date Filed: OTNiLiveScan Number Complaintincident Number .-
Middle: Last:
LEE LEWIS

I, KATHRYN GRADY, 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.

1 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 THAT NON-CONFIDENTIAL INFORMATION AND DOCUMENTS.

A. Ky
(Signature jof Affiant)
Sworn fo me and subscribed before meghis J ah h \ AWA al y\

, Magisterial District Judge

My commission expires first Monday of January,

AOPC 412A — Rev. 7/18 © Pagel of LF


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