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Police Criminal Complaint: Commonwealth of Pennsylvania vs. John Jones (Dauphin County)

Summary

A police criminal complaint against John R. Jones, an inmate at SCI Rockview, filed in Dauphin County, Pennsylvania, with Hon. Sonya M. McKnight as the magisterial district judge. It lists offenses under the Pennsylvania Crimes Code, including criminal conspiracy and theft. In the affidavit of probable cause, SA Chris Weaver and SA Katie Grady state that Jones sent Elise J. Ballard the names, dates of birth and Social Security numbers of 10 inmates through prison messages, and that Pandemic Unemployment Assistance (PUA) applications in those names drew $66,915.00. They state that a PUA application in Jones’s name was submitted on June 12, 2020 while Jones was incarcerated and paid $21,630.00, that Ballard put $3680.00 on John Jones’s JPay account, and that the PUA funds linked to Jones totaled $88,545.00.

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

                                                                                    ffi
  COMMONWEALTH OF PENNSYLVAN IA
                                                                                                                  POLICE CRIMINAL COMPLAINT
  COUNTY OF:DAUPHIN                                                                                                COMMONWEALTH OF PENNSYLVANIA
  Magisterial District Number: t2-2-04
                                                                                                                                                  VS.
  MDJ: Hon. Sonya M. McKnight                                                       DEFENDANT:                                         (NAME and ADDRESS):
  Address: 1805 North Cameron St.                                                  JOHN                                          R                      JONES
              Harrisburg, PA 17103                                                 rirs{                                    -MEAteName W                                                   Ge
                                                                                                                                                                                           n
                                                                                   SCI ROCKVIEW, 1 ROCKVIEW PL
  Telephone : (7 L7)233-3599                                                       BELLEFONTE, PA 16823

  D( 1-Felony Full
  E 2-Felony Limited                                                                                                                                            fl Distance
  I S-fetony Surrounding States                   t] n-UisOemeanor Futl                                 f] e-UisOemeanor Pending Extradition
  [ +-netony No Extradition                       I g-MlisOemeanor Limited                              E f-Misdemeanor Pending Extradition
                                              %




                                                                       =rrrrratt I trJElr I travA I t{Jtt lNrvl{lul,l   I lLrN
  DocketNumber

 rfr:                                      Date Filed                Ofltl/LiveScan Number                          Complai nUlncident Number                   Request Lab
                    i7- al                 I tht 0.1                 ft tolf 5 y-5
                                                                                                                                                              Services?
                                                                                                                        occ-20-0025                               E ves EX wo
  GENDER               DoB 06/10/1989                   POB PA                                                    Add't DoB /             I                   Co-Defendant(s) EI
  E utate                        First Name                                            Middle Name                                    Last Name                                      Gen.
  fl Female            AKA

  RACE                 flwnite                               Asian                                     Black                Native American                   t    Unknown
            r   r    u Hrspantc                   l)!l Non-Hispanic                                 E unknown
            E Cnv (Gray) E neo (Red/Aubn.) E Soy (Sandy)                                            E elu latue;      f] plE (purpte)                         fl ano (Brown)
 Hair
            Et eLr (Btack) fl or,rc (orange)               E wHr(white)                             f]xxx (Unk./Batd) E enr.r (Green)
 Color                                                                                                                                                        fl pr.tx (pinr)
            I alru (Btonde / Strawberry)
 Eye
 Color
            X BLK (Btack)
            E Hez (Hazet)
                                         E elu (etue)          E eno (Brown)
                                         E unn (Maroon) [ pr.rx (ptnr)                                       E wtut- (Mutticotored)
                                                                                                                                                        ffi
                                                                                                                                                         E xxx (Unknown)
 DNA
                            I tl YES tr No I DNA Location                                                                                                         I wElGHr (!bs.)
 FBI Number
                                                                     MNU Number
                                                                                                                                                                    250
 Defendant Fingerprinted             I ves El ruo                                                                                                                   Ft. HEIGHT ln.
 Fingerprint Classification:
                                                                                                                                                                   5            11
                                                                      DEFEN DANT VEHICLE INFORMATION
                                   State      Haz                    Registration @                                              School Veh.       Oth. NCIC Veh. Code              Reg.
 Plate #                                      mat
                                                  D
                                                             Sticker (MM/YY) I                  I       lnd' tr                       n                                          same
 VIN
                                                                                                                                                                                as Def.
                                                        Year          Make                             Model                              Style               Color
                                                                                                                                                                                    tr
 Office of the attorney for the Commonwealth fl Approved tr Disapproved because:


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

 HEATHER A. CASTELLINO, SDAG
 (Nameortnea@                                                                                                                                                      I lls I zoal
                                                                                                                                                                           (Date)



    (Name of the Affiant)                                                                                      EE=4=Aa3lsApGE#s
                                                                                                               (PSP/MPOETC -Assigned           Affiant lD Number tBadge #
           Penn                                                                                                   P4022240A
    (ldentify Department or Agency neprese                                                                     (Police Agency ORI Number)
  do hereby state: (check appropriate box)
 1- E 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 unt no*n to mE ana *t orn t trare
     therefore desiqnated as John Doe or Jane Doe
     with violating the penal laws of the Commonwealth of Pennsylvania at
                                  Pa                                                                            [30U
                                                                                               pA Dept Of Labor And Industrv.
651 Boas St, Harrisburg,                                                  (suE-dlv6-'o-fi-codd)--                                             1naffi
         in DAUPHIN County                            t221                        on or about JUNE                      2O2O TO SEPTEMBER 1 2020


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   Docket Number:                         Date Filed:                 OTN/LiveScan Number
                                                                                                      'ffi PoLtcE 6R;MINAL coMpLAtNT
     b* l1-Al                        First:
                                            lt
                                                                          Middle:
                                                                                                                            Com plai nUlncident Num ber
                                                                                                                            occ-20-0025
                                                                                                                  Last:
                                     JOHN                                 R                                       JONES


  The acts committed by the accuse
  when there is more than one offense, each offense should be numbered chronoloiically.
  (Set forth a bniefsummary of tha facts sufficient to advise th€ derendant ot the nature
                                                                                            oirh" .f""*f.iilr"+l'.a. I cit iion to tho 6tatute(s) a[ogodly viotatod,
  whhout morc, ls not sufficient ln a Gummtry case, you must cite the specific 6ection(s) ano suusecir,on(ey;ih"-"t"tGl"j
                                                                                                                                 o.o.uin"ncc(s) a egedly viotated.
  The age ot the vlctim at the dme of the otirnse m.y-be included lf known. ln addltion siclal socurltyr numlers
                                                                                                                    ana nnanili infoma{on (o.g. plN6) shoutd not
  be llst d.ltthe ldonttty ofan account musl be establlstred, llst onty the tast four dtgttB.2o,t pl"cooj
                                                                                                          SS iis.i - 2iij.i
                                                                                                                             --



    B          1          911                    b3                                                    1            F1
   Lead?
               offense          Section           Subsection                                                                      NCIC Offense
                                                                              PA Statute (Title)                                                   UCR/NIBRS Code
                                                                                                                                     Code



  Statute Description (in


 Acts of the accused asso
 13,  *i.TtfTH:l          i9,l0:J,IiLtI9.?1Ltt     or Da-uphin,. centre, camuria, ienns.)uania ana         *", *narJ oiiirti"ip"t , oir""tv or indirecuy in B1g
 conduct of such enterprise's afirs throush a pattern of racketeerinj                              "ii"*t ;;;i;,;; ii""r.in. our"no"rt *us assocjated with an
                                                                               ir,iiii, ,irrirgG ;"-;;,J.;
                                                                          ".ti"itv,
 enterprise constituting a group of individuals associated.in fact, although   noi a legdlintity,            in commer"e inJ consisting of Elise J. Ballard, and others,
 and Defendant did condud or participate, direcdy or indirectly. in the conduct      of            "ngaied
                                                                                        re atrairs ofitr"                 lnr*sni!-iit",
                                                                                                                                      or rr.t"t""ring activity as
 defined in 18 Pa.C.S. S911(h) consisting of (Seecontinuation of Offenses)                                "rt"rp,ii"




  tr
 Lead?
           2
           Offense#
                          911
                                                 L4 ffi                  TrLE lB                      1           F1
                                                                                                                                 NCIC Offense
                                                  Subsection                PA Statute (Title)         Gounts        Grade          Code          UCR/NIBRS Code

                                                                                                 D lnterstate
 StatuteDescription(includethenameofsiIoNs
 Acts of the accused associated with
 P:gll:}^.gl^.:9*1":       j_"g1rT,1iq!]:*here, conslired to violate the provisions of section sr1('diof 6" iriro cooe 18 pa.c.s. Ss11(bX3),
 pertaining to corrupt orsanizauons, that is, during the periodi.as set forth hereiri,
                                                                                       oefendant,      prr"trg
                                                                                                          with urJ inGrii#
                                                                                                                                                                   --  u,"
 crime of corrupt organizationt did conspire and agree with other indMduals, thai they, ol. one o, ,ore
                                                                                                             ot tt
 enterprise set forth herein, would conduct or participate, direcdy or indirecuy; in the c;;duct of the affairs
                                                                                                                                                                 ti
                                                                                                                                   "iriliiidd"-,:'ilJ.1i,i#i'ill,X
                                                                                                                        wttire enipfoveo uv or
                                                                                                                          "r,
                                                                                                                                               issociatea wiur
                                                                                                                of it J             tt rougli pattem of racketeering
 activitv as defined in 18 Pa.c.s. s911(h), in viotation of section 9111u;1+; ofure crimes cooe, 18 pa.c.s.                   '
                                                                                                                        "nte.prir"           "
                                                                                                               s911(bx4).




               Offense#
           nDOT Data

StatuteDescription(includethenameorst@FTBYUNLAwFULTAKINGoRDIsPosITIoN

Acts of the accused associated with t
        d,"g::,liT.L":TJ-1"^-D-:1,.194 .gllitted the offense durins a Natural Disaster invotvins a catasrrophe ;tricn resud in iuostanti"lduris"
*:T
propefty, hardship, suffering or possible loss of life.                                                                                                           to




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                                                                                                     #        poLtcE cRtMtNAL coMpLAtNT
   'uF:"i#"\t                                   Date Filed:
                                                     lt
                                                                               OTN/LiveScan Number                       Com plai nilnaiden[ Num ber
                                                                                                                         occ-20-0025
                                              First:                              Middle:                      Last:
                                              JOHN                                R                            JONES




        tr               4         I 3e21                    a                                       1           F2
                                                            :r- Subsection
                                                                                      pA S
         reflnuLrtuala                    I   Accident
             (if applicable)              I r',lu*o"i                                          fl tnterstate I                n Safety Zone I        n Work Zone
  Statute Description (include the nam

 Acts of the accused associated w]t
                                                                      asree wittron€ or more otrer'persons irat trey or one or more or ttrem woutd ensase in
 *;'f ,?"Yl':g:ilflgoJ-?,':t^":iu91      llt!^11*f_91:?t!11       9id
 condud which constitutes a clime or did asree_ro-aid such othii perso;";; p";;;;;; dl;
 to commit such crime, that it between June of 2o2o and september of 2oio, within the drnii"r
                                                                                                ffiilff;;ffi;H#hffi:           ;ff; ;i:]#,"ru",i1"#ffii
                                                                                                        oirpni", G"f,e]dmoria,           nennryranlu i"o   a.*h"*,
 3f,*::1,.+i:qf:Ii:*:ll{I9gr:lf!l!1,-9,.o!!                    ol,o,u of them,  wouratngJsei;;il#"#t,fi-tirJ#meoruretoy unrawru takins, in
                                                                                                 "r
 violation of ritle 18, and in pursuance of such conspirary one or more or"rt jcts *"re c6mi"itd;;;
                                                                                                    ;ffi;; ;i;'d;; ;ffi i#"iilU#:l:ffi;:i                       dl


                                 I Attempt                E solicitation     I Conspiracy                Number of Victims Age 60 or Older
                                   18901 A                   18 902 A          18 903

       tr                5          3922                     a3                                      1            F3

                                                    E lnterstate I                                                            n Safety Zone I        n Work Zone
 StatuteDescription(includethenameofstatute@EFTBYDEcEPTIoN
 A^r-
        ur Lr rE ('uuusEq assoclareo wlln m lS UITenSe: The defendant did intentionally obEined or withhold property
             -raL^           -
 ^uLD                                                                                                                            of another by deception. A person
 deceives if he/she intentionally fails to conect a false impression which the deceiver previously
                                                                                                   created or reinforced, o; which the deceiver knows to be
 influencing another to whom he stands in a fiduciary or confidential relationship.




                                                                                                     Number of Victims Age 60 or Older


   !                 6             3922                    a3                                    1              F3
                                                                                  PA Statute         Counts       G   )rade    NCIC Offens   Codr   UCR/NIBRS Code

                                                                                               E=;""*--l                  fl safety zone            fl Work Zone
statute Description (include the name of statute or ordinancel. cRrMra{AL @NsprRAcy


Theft By Dec€ption, ]-iue 18, section 3922(aX3), did agree with one or more other persons that they
                                                                                                      or one & more of them would engage in conduct whlch
constitutes a crime or did agree to aid such other person or peGons in the planning or commlssion
                                                                                                   of such crime or of an attempt or solicitation to commit
such crime, that is, between June of 2020 and september oi 2020, within tire counles of oauptrin,
                                                                                                   Cenm, cambri",- nn"yr"nia una                      Defendant
                                 that thev, or one or more of them, would engage in conduct cbnstinrting the crimi 6ir,"i oy oe."ption, in
                                                                                                                                       "tsewhere,
                                                                                                                                              viotation of rige
fld  :9f:^illl$ll^,19ividuals
r'6, ano ln pursuance  ot such conspiracy one or more overt acb were committed, in violation of Section 903 of the
                                                                                                                   crimes Code, re ea.c.s, gSO:.




AOPC 4AZA- Rev. TltS
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  Docket Number:
                                                                                                  ffi poltcE cRtMtNAL coMpLAtNT
     u- l?,-al                       Date Filed:

                                   First:
                                            l/
                                                                     OTN/LiveScan Number

                                                                         Middle:                                   Last:
                                                                                                                               ComplainUlncident Number
                                                                                                                               occ-20-0025
                                   JOHN                                  R                                         JONES




    tr      7           I :gzs                      a                                              1                 tr?
                                                                                                                     !J
   Lead?                                                                              fiile)           Counts              lrade    NCIC Offense   Code   UCR/N|BRS Code

                                                                                               E lnterstate                |     tr Safety Zone I         n Work Zone
 Statute Description (include the name of statute or orOinance): nrcErvrNc sroLEN pRopERTy


 Acts of the accused associated
 knowing that it had been stolen or believing that it has probably been stolen, unless the property is received, retained, or
                                                                                                                              disposed wiih inteni to restore it to
 the owner.




                   E Attempt                     E soticitation   I Conspiracy                          r.f   umUer of Victims Age 60 or Otder
                        18 901 A                    18 902 A          18 903                       I
    n        B           75L2                       a                                              1                  F3
     ad?     Offense#                                                                                  Counts              irade     NCIC Offense Codr    UCR/NIBRS Code

                                                      E lnterstate
 StatuteDescription(includethenameofstatuteo@MINALUsEoFAcoMMUNIcATIoNFAELIw
                                                                                                                           @                              n Work Zone


 Actsoftheaccusedassociatedwithtnisoffense:rrrtrrattire.aoovenameddefendantdid,onoiffi
 communicauon facility to commit, cause or.fucilitate the commission or the attempt thereof of any crime under this tide or
                                                                                                                            under the pA cont-olled substance,
 Drug, Device and Cosmetic Act 64-1972, all of which is in violauon ofthe liEe 18 pA CS
                                                                                         57512.




Acts of the accused associated with this Offense:




AOPC 4L2A - Rev. 7lL8                                                                                                                                       ease   {ot 13
                                                                & poltcE 6RIMINAL coMpLArNT
                                                                                OFFENSE CONTINUATION PAGE
  Docket Number:         Date Filed:            OTN/LiveScan Number                 Com plainUlncident Number
   cf- l1- Xl              lt                                                       occ-20-002s
                       First:                      Middle:                  Last;
                       JOHN                        R                        JONES

                                OFFENSE DESCRIPTION CONTINUATION

  Offense # 1:


 4.     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 acts of violation of the Chapter 49 of the Pennsylvania Crimes Code, including 1g pa. C.S.
                                                                                                                 A.
 54911,

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

 in violation of Section 911(bX3) of the Crimes Code, 18 pa.C.S.
                                                                   S911(bX3).




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  Docket Number:               Date Filed:                OTN/LiveScan Number
                                                                                   ffi poltcE cRtMtNAL coMpLAtNT
                                                                                                      Com plainUlncident Num ber
  U- l2r'?.1                 First:
                                      lt                                                              occ-20-0025
                                                             Middle:                          Last:
                            JOHN                             R                               JONES

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

     3. I verify that the facts set forth in this complaint are true and conect to the best of my knowledge or information and
        belief. This verification is made subject to the penalties of Section 4904 of the Crinies Cooe 11a pa.C.S. 4904) relating
                                                                                                                     S
        to unsworn falsification to authorities.

    4. This complaint consists of the preceding page(s) numbered 1 through
                                                                                       13.
    5. I certify that this filing complies with the provisions of the case Records Pubtic Access poticy of the Unified Judiciat
      System of Pennsylvan,a that require filing confidential information and documents differenflyihat non-confidential
      information and documents.

    The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth
    oJ Pennsylvania and were contrary to the Act(s) of the Assembly, orln violation of tne statuies iited.
    (Before a warrant of arrest can be issued, an affidavit of pr6bable cause must be comploted, 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,




             ll-A-o/
    (Magisterial District Cburt Number)

                                                                                                             /,:
                                                                                                             l,




                                                                                                                  "b




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    Docket Number:        Date Filed:            OTN/LiveScan Number
                                                                     ffi poLrcE cRTMINAL coMpLAtNT
                                                                                     Com plainUlncident Num ber
    b-/2-At             First:
                                 tt                                                  occ-20-a025
                                                    Middle:                  Last:
                        JOHN                        R                       JONES



                                        AFFIDAVIT of PROBABLE CAUSE
   OnMarch 27,2020, the CARES Act was signed inlo law, which included Title II, Subtitle A, "Relief for Workers
   Affected by Coronavirus Act." Section 2102 of the CARES Act created a tempomry 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 ttre 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 alt rights to such benefits. While the U.S. Deparhnent of

   Labor (USDOL) oversees the Pandemic Unemployment Assistanc€ @UA) program, the Pennsylvania Deparhrent
   of Labor & Industry administers the program in pennsylvania.


   PUA is only for individuals who are unemployed due to COVID-I9 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 ttre current pandemic.
  According to the Pennsylvania Deparhnent of Labor & Industry's website, the following groups axe explicitly
  defined as being ineligible to receive PUA: kmrates; 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 qualiff under
  regular Unemployment Compensation; Individuals living in a halfuay house on lock-down; and Landlords.
  Additionally, the Pennsylvania Department of Labor & Industry's website states that "Knowingly making false
  statements or omitting material facts to obtain PUA benefits to which you are not entitled will result in a
  disqualification and repayment of all overpaid PUA benefits. You may also be subject to criminal
  prosecution." On June 1,2020, Ttre Pa. Offrce of Attomey General received a referral letter from the Governor,s
  office referring investigation and prosecution ofPUA related fraud based upon the findings of an audit conducted
  by the Pa. Dept. of Labor & Industry.


  In June of 2020 tle Deparhnent of Conection identified possible PUA fraud involving inmates at SCI Rockview
  and other state corectional institutions. The Departrnent of Corrections identified Elise J. Ballard through prison
  inmale messages as possibly being part of the PUA fraud. The Departrnent 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.


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  Docket Number:.
                                                                     & polrcE cRTMTNAL coMpLArNT
   C-f- / L- ll
                           Date Filed:            OTN/LiveScan Number                Com plainUlncident Number
                                  tt                                                 occ-20-0025
                         First:                      Middle:                 Last:
                        JOHN                         R                       JONES



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


 Your affiant was aware of a pattern of recent fraud scheme from previous PUA fraud investigations that inmates
 were contacting individuals outside of the prison using the State Conectional 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 inmates 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 palrnents would be sent to the imate at the address provided on the application in the form of a US
Bank Debit card and ofl some occasion's actual checks from the PA Treasury. Once the PUA funds were received
money would be placed on the inmate's prison financial account "JPay" by the person receiving the firnds and the
person who submitted the application if different from the person who received tle 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 8/27120, 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 unemployrnent 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 unemployment for inmates. During
this conversation Ballard was sitting at a desk with a frrnctioning desktop computer. Ballard reached into the desk
drawer and handed your AfEant a US Bank Debit card in the 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 tfuew them away or misplaced them. Ballard agreed to go to the Johnstown Police Departrnent
to sit down and discuss her role in the PUA unemployment fraud. Ballard drove herself to the Johnstown police
Departrnent to be interviewed.



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  Docket Number:-          Date Filed:            OTN/LiveScan Number
                                                                      & poLrcE cRTMTNAL coMpLArNT
                                                                                      Com plainUlncident Number
    Lr- 12,-?'.l                  lt                                                  occ-20 -oo2s
                         First:                      Middle:                  Last:
                         JOHN                        R                        JONES

 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 brothers, and several good friends in state
 correctional facilities. Ballard stated that Robert Palmer is her boyfriend and 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 unde$tood that filing 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 nrunerous applications
 for numerous inmates and 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 tle money on inmate accounts
through the prison JPay accounts and sent larger amounts to inmates through MoneyGram. BaIIard was shown
                                                                                                                     her
communications with inmates and admitted that she had exchanged the messages and information for other
inmates dwing 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.
Ballmd 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. Ballard reported tlat her home intemet was tluough
Atlantic Broadband and that the accou.nt was in her name or in Robert palmer's name.


Your Affiant's reviewed the Departrnent of Corrections inmate financial JPay accormts 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 inmate accounts in June, July and August of 2020. The deposits into the inmate accounts
coincided with the PUA payments placed on the debit cards for tlose inmates. The Jpay system identifies t11e
narne 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 138.207.247.124.


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



AOPC 4I,2A- Rev. T|LS
                                                                                                                  ;.g"Y"rd
                                                                           POLICE CRIMINAL COMPLAINT
  Docket Number:           Date Filed:           OTNlLiveScan Number
   C-r- l),-   II        First:
                                lt
                                                                                    Com plainUlncident Num ber
                                                                                    occ-?o-aa?s
                                                    Middle:                 Last:
                         JOHN                       R                       JONES

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


 Your Affiant's requested additional information from the PA Departrnent of Labor and Industry, specific to Elise
 Ballard. Labor and Industry was able to search for tle narnes of the inmates associated with Ballard,
                                                                                                 applications
 completed with similar IP addresses associated with Ballard, and for addresses associated with Ballard. The
 Department of Labor and Industry found 42 names associated with the search criteria related to
                                                                                                    Elise Ballard; 31
 of the PUA applications were completed using IP address 138.207 .247.124. Your Affiant conducted a
                                                                                                           search and
 determined that IP address 138.207.247.124 is owned by Atlantic Broadband. A search of Atlantic Broadband
 records deterrnined that IP address 138.207.247.124 belonged to subscriber Robert palmer at 718 Linden
                                                                                                             Avenue,
 Johnstown, PA.


As a result of the search by the Deparhnent ofLabor and [ndushy, 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. Robert Palmer provided 20 of tlle names and those 20 names totaled
$148,247.00 in PUA funds issued. John Jones provided 10 of the names and those 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 the debit card in the possession of Elise Ballard on 8/27 /20. 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 frurds. The total for a]l the pUA funds
                                                                                                           associated
with the 31 PUA applications completed by Ballard was $226,0L2.00.


The Perursylvania Offrce of Attomey General contacted the Pennsylvania Department of Labor aad
                                                                                                        Industry and
requested the application and payment infomration regarding Robert E. Palmer and John R.
                                                                                             Jones pUA claims.


The Pennsylvania Department of Labor and Industry records show that Robert palmer had an application
                                                                                                            for PUA
subrnitted on June 11,2020. On the application it was reported that palmer,s last day of employment
                                                                                                                   was

AOPC 4L2A - Rev. 7 lLg
                                                                                                                 Page   Aot !_3
  Docket Number:            Date Filed:           OTN/LiveScan Number
                                                                      # polrcE cRTMTNAL coMpLArNT
                                                                                      Com plainUlncident Number
   Or tT-al                        lt                                                 occ-20-0025
                          First:                     Middle:                  Last:
                          JOHN                       R                        JONES

 12/1/2019. Your Affiant notes that Palmer was incarcerated on the date his application was submitted.
 Additionatly, records show that Palmer's application was submitted by an individual using the address 718 Linden
 Ave, Johnstown, PA. Pennsylvania State Correctional Institution records show that Robert Palmer has been
 incarcerated in SCI Huntingdon from I l/1/16 thru present.


The Pennsylvania Deparftnent of Labor and Industry also provided information regarding PUA payrnents made to
Robert E. Palmer. Records show that Palmer received payments on 6112120 (check), 6t17120 (debit card), 6120120
(debit card), 6123120 (debit cafi), 6/29/20 (debit card), 719120 (debit card), and 7ll5l20 (debit card). The rotal for
all the palments was $t 5,660.00. The payments were from the last day of work listed on Palmer's application to
present. These payments directly coincide with the time that 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
Pennsylvania Deparhnent of Labor and Industry records show that Palrner'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 6113/20, 6ll6D0, 6119120, 6123/20,6127120,7121120,7130120,813/20, and 8t3t/20. The total amount
deposited, on Robert Palmer's 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 oflabor and Industry records show that John R. Jones had an application for PUA
submitted on June 12, 2020. On the application it was reported that Jones last day of employm ent wx 12t2912019.
Your AfEant notes that Jones was incarcerated on the date his application was submitted. Additionally, records
show that Jones application was submitted by an individual using the address 718 Linden Ave, Johnstown, pA.
Pennsylvania State Correctiona.l Institution records show that John R. Jones has been incarcerated in SCI
Rockview from 2 17 / 17 lla:u present.




AOPC 4tZA- Rev. 7lLB                                                                                              easell of 13
                                                                         ffi polrcE cRTMTNAL coMpLArNT
  'ff!.i[lTr               Date Filed:
                                lt
                                                   OTN/LiveScan Number                   Com plainUlncident Number
                                                                                         occ-20-oo2s
                         First:                       Middle:                    Last.
  Defendant Name:
                         JOHN                         R                          JONES

 The Pennsylvania Deparknent of Labor and lndustry also provided information regarding the payments
                                                                                                                     made to
 Jones. Records slrow that Jones received payments on 6113/20 (check), 6/23/20 (debit card),
                                                                                                     6/29/20 (debit card),
 a:ard 7 /15120 (debit card). The total for all the payments was
                                                                   $21,630.00. The pal,rnents were from the last day of
 work listed on Jones application to present. These palments directly coincide with the time that Jones was
 incarcerated at SCI Rockview. The PUA pal,rnents were made using check and a US Bank pre-paid
                                                                                                              debit card with
 the last four numb erc 1629. The Pennsylvania Departunent 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 scl Rockview inmate money account "Jpay" showed that Palmer received money on his account from
                                                                                                                       Elise
 Ballard on 6123/2a, 6D6120, 6127/20,717120, and 7125120. 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 lll17l20, your AfEants traveled to Johnstown, PA and conducted a second interview of Elise Ballard at 71g
Linden Ave., Johnstown, PA.


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



Ballard was questioned about the additional names and applications reported by the Department of Labor
                                                                                                                        and
Industry. Ballard admitted to completing all the applications from the list of 31 pUA applications. Ballard
                                                                                                                      stated
that she personally received 24 of the PUA US Bank debit cards that wele sent to Johnstown addresses. Ballard
stated that she used her address and friends addresses in Johnstown to get tlle debit cards. Ballard
                                                                                                          stated that the
debit cards mailed to other cities were sent to the individual inmate's families and she had no frrther
                                                                                                      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

ffi--i-._..__-_--                                                                                                               rs
                                                                     & poLrcE cRTMTNAL GoMpLATNT
   u-l\-\1
  Docket Number:            Date Filed:

                          First:
                                   l/
                                                   OTN/LiveScan Number

                                                     Middle:                 Last:
                                                                                     ComplainUlncident Number
                                                                                     occ-20 -002s
                          JOHN                       R                       JONES

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

 people out".




I, SA CHRIS WEAVER/SA KATIE GRADY, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY
THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECITO THE BEST OF MY
KNOWLEDGE, INFORMATION AND BELIEF.

I CERTIFY THAT THIS FILING COMPLIES WTH THE PROVISIONS OF THE CASE RECORDS PUBLIC ACCESS
POLICY OF THE UNIFIED JUDICIAL SYSIE/U OF PEA"VSYLVANIAIHAT REQUIRE FILING CONFIDENTIAL
INFORMATION AND DOCUMENTS DIFFERENTLY THAT NON-CONFIDE                       INFORMATION AND DOCUMENTS.




                                                                                     (Signature of

Sworn to me and subscribed befo                          day of

                   Date

My commission expires first Mon           u,ry'
                                                  ?clz

AOPC 4LZA- Rev. TlLS                                                                                            Pasei3 otl]


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