Superseding Indictment, United States v. Allison and Blevins (Eastern District of Tennessee, June 27, 2023)

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A grand jury Superseding Indictment filed June 27, 2023 as Document 12 in United States v. Randa Allison and Evelyn Blevins, No. 1:23-cr-00044-CLC-MJD, in the U.S. District Court for the Eastern District of Tennessee. Count One charges Randa Allison with mail fraud under 18 U.S.C. § 1341 over false unemployment insurance claims that caused approximately $100,225.00 in debit cards to be distributed, including a $23,454.00 debit card mailed from the Pennsylvania Department of Labor and Industry. Count Two charges both defendants with conspiracy to commit wire fraud and mail fraud under 18 U.S.C. §§ 1349, 1343 and 1341, and Count Three charges Evelyn Blevins with wire fraud under 18 U.S.C. § 1343 for a scheme from about June 2020 to August 2021. The forfeiture allegations seek personal money judgments of $100,225.00 against Allison and $109,683.00 against Blevins.

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Sy 9
UNITED STATES DISTRICT COURT Sag th uy. ? Les
EASTERN DISTRICT OF TENNESSEE ©” Oise: ise,
AT CHATTANOOGA Acpant or Cour
UNITED STATES OF AMERICA )
) 1:23-cr-44
V. )
) Judge Collier/Lee
RANDA ALLISON )
EVELYN BLEVINS )

SUPERSEDING INDICTMENT

COUNT ONE
MAIL FRAUD
(18 U.S.C. § 1341)

THE GRAND JURY CHARGES THAT:

AT ALL TIMES MATERIAL HEREIN:

1. The defendant, RANDA ALLISON, at all times relevant to the dates in this
Indictment, was a resident of Stevenson and Bridgeport, Alabama.
2. Facts relating to COVID-19:

a. In December 2019, a novel coronavirus, SARS-CoV-2 (the “coronavirus’’), was
first detected in Wuhan, Hubei Province of the People’s Republic of China (“PRC”), causing
outbreaks of the coronavirus disease COVID-19 that have since spread globally. On January
31, 2020, the Secretary of Health and Human Services (“HHS”) declared a national public health
emergency under 42 U.S.C. § 247d as a result of the spread of COVID-19 to and within the
United States. On March 11, 2020, the Director-General of the World Health Organization
(“WHO”) characterized COVID-19 as a pandemic. On March 13, 2020, the President of the

United States issued Proclamation 9994 declaring a national emergency beginning on March 1,

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2020, as a result of the rapid spread of COVID-19 within the United States.

b. Unemployment Insurance System: The Social Security Act of 1935 initiated the
unemployment insurance (“UI”) system. UI payments were intended to provide temporary
financial assistance to lawful workers who were unemployed through no fault of their own.
Beginning in or around March 2020, in response to the COVID-19 pandemic, several federal
programs expanded UI eligibility and increased UI benefits. The UI system is administered for
the federal government by the state employment offices, and each state administrates a separate
unemployment benefits program under guidelines established by federal law.

1) In the State of Tennessee, the agency responsible for overseeing the
disbursement of unemployment insurance is the Tennessee Department of
Labor and Workforce Development (“TNLWD”) which administers the
unemployment benefits system on behalf of the federal government,
specifically the United States Department of Labor (“DOL”). The DOL
funds all substantive and administrative costs for the TNLWD.

2) In order to qualify for unemployment insurance, an applicant must complete
an online application on TNLWD’s website with the applicant’s name, date of
birth, social security number, and other personal information. The applicant
can then file for weekly benefits by certifying online that he/she is
unemployed and eligible for benefits.

3) Other states, such as Pennsylvania, California, and Alabama, likewise provide
unemployment insurance to their citizens in a similar fashion. In the State of

Pennsylvania, the agency responsible for program oversight is the

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Pennsylvania Department of Labor and Industry, (PADOL). In the State of

California, the agency responsible for program oversight is the California

Employment Development Department (CAEDD). In the State of Alabama,

the agency responsible for program oversight is the Alabama Department of

Labor, (ADOL).

c. Federal Cares Act: On March 27, 2020, the Coronavirus Aid, Relief, and

Economic Security (CARES) Act was passed by Congress and signed into law by President
Donald J. Trump. The CARES Act included an economic relief package in excess of $2 trillion
designed to help the American people during the public health and economic crises related to the
pending coronavirus (““COVID-19”) pandemic. The CARES Act provides for three new types
of unemployment benefits:

1) The Pandemic Unemployment Assistance (“PUA”) program is a separate
benefit program designed to cover many people who do not qualify for regular
unemployment during the COVID-19 pandemic. This includes self-employed
individuals, independent contractors, and part-time workers affected by
COVID-19.

2) The Pandemic Emergency Unemployment Compensation (“PEUC”) program
is an extension of regular unemployment benefits that offers unemployment
benefits up to thirteen (13) weeks beyond the number of weeks available from
regular unemployment. The CARES Act made these PEUC benefits
available to the unemployed between March 29, 2020, and December 26,

2020.
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3) The Federal Pandemic Unemployment Compensation (“FPUC”) program
provides an extra $600 per week in addition to regular or PUA unemployment
payments between March 29, 2020 and July 25, 2020. The FPUC is available
for everyone on regular unemployment or PUA, except those on training
benefits.

d. Inthe State of Pennsylvania, the PADOL, based in Harrisburg, Pennsylvania,
administered the UI program. Those seeking UI benefits submitted online applications.
Applicants had to answer specific questions to establish eligibility to receive UI benefits,
including their name, Social Security Number (SSN), and mailing address, among other things.
Applicants also had to self-certify that they met a COVID-19-related reason for being
unemployed, partially employed, or unable to work. The PADOL relied upon the information in
the application to determine UI benefits eligibility. Once an application was approved, the
PADOL typically distributed state and federal UJ benefits electronically to a debit card, which
claimants could use to withdraw funds and/or make purchases. These debit cards were sent via
the U.S. Postal Service or by a private and commercial interstate carrier to the address the
claimant provided. Claimants could activate their debit card via telephone or online.

e. Inthe state of California, the CAEDD, based in Sacramento, California,
administered the UI program. Those seeking UI benefits submitted online applications.
Applicants had to answer specific questions to establish eligibility to receive UI benefits,
including their name, Social Security Number (SSN), and mailing address, among other things.
Applicants also had to self-certify that they met a COVID-19-related reason for being

unemployed, partially employed, or unable to work. The CAEDD relied upon the information

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in the application to determine UI benefits eligibility. Once an application was approved, the
CAEDD typically distributed state and federal UI benefits electronically to a debit card, which
claimants could use to withdraw funds and/or make purchases. These debit cards were sent via
the U.S. Postal Service to the address the claimant provided. Claimants could activate their
debit card via telephone or online.

f. Inthe State of Alabama, the ADOL, based in Montgomery, Alabama,
administered the UI program. Those seeking UI benefits submitted online applications.
Applicants had to answer specific questions to establish eligibility to receive UI benefits,
including their name, Social Security Number (SSN), and mailing address, among other things.
Applicants also had to self-certify that they met a COVID-19-related reason for being
unemployed, partially employed, or unable to work. The ADOL relied upon the information in
the application to determine UI benefits eligibility. Once an application was approved, the
ADOL typically distributed state and federal UI benefits electronically to a debit card, which
claimants could use to withdraw funds and/or make purchases. These debit cards were sent via
the U.S. Postal Service or by a private and commercial interstate carrier to the address the
claimant provided. Claimants could activate their debit card via telephone or online.

g. The Tennessee State UI Trust Fund is maintained by the US Treasury at the
Federal Reserve Bank. Funds collected for Unemployment Insurance benefits payments are
deposited into Bank of America, located in Nashville, TN and then wired to the Bank of America
in New York, on behalf of the US Treasury. They are transferred from Bank of America to the
Federal Reserve Bank. The Tennessee Department of Labor and Workforce Development

(TLWED) requests funds daily, from the US Treasury, via the Automated Standard Application
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for Payments (ASAP) system. Upon request, the funds are wired from the Federal Reserve Bank
to the TLWFD paying account at First Horizon Bank, located in Nashville, TN. First Horizon
Bank then distributes the benefits payments electronically, through direct deposit or to a debit
card, as requested by the recipient.

THE SCHEME TO DEFRAUD:

3. Beginning in or about June 2020, and continuing until in or about June,

2021, in the Eastern District of Tennessee and elsewhere, the defendant. RANDA ALLISON,
aided and abetted by others, devised and intended to devise a scheme and artifice to defraud the
government of the United States, governments of various states, and others, and to obtain money
and property by means of false and fraudulent pretenses, representations and promises. The
scheme and artifice to defraud and to obtain money so devised and intended to be devised by the
defendant was in substance as follows:

4. It was part of the scheme to defraud that beginning in or about June 2020, the
defendant, RANDA ALLISON, coordinated with others who had knowledge about making false
submissions to various states’ UI programs and worked with them to create a system to make
mass false UI claims to those states.

5. It was further part of the scheme to defraud that between in or about June 2020, and
June 2021, the defendant, RANDA ALLISON, obtained the personal information of other
individuals with which to make false UI claims in various states. In some instances, the
defendant obtained the permission of these individuals to file claims using their information; in
other instances she filed the individuals’ information without their permission.

6. It was further part of the scheme to defraud that beginning in or about June 2020, the

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defendant, RANDA ALLISON, aided and abetted by others, utilized a personal computer located
in Alabama to submit false UI claims in the defendant, RANDA ALLISON’s name to the state
of Tennessee.

7. Jt was further part of the scheme to defraud that between in or about June 2020, and
June 2021, the defendant, RANDA ALLISON, in the Eastern District of Tennessee and
elsewhere, worked with others to submit false claims. Specifically, the defendant, RANDA
ALLISON, aided and abetted by others, utilized a personal cellphone or computer to submit false
UI claims in various names to the states of Pennsylvania, Alabama, and Tennessee.

8. It was further part of the scheme to defraud that between in or about June
2020 and June 2021, the defendant, RANDA ALLISON, aided and abetted by others,
submitted false UI claims to various states on behalf of individuals she knew did not
qualify for such benefits, and caused to be distributed approximately $100,225.00 in debit
cards to parties in the Eastern District of Tennessee and elsewhere who were not entitled to

receive the claims.

THE EXECUTION:

Beginning on or about June 21, 2020, and continuing until on or about June 25, 2020, in
the Eastern District of Tennessee and elsewhere, the defendant, RANDA ALLISON, having
devised and intended to devise a scheme to defraud, and for the purpose of obtaining money and
property by means of false and fraudulent pretenses, representations and promises, knowingly
caused to be delivered by mail and by private and commercial interstate carrier to the place in the
Eastern District of Tennessee at which the defendant directed it to be delivered in connection

with the following transaction:

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COUNT DATE AMOUNT DESCRIPTION_ | CONTENT OF
OF MAIL MAIL

| On or about June | $23,454.00 Mailing caused by | Unemployment

22, 2020 defendant Insurance Claim

ALLISON from Debit Card
PADOL to PM in
the Eastern
District of
Tennessee.

The violation occurred in relation to and involving a benefit authorized, transported, transmitted,
transferred, disbursed, and paid in connection with a presidentially declared major disaster and

emergency.

All in violation of Title 18 United States Code, Sections 1341 and 2.

COUNT TWO
CONSPIRACY TO COMMIT WIRE FRAUD AND MAIL FRAUD
(18 U.S.C. §§ 1349, 1343 AND 1341)

THE GRAND JURY FURTHER CHARGES THAT:

The Grand Jury re-alleges and incorporates by reference the above paragraphs of this
Indictment as if fully set forth herein. From in or about June 2020 and continuing until in or
about June 2021, in the Eastern District of Tennessee and elsewhere, the defendants, RANDA
ALLISON, EVELYN BLEVINS, and others known and unknown to the Grand Jury, did
combine, conspire, confederate, and agree with one another to commit the following offenses:

A. They knowingly devised and intended to devise a scheme and artifice to defraud another
by means of false and fraudulent pretenses and for obtaining money by means of false

and fraudulent pretenses, representations, and promises, and for the purpose of executing

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the scheme and artifice and attempting to do so, did cause mail matter to be delivered to
and from the Eastern District of Tennessee by mail and by private and commercial
interstate carrier, in violation of Title 18, United States Code, Section 1341; and
B. They knowingly devised and intended to devise a scheme to defraud, and for the purpose
of obtaining money and property by means of false and fraudulent pretenses,
representations and promises, and for the purpose of executing the scheme and artifice
and attempting to do so, did transmit and cause to be transmitted to and from the Eastern
District of Tennessee by interstate wire communication in interstate commerce, writings,
signs, signals, pictures, and sounds for the purpose of executing such scheme and artifice
to defraud others, in violation of Title 18, United States Code, Section 1343.
The conspiracy occurred in relation to and involving a benefit authorized, transported,
transmitted, transferred, disbursed, and paid in connection with a presidentially declared major
disaster and emergency.
All in violation of Title 18, United States Code, Section 1349, 1341, and 1343.
COUNT THREE

WIRE FRAUD
(18 U.S.C. § 1343)

The Grand Jury re-alleges and incorporates by reference the above paragraphs of this

Indictment as if fully set forth herein.
1. The defendant, EVELYN BLEVINS, at all times relevant to the dates in this
Indictment, was a resident of South Pittsburg, Tennessee.

THE SCHEME TO DEFRAUD:

2. Beginning in or about June 2020, and continuing until in or about August 2021, in the

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Eastern District of Tennessee and elsewhere, the defendant, EVELYN BLEVINS, aided and
abetted by others, devised and intended to devise a scheme and artifice to defraud the
government of the United States, governments of various states, and others, and to obtain money
and property by means of false and fraudulent pretenses, representations and promises. The
scheme and artifice to defraud and to obtain money so devised and intended to be devised by the
defendant was in substance as follows:

3. It was part of the scheme to defraud that beginning in or about July 2020, the
defendant, EVELYN BLEVINS, coordinated with others who had knowledge about making
false submissions to various states’ UI programs and worked with them to create a system to
make mass false UI claims to those states.

4. It was further part of the scheme to defraud that between in or about July 2020, and
August 2021, the defendant, EVELYN BLEVINS, obtained the personal information of other
individuals with which to make false UI claims in various states. In some instances, the
defendant obtained the permission of these individuals to file claims using their information; in
other instances she filed the individuals’ information without their permission.

5. It was further part of the scheme to defraud that beginning in or about July 2020, the
defendant, EVELYN BLEVINS, aided and abetted by others, utilized a personal computer
located in the Eastern District of Tennessee to submit false UI claims in various names to the
states of Pennsylvania, California, and Tennessee.

6. It was further part of the scheme to defraud that in or about July 2020, the
defendant, EVELYN BLEVINS worked together with M.P. in the Eastern District of Tennessee

and elsewhere to submit false UI claims to the states of Pennsylvania, California, and Tennessee.

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7. It was further part of the scheme to defraud that between in or about June 2020,
and August 2021, in the Eastern District of Tennessee and elsewhere, the defendant,
EVELYN BLEVINS, utilized a personal cellphone and computer to submit false UI claims
in various names to the states of Pennsylvania, California and Tennessee.

8. It was further part of the scheme to defraud that between in or about June
2020 and August 2021, the defendant, EVELYN BLEVINS, submitted false UI claims to
various states and caused to be distributed approximately $109,683.00 in debit cards to
parties who were not entitled to receive the claims.

THE EXECUTION:

Beginning in or about June 2020, and continuing until in or about August 2021, in the
Eastern District of Tennessee and elsewhere, the defendant, EVELYN BLEVINS, having
devised and intended to devise a scheme to defraud, and for the purpose of obtaining money and
property by means of false and fraudulent pretenses, representations and promises, did transmit
and cause to be transmitted by interstate wire communication in interstate commerce, writings,
signs, signals, pictures, and sounds for the purpose of executing such scheme and artifice to

defraud others, and attempting to do so, in connection with the following transaction:

COUNT DATE AMOUNT DESCRIPTION_ | CONTENT OF
OF WIRE WIRE
3 07/29/2020 $15,015.00 Online submission |} Unemployment

to CAEDD from Insurance Claim
defendant Blevins

in the name of
ER.

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The violation occurred in relation to and involving a benefit authorized, transported, transmitted,
transferred, disbursed, and paid in connection with a presidentially declared major disaster and
emergency. All in violation of Title 18 United States Code, Sections 1343 and 2.

COUNT FOUR

AGGRAVATED IDENTITY THEFT
(18 U.S.C. § 1028A)

The United States Attorney re-alleges and incorporates by reference the above paragraphs
of this Indictment as if fully set forth herein. On or about the date set forth below in the Eastern
District of Tennessee and elsewhere, the defendant, EVELYN BLEVINS, aided and abetted by
others, did knowingly transfer, without lawful authority, means of identification of another
person during and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), that is,
wire fraud (18 U.S.C. § 1343), knowing that the means of identification belonged to another
actual person, in violation of Title 18, United States Code, Section 1028A(a)(1):

Count On or about: Description of stolen transferred means of identification:

4 July 29, 2020 Online Unemployment Insurance Claim to PADOL from
defendant Blevins using the name and personal information of SF

All in violation of Title 18, United States Code, Section 1028A(a)(1) and 2.

[FORFEITURE ALLEGATIONS ON FOLLOWING PAGE]
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FORFEITURE ALLEGATIONS

1, The allegations contained in Counts One through Three of this Indictment are
hereby realleged and incorporated by reference for the purpose of alleging forfeiture pursuant to
Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section
2461(c).

2. Pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28,
United States Code, Section 2461(c), upon conviction of an offense in violation of Title 18,
United States Code, Sections 1341, 1343, and 1349, the defendants, RANDA ALLISON and
EVELYN BLEVINS, shall forfeit to the United States of America, any property, real or
personal, which constitutes or is derived from proceeds traceable to the offense. The properties
to be forfeited include, but are not limited to, the following:

a. A personal money judgment in the amount of $100,225.00 in favor of the United
States and against the defendant, RANDA ALLISON, which represents the
proceeds the defendant personally obtained as a result of an offense in violation of
Title 18, United States Code, Sections 1341 and 1349.

b. A personal money judgment in the amount of $109,683.00 in favor of the United
States and against the defendant, EVELYN BLEVINS, which represents the
proceeds the defendant personally obtained as a result of an offense in violation of
Title 18, United States Code, Section 1343 and 1349.

3. Pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title
28, United States Code, Section 2461(c), the defendants, RANDA ALLISON and EVELYN
BLEVINS, shall forfeit substitute property, up to the value of the property subject to forfeiture, if
by any act or omission of any of the defendants, said property, or any portion thereof:

a. cannot be located upon the exercise of due diligence;

b. has been transferred, sold to, or deposited with a third party;

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ei. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or
S has been commingled with other property that cannot be divided without
difficulty.
A TRUE BILL.

Francis M. Hamilton, III
United States Attorney

Steven S. Neff .
Assistant U.S. Attorney

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