IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND * * * * * ****** INDICTMENT. COUNT ONE (Wire Fraud)

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1 TLF:2016R00326 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA v. Defendant. CRIMINAL NO. (Wire Fraud, 18 U.S.C. 1343, False use of Passport, 18 U.S.C. 1543, Aiding & Abetting, 18 U.S.C. 2, Forfeiture, 18 U.S.C. 981(a)(1)(C); 21 U.S.C. 853; and 28 U.S.C. 2461(c) INDICTMENT COUNT ONE (Wire Fraud) The Grand Jury for the District of Maryland charges that: From on or about August 18, 2015 through on or about August 8, 2016, in the District of Maryland and elsewhere: 1. Defendant a/k/a Marie Joy Steffan- Tanamor, a/k/a Marie Joy Acibo Tanamor (hereinafter TANAMOR-STEFFAN ) was a resident of Baltimore City. 2. Defendant TANAMOR-STEFFAN had no regular employment but occasionally picked up odd jobs with a cleaning service. 3. Victoria s Secret is and was a chain of retail store specializing in high-end women s lingerie and other clothing, with locations across the United States, including in Maryland, Virginia, Delaware, Pennsylvania, and the District of Columbia. 1

2 4. Victoria s Secret allowed customers to exchange merchandise or return merchandise for store credit without a receipt. Such transactions required use of a valid identification, such as a state identification card or driver s license, or a passport issued by any country. In order to process an exchange or return for store credit without a receipt, the identification number (such as the driver s license number or passport number) was entered into Victoria s Secret s system. A customer could only receive $300 in non-receipted exchanges (or returns for store credit) in a 90-day period. Such transactions were processed through servers located in Victoria s Secret s home office in Columbus Ohio. 5. Victoria s Secret would allow returns for refund with a receipt for the merchandise. All such transactions were also conducted through servers located in Victoria s Secret s home office in Columbus, Ohio. Receipt information was transmitted via the internet to the servers located in Columbus Ohio, and once the receipt data is verified, approval for the refund was transmitted via the internet back to the store location, where the authorized refund was processed. 6. Defendant TANAMOR-STEFFAN was prohibited from entering into Victoria s Secret stores. Manner and Means of the Scheme and Artifice to Defraud 7. It was part of the scheme and artifice to defraud that Defendant TANAMOR- STEFFAN would shoplift items from Victoria s Secret Stores in Maryland, Virginia, and other states. 8. It was further part of the scheme and artifice to defraud that Defendant TANAMOR-STEFFAN would enter another Victoria s Secret Store to conduct a non-receipted exchange of the items that she had shoplifted for other items costing slightly more in total. 2

3 9. It was further part of the scheme and artifice to defraud that Defendant TANAMOR-STEFFAN would present a Philippine passport as her identification for the nonreceipted exchange, but would alter the passport number for each exchange to avoid triggering a denial for having conducted too many such exchanges within a 90-day period. 10. It was further part of the scheme and artifice to defraud that Defendant TANAMOR-STEFFAN would pay for the additional amount due on the non-receipted exchange with her debit card, and receive a receipt for the transaction showing the debit card payment. 11. It was further part of the scheme and artifice to defraud that Defendant TANAMOR-STEFFAN would return the items she had obtained in the non-receipt exchange, with the refund being credited to the debit card she had used for the earlier non-receipted exchange. defendant, The Charge 12. On or about July 1, 2016, in the District of Maryland and elsewhere, the having devised and intending to devise a scheme and artifice to defraud and for obtaining money and property by means of materially false and fraudulent pretenses, representations and promises, transmitted and caused to be transmitted by means of wire, radio and television communication in interstate and foreign commerce a writing, sign, signal, picture and sound for the purpose of executing such scheme and artifice, to wit: Defendant exchanged previously shoplifted items at the Victoria s Secret Store in Towson Mall, Towson, Maryland using a Filipino Passport bearing the altered number , in a transaction in which she paid an additional $24.46, and then returned those items at a Victoria s Secret Store in Prince George s Mall in Hyattsville, Maryland, 3

4 presenting a Filipino Passport bearing the altered number BB , receiving a credit of $ to her BB&T debit card ending U.S.C. ' U.S.C. '2 4

5 COUNT TWO (Wire Fraud) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs one 1 through 11 of Count One of the Indictment are incorporated by reference as if fully set forth herein. defendant, 2. On or about August 5, 2016, in the District of Maryland and elsewhere, the having devised and intending to devise a scheme and artifice to defraud and for obtaining money and property by means of materially false and fraudulent pretenses, representations and promises, transmitted and caused to be transmitted by means of wire, radio and television communication in interstate and foreign commerce a writing, sign, signal, picture and sound for the purpose of executing such scheme and artifice, to wit: Defendant exchanged previously shoplifted items at the Victoria s Secret Store in Hyattsville, Maryland using a Filipino Passport bearing the altered number BB , in a transaction in which she paid an additional $23.14, and then returned those items at a Victoria s Secret Store in Alexandria, Virginia, presenting a Filipino Passport bearing the altered number , receiving a credit of $ to her BB&T debit card ending U.S.C. ' U.S.C. '2 5

6 COUNT THREE (Wire Fraud) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs one 1 through 11 of Count One of the Indictment are incorporated by reference as if fully set forth herein. 2. Between or about May 1, 2016, through on or about May 6, 2016, in the District of Maryland and elsewhere, the defendant, having devised and intending to devise a scheme and artifice to defraud and for obtaining money and property by means of materially false and fraudulent pretenses, representations and promises, transmitted and caused to be transmitted by means of wire, radio and television communication in interstate and foreign commerce a writing, sign, signal, picture and sound for the purpose of executing such scheme and artifice, to wit: Defendant exchanged previously shoplifted items at the Victoria s Secret Store in Gallery Harbor Mall in Baltimore, Maryland in a transaction in which she paid an additional $52.31, and then returned those items at a Victoria s Secret Store in Towson Mall in Towson, Maryland, presenting a Filipino Passport bearing the altered number BB , receiving a credit of $ to her BB&T debit card ending U.S.C. ' U.S.C. '2 6

7 COUNT FOUR (Wire Fraud) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs one 1 through 11 of Count One of the Indictment are incorporated by reference as if fully set forth herein. defendant, 2. On or about August 10, 2016, in the District of Maryland and elsewhere, the having devised and intending to devise a scheme and artifice to defraud and for obtaining money and property by means of materially false and fraudulent pretenses, representations and promises, transmitted and caused to be transmitted by means of wire, radio and television communication in interstate and foreign commerce a writing, sign, signal, picture and sound for the purpose of executing such scheme and artifice, to wit: Defendant returned merchandise, which she had previously exchanged for shoplifted items, at the Victoria s Secret Store in Arundel Mills Mall in Hanover, Maryland using a Filipino Passport bearing the altered number BB , receiving credits of $ and $ to her BB&T debit card ending U.S.C. ' U.S.C. '2 7

8 COUNT FIVE (Wire Fraud) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs one 1 through 11 of Count One of the Indictment are incorporated by reference as if fully set forth herein. defendant, 2. On or about July 26, 2016, in the District of Maryland and elsewhere, the having devised and intending to devise a scheme and artifice to defraud and for obtaining money and property by means of materially false and fraudulent pretenses, representations and promises, transmitted and caused to be transmitted by means of wire, radio and television communication in interstate and foreign commerce a writing, sign, signal, picture and sound for the purpose of executing such scheme and artifice, to wit: Defendant exchanged previously shoplifted items and returned previously exchanged items at the Victoria s Secret Store in White Marsh Mall, White Marsh, Maryland using a Filipino Passport bearing the altered number BB , receiving a credit of $ to her BB&T debit card ending U.S.C. ' U.S.C. '2 8

9 COUNTS SIX & SEVEN (Wire Fraud) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs 1 and 2 of Count One of the Indictment are hereby incorporated by reference as though fully set forth herein. 2. Home Depot is and was a retail home improvement store, with locations across the United States, including in Maryland. 3. Home Depot allows customers to return merchandise for a refund with a receipt. Receipt information is transmitted via the internet to the servers located in Austin, Texas. Once the receipt data is verified, approval for the refund is transmitted via the internet back to the store location, where the authorized refund is processed. At the same time, a back-up of the transaction information is transmitted over the internet to company servers in Atlanta, Georgia, where it is stored. Manner and Means of the Scheme and Artifice to Defraud 4. It was part of the scheme and artifice to defraud that Defendant TANAMOR- STEFFAN would enter a Home Depot location with a receipt for Home Depot merchandise, but without the merchandise. 5. It was part of the scheme and artifice to defraud that Defendant TANAMOR- STEFFAN would selected the items on the receipt from the inventory in the store and return to customer service. 6. It was further part of the scheme and artifice to defraud that Defendant TANAMOR-STEFFAN would return the items she had just selected but had not purchased, using a receipt showing the purchase of the same items. The amount refunded would be credited to her BB&T account. 9

10 defendant, The Charge 7. On or about the dates listed below, in the District of Maryland and elsewhere, the having devised and intending to devise a scheme and artifice to defraud and for obtaining money and property by means of materially false and fraudulent pretenses, representations and promises, transmitted and caused to be transmitted by means of wire, radio and television communication in interstate and foreign commerce a writing, sign, signal, picture and sound for the purpose of executing such scheme and artifice, to wit: Defendant conducted the following fraudulent returns of stolen merchandise, causing wire communications with Home Depot s servers in Austin, Texas, and Atlanta, Georgia, and resulting in credits to her BB&T debit card ending 1507 on the dates and in the amounts set forth below: Count Date Amount Store Location Six 1/10/16 $ Bethesda, Maryland Seven 3/2/16 $ Bethesda, Maryland 18 U.S.C. ' U.S.C. 2 10

11 COUNT EIGHT (Passport Fraud) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs 1 through 11 of Count One of the Indictment are hereby incorporated by reference as though fully set forth herein. 2. From on or about August 18, 2015 through on or about August 8, 2016, in the District of Maryland and elsewhere, the defendant, did falsely mutilate and alter a passport with the intent that the passport may be used, and willfully and knowingly used and attempted to use a false, mutilated and altered passport, to wit, Defendant repeatedly altered two Filipino passports validly issued to her to change the passport numbers and then used the altered passports as part of the wire fraud conspiracy charged in Counts One through Five of the Indictment. 18 U.S.C U.S.C. 2 11

12 FORFEITURE 1. The allegations contained in Counts One through Seven of this Indictment are incorporated here for the purpose of alleging forfeitures pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c). 2. Upon conviction of the offenses in violation of Title 18, United States Code, Section 1343 set forth in Counts One through Seven of this Indictment, the defendant, shall forfeit to the United States of America, pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property, real or personal, which constitutes or is derived from proceeds traceable to the offense(s). The property to be forfeited includes, but is not limited to, the following: a Hyundai Sonata with Maryland tag number 3BA1000, VIN 5NPEC4AC3DH590572; b. A sum of money equal to the value of the proceeds of the scheme to defraud, which amount is at least $61, If any of the property described above, as a result of any act or omission of the defendant: a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to, or deposited with, a third party; c. has been placed beyond the jurisdiction of the court; 12

13 d. has been substantially diminished in value; or e. has been commingled with other property which cannot be divided without difficulty, the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c). 18 U.S.C. 981(a)(1)(C) 21 U.S.C U.S.C. 2461(c) A TRUE BILL Rod J. Rosenstein United States Attorney Foreperson Date: 13