Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 1 of 8 PageID.1 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

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1 Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 1 of 8 PageID.1 UNITED STATES OF AMERICA, UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION vs. Plaintiff, DERRICK J. GIBSON, CHARMICA GRIFFIN, STEPHANIE T. BAKER, LATIA M. WILLIAMS, ALVIN E. STEPHENSON II, SANDRIA M. BLAKLEY, EDWARD WARDEN, JR., CHANEL MCCLENNEY, DARWIN GIBSON, BOBBY CRABTREE, DEQYNN GIBSON, DARRIEN GIBSON, ROCHELLE R. VELASQUEZ, SCHERRIE MCNUTT, DEVOINE GIBSON, PRENTIS H. GIBSON, LAMONT JOYNER, SHAMEIKA N. CARR-MCCLENNEY, CHARLEETA CORK, KEITH CORK, MAIYA R. JACKSON, SHAWN MCKNIGHT, DAVID HAYMER, DIALLO DOTSON, ROMELL BOLDEN, LABRISHA PORTER, KYPREE TAYLOR, ROSEMARY BOYD, PATRICIA RIDDLE-MCCLINTON, JOSEPH JEREMY JOHNSON, KISHA N. EVANS, RASHALL FORD, SIMONE WATKINS, and ROMARO CARSWELL, INDICTMENT Defendants. /

2 Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 2 of 8 PageID.2 The Grand Jury charges: (Conspiracy to Defraud the United States) THE CONSPIRACY AND ITS OBJECTS 1. Beginning in or about 2008, and continuing to in or about February of 2016, in the Western District of Michigan, Southern Division, and elsewhere, the defendants, DERRICK J. GIBSON, CHARMICA GRIFFIN, STEPHANIE T. BAKER, LATIA M. WILLIAMS, ALVIN E. STEPHENSON II, SANDRIA M. BLAKLEY, EDWARD WARDEN, JR., CHANEL MCCLENNEY, DARWIN GIBSON, BOBBY CRABTREE, DEQYNN GIBSON, DARRIEN GIBSON, ROCHELLE R. VELASQUEZ, SCHERRIE MCNUTT, DEVOINE GIBSON, PRENTIS H. GIBSON, LAMONT JOYNER, SHAMEIKA N. CARR-MCCLENNEY, CHARLEETA CORK, KEITH CORK, MAIYA R. JACKSON, SHAWN MCKNIGHT, DAVID HAYMER, DIALLO DOTSON, ROMELL BOLDEN, LABRISHA PORTER, KYPREE TAYLOR, ROSEMARY BOYD, PATRICIA RIDDLE-MCCLINTON, JOSEPH JEREMY JOHNSON, KISHA N. EVANS, RASHALL FORD, SIMONE WATKINS, and ROMARO CARSWELL,

3 Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 3 of 8 PageID.3 did knowingly enter into an agreement, combination, or conspiracy to defraud the United States, or a department or agency thereof, specifically the Internal Revenue Service, by obtaining or aiding to obtain the payment of false, fictitious, and fraudulent claims, specifically false federal income tax refunds. 2. The principal goal of the conspiracy was to obtain money by defrauding the United States Internal Revenue Service through the filing of false, fictitious, and fraudulent federal income tax returns claiming false, fictitious, and fraudulent federal income tax refunds. MANNER AND MEANS OF THE CONSPIRACY 3. The conspirators used multiple methods of obtaining personal identification information (PII), including names, social security numbers, and dates of birth, to enable them to file false, fictitious, and fraudulent federal income tax returns, including but not limited to: (a) Michigan Department of Corrections (MDOC) inmates, including BOBBY CRABTREE, DAVID HAYMER, and JOSEPH JEREMY JOHNSON provided PII of fellow inmates in anticipation of receiving money and/or personal items; (b) MDOC inmate SHAWN MCKNIGHT attempted to recruit others outside the prison to provide PII; and (c) Veterans Affairs (VA) Battle Creek Medical Center employees, including ALVIN E. STEPHENSON, II, provided PII of veteran patients of the Battle Creek Medical Center. 4. Multiple individuals were involved in the filing of false, fictitious, and fraudulent federal income tax returns claiming false, fictitious, and fraudulent federal income tax refunds in association with DERRICK J. GIBSON, including but not limited to: CHARMICA GRIFFIN, STEPHANIE T. BAKER, LATIA M. WILLIAMS, SANDRIA M. BLAKLEY, EDWARD 3

4 Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 4 of 8 PageID.4 WARDEN, JR., CHANEL MCCLENNEY, DARWIN GIBSON, DEQYNN GIBSON, DARRIEN GIBSON, ROCHELLE R. VELASQUEZ, SCHERRIE P. MCNUTT, PRENTIS H. GIBSON, LAMONT JOYNER, SHAMEIKA CARR-MCCLENNEY, CHARLEETA CORK, KEITH CORK, MAIYA R. JACKSON, DIALLO DOTSON, ROMELL BOLDEN, LABRISHA PORTER, KYPREE TAYLOR, ROSEMARY BOYD, PATRICIA RIDDLE-MCCLINTON, KISHA N. EVANS, RASHALL FORD, SIMONE WATKINS, and ROMARO CARSWELL. 5. Multiple individuals opened and/or maintained bank accounts into which false, fictitious, and fraudulent federal income tax refunds where deposited, including but not limited to: DERRICK J. GIBSON, STEPHANIE T. BAKER, LATIA M. WILLIAMS, DARWIN GIBSON, DEQYNN GIBSON, ROCHELLE R. VELASQUEZ, SCHERRIE MCNUTT, PRENTIS H. GIBSON, LAMONT JOYNER, KEITH CORK, MAIYA R. JACKSON, DIALLO DOTSON, LABRISHA PORTER, KYPREE TAYLOR, ROSEMARY BOYD, RASHALL FORD, and SIMONE WATKINS. 6. For tax years 2007 through 2014, DERRICK GIBSON and co-conspirators filed at least 4,668 federal income tax returns, Forms 1040, claiming total false, fictitious, and fraudulent refunds of at least $22,585,333. OVERT ACTS 5. In furtherance of the conspiracy, and to effect the object of the conspiracy, at least one of the following overt acts was committed: a. On or about February 3, 2009, CHARMICA GRIFFIN filed a federal income tax return, Form 1040, for the 2008 tax year, in the name of and using the social security number of S.J., claiming false income in the amount of $11,500, claiming false earned income credit in the amount of $4,610, and claiming a false federal income tax refund of $5,960. 4

5 Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 5 of 8 PageID.5 b. On or about February 12, 2010, CHARMICA GRIFFIN filed a federal income tax return, Form 1040, for the 2009 tax year, in the name of and using the social security number of S.J., claiming false income in the amount of $13,193, claiming false earned income credit in the amount of $5,028, and claiming a false federal income tax refund of $6,707. c. On or about May 31, 2010, MDOC inmate DAVID HAYMER, while at the West Shoreline Correctional Facility, provided DERRICK GIBSON with MDOC inmate G.R. s personal identification information, including name, social security number, and date of birth. d. On or about February 24, 2011, CHARMICA GRIFFIN filed a federal income tax return, Form 1040, for the 2010 tax year, in the name of and using the social security number of S.J., claiming false income in the amount of $12,365, claiming false earned income credit in the amount of $4,950, and claiming a false federal income tax refund of $7,569. e. On or about June 21, 2011, a co-conspirator filed a federal income tax return, Form 1040, for the 2010 tax year, in the name of and using the social security number of MDOC inmate G.R., claiming false income in the amount of $10,787, claiming false earned income credit in the amount of $3,050, and claiming a false federal income tax refund of $3,450. f. On or about January 20, 2012, DERRICK GIBSON filed a federal income tax return, Form 1040, for the 2011 tax year, in the name of and using the social security number of S.J., claiming false income in the amount of $14,646, claiming false earned income credit in the amount of $5,751, and claiming a false federal income tax refund of $6,308. g. On or about May 9, 2012, LATIA WILLIAMS, SCHERRIE MCNUTT, DEVOINE GIBSON, and others, cleared DERRICK GIBSON s home, at 33 Echo Street, in Battle Creek, Michigan, of personal identification information, copies of federal income tax returns, and 5

6 Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 6 of 8 PageID.6 computers used to file federal income tax returns, prior to the execution of a federal search warrant on May 10, h. On or about December 4, 2012, MDOC inmate BOBBY CRABTREE, while at the E.C. Brooks Correctional Facility, provided DERRICK GIBSON with MDOC inmate L.D. s personal identification information, including name, social security number, and date of birth. i. On or about February 21, 2013, STEPHANIE BAKER filed a federal income tax return, Form 1040, for the 2012 tax year, in the name of and using the social security number of S.J., claiming false income in the amount of $13,456, claiming false earned income credit in the amount of $5,130, and claiming a false federal income tax refund of $6,238, and directing $500 of the refund into a First Community Federal Credit Union bank account controlled by STEPHANIE BAKER and $5,738 of the refund onto a prepaid debit card. j. On March 14, 2013, during a recorded telephone conversation, MDOC inmate JOSEPH JEREMY JOHNSON provided DERRICK GIBSON with MDOC inmates W.F. and B.D s personal identification information, including names, social security numbers, and dates of birth. k. On or about October 2 through 4, 2013, ALVIN STEPHENSON II removed a patient census, containing patient personal identification information, from the VA Medical Center Domicile building where he worked at that time. l. On November 27, 2013, during a recorded telephone conversation, MDOC inmate JOSEPH JEREMY JOHNSON provided DERRICK GIBSON with MDOC inmate D.G. s personal identification information, including name, social security number, and date of birth. 6

7 Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 7 of 8 PageID.7 m. On or about January 25, 2014, a co-conspirator filed a federal income tax return, Form 1040, for the 2013 tax year, in the name of M.P., falsely claiming MDOC inmate L.D. as a dependent, and claiming a false federal income tax refund of $3,887. n. On or about January 29, 2014, a co-conspirator filed a federal income tax return, Form 1040, for the 2013 tax year, in the name of and using the social security number of MDOC inmate W.F., claiming false income in the amount of $18,523, claiming false income tax withholding in the amount of $2,002, claiming false earned income credit in the amount of $487, and claiming a false federal income tax refund of $2,489. o. On or about February 14, 2014, a co-conspirator filed a federal income tax return, Form 1040, for the 2013 tax year, in the name of and using the social security number of S.J., claiming false income in the amount of $12,074, claiming false income tax withholding in the amount of $162, claiming false earned income credit in the amount of $3,250, and claiming a false federal income tax refund of $3,321, and directing $2,000 of the refund into a First Community Federal Credit Union bank account controlled by STEPHANIE BAKER and $1,321 of the refund onto a prepaid debit card. p. On or about February 26, 2014, a federal income tax refund in the amount of $2,000 from S.J. s 2013 tax return was direct deposited into a First Community Federal Credit Union bank account controlled by STEPHANIE BAKER. q. On or about March 14, 2014, a co-conspirator filed a federal income tax return, Form 1040, for the 2013 tax year, in the name of and using the social security number of VA patient C.W., claiming false income in the amount of $18,190, claiming false income tax withholding in the amount of $1,848, claiming false education credits in the amount of $1,144, 7

8 Case 1:16-cr JTN ECF No. 1 filed 02/25/16 Page 8 of 8 PageID.8 claiming false earned income credit in the amount of $3,147, and claiming a false federal income tax refund of $5,995. r. On or about March 23, 2014, a co-conspirator filed a federal income tax return, Form 1040, for the 2013 tax year, in the name of DIALLO DOTSON, falsely claiming MDOC inmate D.G. as a dependent, and claiming a false federal income tax refund of $8,240. s. On or about February 5, 2016, a co-conspirator filed a federal income tax return, Form 1040, for the 2013 tax year, in the name of and using the social security number of VA patient B.D., claiming false income in the amount of $8,628, false income tax withholding in the amount of $500, and claiming a false federal income tax refund of $ U.S.C. 286 A TRUE BILL PATRICK A. MILES, JR. United States Attorney GRAND JURY FOREPERSON B. RENÉ SHEKMER Assistant United States Attorney P.O. Box Ionia Avenue, NW Grand Rapids, Michigan (616)