IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINE SVILLE DIVISION

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINE SVILLE DIVISION UNITED STATES OF AMERICA I ^..,,, V. J EANETTE ELIZABETH FORD No. 2:18-cr- l^ -RWS-TCF THE UNITED STATES ATTORNEY CHARGES THAT: COUNT ONE (Wire Fraud, 18 U.S.C. 1343) 1. Beginning in or about J anuary 2015, and continuing through in or about March 2016, in the Northern District of Georgia/ and elsewhere/ the defendant/ J EANETTE ELIZABETH FORD ("FORD"), did knowingly devise and intend to devise a scheme and artifice to defraud her employer/ CP OpCo/ LLC/ d/b/a Classic Party Rentals (//CPR//), and to obtain money and property of CPR/ by means of materially false and fraudulent pretenses/ representations, and promises, and for the purpose of executing the scheme and artifice, and to obtain money and property/ did cause to be transmitted by means of wire communication/ in interstate and foreign commerce/ certain signs/ signals/ and sounds, as specified below. 2. At all times material to the Information/ FORD was employed as the operations controller in the accounting and finance department at CPR. Although CPR was headquartered in Inglewood, California/ FORD worked remotely from her home in Blue Ridge/ Georgia. Among her duties/ FORD was

responsible for managing accounting and finance records for CPR/ including records relating to corporate credit card expenditures by CPR employees. Description of the Scheme to Defraud 3. As part of her job as a controller at CPR/ FORD was responsible for reconciling and recording CPR employees' corporate credit card transactions within CPR's accounting records. 4. As part of the scheme to defraud/ FORD knowingly and willfully used her authority and access as an operations controller to circumvent company controls to charge over $500/000 in unauthorized personal expenses/ for herself and her family/ to a corporate credit card issued in her name. 5. The personal expenditures that FORD made using her CPR corporate credit card included the purchase of products and services such as building and masonry services/ furniture and other home furnishings/ vacation travel/ resort accommodations/ cruises/ and a variety of other personal items. Manner and Means of the Scheme to Defraud 6. As an operations controller/ FORD was able to hide her unauthorized charges from her colleagues and supervisors at CPR. 7. As part of the scheme to defraud/ FORD manipulated transaction reports from NIasterCard/ the corporate credit card company/ by deleting the unauthorized transactions from MasterCard spreadsheets and then presenting the manipulated data to conceal for the credit card transactions.

8. As a part of the scheme to defraud/ FORD also recorded fraudulent entries within the accounting system. The corporate credit card company would automatically debit a cash account when CPR's total credit card transactions reached a certain threshold. As bank reconciliations were performed at the end of each month/ these cash transactions were recorded by crediting cash and debiting the credit card liability. FORD would use her ability and access as operations controller to post entries within the system and record the fraudulent journal entries. These entries were used to change the balance of the credit card liability in order to reconcile the credit card file that she manipulated. 9. As a part of the scheme to defraud/ FORD also circumvented CPR policy by not linking her company credit card to CPR/s expense reporting software/ ExpensAble. CPR implemented ExpensAble in November 2015. One of the features of ExpensAble was its ability to automatically download corporate credit card transactions into CPR/s accounting system directly from the credit card processor. FORD/ along with others, was responsible for the implementation of ExpensAble/ but she did not link her corporate credit card to the CPR accounting system/ and thus her transactions were not included in system reporting. Execution of the Scheme to Defraud 10. On or about August 12,2015, in the Northern District of Georgia/ and elsewhere/ defendant/ J EANETTE ELIZABETH FORD ("FORD")/ for the purpose of executing and attempting to execute the aforementioned scheme and artifice

to defraud/ and to obtain money and property of her employer/ CP OpCo/ LLC/ d/b/a Classic Party Rentals (//CPR//)/ by means of materially false and fraudulent pretenses and representations/ did cause to be transmitted in interstate commerce/ by means of a wire communication/ certain signs/ signals/ and sounds: specifically/ FORD used her CPR corporate MasterCard to fraudulently purchase building contractor services for personal use from PayPal vendor :frrustyrooste RU/ in the amount of $9/554.57, and in so doing/ did knowingly cause MasterCard to initiate an electronic transfer of funds.. All m violation of Title 18, United States Code/ Section 1343. FORFEITURE PROVISION 11. Upon conviction of the offense alleged in this Information/ defendant, J EANETTE ELIZABETH FORD, shall forfeit to the United States any property/ real or personal/ which constitutes or is derived from gross proceeds traceable to such violations/ pursuant to Title 18, United States Code/ Section 981(a)(l)(C) and Title 28, United States Code/ Section 2461 (c)/ including but not limited to: a. the real property located at 60 Ford Road, in Blue Ridge/ Georgia; and b. the real property located at 62 Ford Road/ in Blue Ridge/ Georgia. 12. If/ as a result of any act or omission of the defendant/ any property subject to forfeiture: a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to/ or deposited with/ a third person;

c. has been placed beyond the jurisdiction of the Court; d. has been substantially diminished in value; or e. has been commingled with other property which cannot be subdivided without difficulty; the United States intends/ pursuant to Title 21, United States Code/ Section 853(p)as incorporated by Title 18, United States Code, Section 982(b)/ to seek forfeiture of any other property of said defendant up to the value of the forfeitable property. BYUNG J.PAK Unit/^ Stff^ s Attorney J OH^ f S. GHOSE AsSistyyt United States Attorney Geor$da/Bar No. 446568 A^ -EX-^ -'SIST^ -A_- Assistant United States Attorney Provisionally admitted pursuant to Local Rule 83.1A(3) 600 U.S. Courthouse 75 Ted Turner Drive SW Atlanta/ GA 30303 404-581-6000; F a x: 404-581-6181