CR-WILLIAMS/SIMONTON

Transcription

1 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 1 of 10 TB Jan 26, 2017 U NITED STATES D ISTR ICT CO UR T SO UTH ERN D ISTR ICT O F FL O RID A CR-WILLIAMS/SIMONTON CA SE N O. 18U.S.C.j1029(b)(2) 18U.S.C.j1029(a)(3) 18U.S.C.j1028A(a)(1) 18U.S.C.j1030(a)(2)(C) 18U.S.C.j982(a)(2)(B) 18U.S.C.j1029(c)(1)(C) 18U.S.C.j1030U) U NITED STA TE S O F AM ER IC A VS. EV ELIN A SO PH IA R EID, D efendant. / IN D ICTM EN T The Grand Jury chargesthat: COUNT 1 C onspiracy to Com m ita ccessd evice Fraud (18U.S.C.j 1029(b)(2)) From in or around January 201l,through on or about January 28,20l6,in M iam i-d ade County,in the Southern D istrictofflorida,and elsewhere,the defendant, EVELIN A SO PH IA R EID, did knowingly and willfully com bine,conspire,confederate and agree w ith otherpersonsknow n and unknow n to the Grand Jury to com m itviolations of Title 18,U nited States Code, Section l029(a)(3),namely,to knowingly,and with intentto defraud,possess tifteen (15) ormore unauthorized access devices,thatis,socialsecurity num bersissued to otherpersons,said conduct affecting interstate and foreign com m erce. A CT S IN FUR TH EM N CE O F TH E C O N SPIM C Y ln furtherance ofthe conspiracy,atleastone ofthe co-conspiratorscom m itted and caused

2 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 2 of 10 to be com m itted, in the Southern D istrict of Florida, and elsewhere, at least one of the fo low ing acts, am ong others: On or about A ugust l7, 2012, EV ELINA SO PH IA REID, an em ployee of Jackson Hea1th System (JHS), accessed a computer database at JHS and obtained, without authorization or permission, the social security numbers belonging to over one hundred (100) current and former patients of JH S. On or about February 9, 2013, EVELINA SOPHIA REID accessed JHS'S computer database and obtained, w ithout authorization or pennission, the social security num bers belonging to over three hundred (300) current and former patients of JHS. On or about July 4, 2014, EV ELINA SO PH IA REID accessed JHS'S com puter database and obtained, w ithout authorization or perm ission, the social security num bers belonging to over one hundred (100) current and former patients of JHS. On or about July 8, 2014, a co-conspirator filed a fraudulent tax return for a current or fonner patient of JH S, ttj.b.,'' using that patient's nam e, date of birth, and social security num ber, without J.B.'S know ledge. On or about March 2015, EVELINA SOPHIA REID accessed JHS'S com puter database and obtained, w ithout authorization or pennission, the social security num bers belonging to over two hundred (200) current and former patients of JHS. On or about June 9, 2015, a co-conspirator filed a fraudulent tax return for a current or form er patient of JH S, çea.l.,'' using that patient's nam e, date of birth, and social security num ber, w ithout A.I.'s know ledge. A l in violation of Title 18, United States Code, Section 1029(b)(2).

3 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 3 of 10 COUNTZ Possession of Fifteen or M ore U nauthorized A ccess D evices (18 U.S-C. j 1029(a)(3)) O n or about August 17, 2012, in M iam i-dade County, in the Southem Distrid of Florida, and elsew here, the defendant, did knowingly, and with intent to defraud, possess tifteen (15) or more unauthorized access and foreign commerce, in violation of Title 18, United States Code, Sections 1029(a)(3) and 2. COUNTS 3-4 A ggravated ldentity Theft (18 U.S.C. j 1028A(a)(1)) O n or about A ugust 17, 2012, in M iam i-d ade County, in the Southern D istrict of Florida, and elsewhere, the defendant, during and in relation to a felony violation of Title 1 8, United States Code', Section l 029(a)(3), that is, knowingly, and with intent to defraud, possessing fifteen (15) or more unauthorized access and foreign com m erce, as charged in Count 2, did know ingly transfer, possess, and use, without law ful authority, the m eans of identification of another person, as specified below: C ount M eans of ldentification 3 N am e, date of birth, and social security num ber of tte.d.'' 4 N am e, date of birth, and social security num ber of tta.r.'' In violation of Title 18, United States Code, Sections 1028A(a)(1) and 2.

4 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 4 of 10 COUNT 5 Possession of Fifteen or M ore U nauthorized Access Devices (18 U.S.C. j 1029(a)(3)) On or about Febnlary 9, 2013, in M iam i-dade County, in the Southern District of Flolida, and elsew here, the defendant, did knowingly, and with intent to defraud,possess fifteen (15) or more unauthorized access devices, that is, social secudty num bel-s issued to other persons, said conduct affecting interstate and foreign commerce, in violation of Title 18, United States Code, Sections l029(a)(3) and 2. COUNT 6 A ggravated ldentity Theft (18 U.S.C. j 1028A(a)(1) On or about Febnlary 9, 2013, in M iam i-d ade County, in the Southern D istrict of Florida, and elsew here, the defendant, during and in relation to a felony violation of Title l 8, United States Code, Section 1029(a)(3), that is, knowingly, and with intent to defraud, possessing fifteen (15) or more unauthorized access and foreign com m erce, as charged in Count 5, did know ingly transfer, possess, and use, w ithout lawful authority, the m eans of identification of another person, that is, the nam e, date of birth, and social security number of tta.f.,'' in violation of Title 1 8, United States Code, Sections 1028A(a)(1) and 2. COUNT 7 C om puter Fraud (18 U.S.C. j 1030(a)(2)(C)) On or about February 9, 20l 3, in M iam i-d ade County, in the Southern D istrict of Flolida,

5 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 5 of 10 and elsewhere, the defendant, did know ingly and intentionally access a com puter w ithout authorization and exceed authorized access to a com puter, and thereby did obtain inform ation from any protected com puter, that is, social security numbersissued to other persons, for the pupose of private financial gain, in violation of Title 18, United States Code, Sections 1030(a)(2)(C), 1030(c)(2)(B)(i), and 2. COUNT 8 Aggravated ldentity Theft (18 U.S.C. j 1028A(a)(1)) O n or about February 9, 2013, in M iam i-dade County, in the Southern D istrict of Florida, and elsewhere, the defendant, during and in relation to a felony violation of Title l 8, United States Code, Section 1030(a)(2)(C), that is, know ingly and intentionally accessing a com puter w ithout authorization and exceeding authorized access to a com puter, and by such conduct obtaining inform ation from any protected com puter, that is, social secudty num bel's issued to other persons, for the purpose of private financial gain, as charged in Count 7, did know ingly transfer, possess, and use, w ithout law ful authority, the m eans of identification of another person, that is, the nam e, date of birth, and social security number of çr.s.,' in violation of Title 1 8, United States Code, Sections 1028A(a)(1) and COUNT 9 Possession of Fifteen or M ore U nauthorized A ccess Devices (18 U.S.C. j 1029(a)(3)) O n or about July 4, 2014, in M iam i-d ade County, in the Southern D istrict of Florida, and elsewhere, the defendant,

6 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 6 of 10 did knowingly, and with intent to defraud, possess fifteen (15) or more unauthorized access and foreign commerce, in violation of Title 18, United States Code, Sedions 1029(a)(3) and 2. COUNTS A ggravated ldentity Theft (18 U.S.C. j 1028A(a)(1)) On or about the dates specified as to each count below, in Miami-Dade County, in the Southenz District of Florida, and elsewhere, the defendant, duling and in relation to a felony violation of Title 18, United States Code, Section 1029(a)(3), that is, knowingly, and with intent to defraud, possessing tifteen (15) or more unauthorized access and foreign com m erce, as charged in Count 9, did know ingly transfer, possess, and use, w ithout law ful authority, the m eans of identification of another person, as specified below: C ount D ate M eans of ldentification 10 July 4, 2014 N am e, date of birth, and social security num ber of çt.h.' 1 July 8, 2014 N am e, date of birth, and social security num ber of çj.b.' ln violation of Title l8, United States Code, Sections l028a(a)(1) and 2. COUNT 12 Possession of Fifteen or M ore U nauthorized A ccess D evices (18 U.S.C. j 1029(a)(3) O n or about M arch 27, 2015, in M iam i-dade County, in the Southern District of Florida, and elsewhere, the defendant, did knowingly, and with intent to defraud, possess fifteen (1 5)or naore unauthorized access

7 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 7 of 10 and foreign commerce, in violation of Title l 8, United States Code, Sections 1029(a)(3) and 2. COUNTS A ggravated Identity Theft (18 U.S.C. j 1028A(a)(1)) On or about the dates specified as to each count below, in M iam i-dade County, in the Southem District of Florida, and elsewhere, the defendant, during and in relation to a felony violation of Title 18, United States Code, Section l029(a)(3), that is, knowingly, and with intent to defraud, possessing fifteen (15) or more unauthorized access and foreign com m erce, as charged in Count 12, did know ingly transfer, possess, and use, w ithout lawful authority, the m eans of identification of another person, as specified below: Count Date M eans of Identification 13 M arch 27, 2015 N am e, date of birth, and social security num ber of t&e.c.'' 14 June 9, 2015 N am e, date of birth, and social security num ber of t6a.l.'' In violation of Title 18, United States Code, Sections l028a(a)(1) and 2. FORFEITURE ALLEGATIONS The allegations of this lndictm ent are re-alleged and by this reference fully incolporated herein for the purpose of alleging crim inal forfeiture to the United States of Am erica of certain property in which the defendant, has an interest. Upon conviction of a violation of Title 18, United States Code, Section 1029 and/or Section 1030, as alleged in this lndictm ent, the defendant shall forfeit to the United States of America: (a) anypersonal property used or intended to be used to commit such violations, pursuant to Title l8, United States Code, Sections l029(c)(1)(c) and 1030()41)., and (b) any property

8 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 8 of 10 constituting, or delived from, proceeds obtained directly or indirectly, as the result of such violations, pursuant to Title 18, United States Code, Sections 982(a)(2)(B) and l030u)(2). Al1 pursuant to Title l 8, United Stats Code, Sections 982(a)(2)(B), 1029(c)(1)(C), and 1030(), and the procedures set forth at Title 21, United States Code, Section 853, as incoporated by Title 18, United States Code, Section 982(b)(1). A TRUE BILL FOREPERSON W IFRE O A.FERR UNIT STATES A TORNEY DAYA ATHAN ASSISTANT UNITED STATES ATTORNEY 8

9 Case 1:17-cr KMW Document UNITED STATES 1 Entered DISTRICT on FLSD COURT Docket 01/27/2017 Page 9 of 10 SOUTHERN DISTRICT OF FLORIDA UNITED STATES O F AM ERICA CASE NO. V. Defendant. / Superseding Case Inform ation: Court Division: (select one) X Miami FTL Key W est WPB l do hereby certify that: l W V New Defendantts) Number of New Defendants Total num ber of counts 1 have carefuly considered the alegations of the indictmept, the num ber of defendants, the num ber of probable witnesses and the legal complexities of the lndlctm ent/lnform ation attached hereto. 1 am afare that the inform ation supplied on this statement w il be relied upon by the Judges of this Court ln setting their calrndars and scheduling criminal trials under the mandate of the Speedy Trial Act, Tltle 28 U.S.C. Sectlon lnterpreter: (Yes or No) No Listlanguage and/or dialect This case will take 4-5 days for the parties to try. Please check appropriate categol.y and type of offense listed below: (Check only one) 0 to 5 days 6 to 10 days 1 l to 20 days 21 to 60 days 6 1 days and over (Check only one) Petty Minor Misdem. Felony Yes 6. Has this case been previously tiled in this District Court? (Yes or No) No lf yes: Judge: Case No. (A tach copy pf dispositive ordel) Has a complalnt been filed in thls mater? (Yes or No) No If yes: M agistrate Case No. Related M iscqlaneous num bers: Defendants) ln federal custody as of Defendants) in state custody as of Rule 20 from the District of Is this a potential death penalty case? (Yes or No) Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office prior to October 14, 2003? Yes No x No X 8. D ges this case originate from a m ater pending in the Central Region of the U.S. A tonzey's Office prlor to September 1, 2007? Yes No x *penalty Sheetts) atached DA A ATHAN ASSISTANT UN ITED STATES ATTORNEY FLORIDA BAR NO

10 Case 1:17-cr KMW Document 1 Entered on FLSD Docket 01/27/2017 Page 10 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA PENALTY SHEET Defendant's Name: EVELINA SOPHIA REID Case No: Count #: l Conspiracy to Com m it Access D evice Fraud Title 18, United States Code, Section l029(b) *M ax. Penalty: 10 Years' lm prisonm ent Counts #: 2, 5, 9, 12 Possession of 15 or M ore Unautholized Access D evices Title 18, United States Code, Section 1029(a)(3) *M ax. Penalty: 10 Y ears' lm prisonm ent Count #: 3-4, 6, 8, , Aggravated ldentity Theft Title 18, United States Code, Section l028a(a)(l) *M ax. Penalty: 2 Years' lmprisonment (consecutive to any other sentence) Count #: 7 Com puter Fraud Title 18, United States Code, Section 1030(a)(2)(C) *M ax. Penalty: 5 Y ears' lm prisonm ent *ltefers only to possible term of incarceration, does not include possible fines, restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.