Approved:

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Assistant United States Attorney

Before:

HONORABLE MICHAEL H. DOLINGER united States Magistrate Judge Southern District of New York

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SEALED
UNITED STATES OF AMERICA COMPLAINT
-v. - Violation of
18 U.S.C. s 1349
VANEE SYKES,
ALICE BRADFORD,
TORI JACKSON, and COUNTY OF OFFENSE:
LOIS JOHNSON, NEW YORK
Defendants.
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SOUTHERN DISTRICT OF NEW YORK, ss. : RONALD GARDELLA, being duly sworn, deposes and says that he is a Criminal Investigator with the United States Attorney's Office for the Southern District of New York and charges as follows:

COUNT ONE

1. From in or about October 2006, up to and including in or about December 2010, in the Southern District of New York and elsewhere, VANEE SYKES, ALICE BRADFORD, TORI JACKSON, and LOIS JOHNSON, the defendants, and others known and unknown, unlawfully, wilfully, and knowingly did combine, conspire, confederate, and agree together and with each other to commit offenses against the United States, to wit, to violate Section 1341 of Title 18, United States Code.

2. It was a part and an object of the conspiracy that VANEE SYKES, ALICE BRADFORD, TORI JACKSON, and LOIS JOHNSON, the defendants, and others known and unknown, unlawfully, wilfully, and knowingly, and having devised and intending to devise a scheme and artifice to defraud, and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, for the purpose of executing such scheme and artifice and attempting so to do, would and did place in a post office and authorized depository for mail matter, a

matter and thing to be sent and delivered by the Postal Service, and would and did knowingly cause to be deli vered--by mail according to the direction thereon, and at the place at which it is directed to be delivered by the person to whom it is addressed, such matter and thing, in violation of Title 18, United States Code, Section 1341.

OVERT ACTS

4. In furtherance of the conspiracy and to effect the illegal objects thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere:

a. On or about December 13, 2007, VANEE SYKES, the defendant, helped to process and approve a food stamp benefit card ("Food Stamp Card") using a false name and false social security number.

b. On or about December 1, 2010, ALICE BRADFORD, the defendant, provided SYKES with approximately nine mailing addresses for SYKES to use to obtain Food Stamp Cards, which were addresses where BRADFORD intended Food Stamp Cards to be mailed and where BRADFORD intended to collect the Food Stamp Cards in order to sell them.

c. In or about October 2006, TORI JACKSON, the defendant, used false names and false social security numbers to obtain approximately four fraudulent Food Stamp Cards that JACKSON helped to process.

d. In or about September 2010, LOIS JOHNSON, the defendant, used a fraudulent Food Stamp Card, which was maileCi. to a post office box located in Manhattan, which JOHNSON opened and used.

(Title 18, United States Code, Section 1349.)

The bases for my knowledge and the foregoing charge are, in part, as follows:

5. I am a Criminal Investigator employed by the United States Attorney's Office for the Southern District of New York. This affidavit is based upon my conversations with investigators employed,by the New York City Department of Investigation ("DOl"), as well as other law enforcement and DOl officials, and

my examination of pertinent records and reports. Because this affidavit is being submitted for the limited purpose of

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establishing probable cause, it does not include all of the facts that I have learned during the course of my investigation. Where the contents of documents and the actions, statements and conversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated.

6. Based on conversations with investigators from DOI, I have learned in substance and in part, the following:

a. Food stamp benefits, made available through Food Stamp Cards, are funded entirely by the united States Department of Agriculture Supplemental Nutrition Assistance Program. The New York City Human Re aouz ce s Administration ("HRA") is the New York City agency responsible for determining who is eligible for Food Stamp Cards in New York City.

b. Individuals seeking Food Stamp Cards and food stamp benefits through HRA ("Applicants") are asked for, among other things, the Applicant's name, social security number, mailing address, members of the Applicant's household and their social security numbers.

c. VANEE SYKES, the defendant, has been employed by HRA as an Associate Job Opportunity Specialist II ("AJOS II") since at least October 2006 through the present.

d. As an AJOS II, SYKES works in the Separate Determination Unit, where she is responsible for, among other things, determining whether particular Applicants are eligible to receive Food Stamp Cards and benefits.

e. In her capacity as an AJOS II, SYKES has access to the Welfare Management System, a computer database which maintains records concerning the applications and approvals for, among other things, Food Stamp Cards and benefits.

f. SYKES is assigned a unique user identification log-in and password ("Sykes' ID") that allows administrators of the Welfare Management System to determine which Food Stamp Card cases were processed and/or approved by an individual or individuals using SYKES's user identification. In addition, employees of HRA input a unit/worker identification number ("Worker ID") when they use the Welfare Management System to take action on or process a Food Stamp Card case.

g. After SYKES approved of a Food Stamp Card, a Food Stamp Card would be mailed by a third-party vendor (the "Vendor") located in Albany, New York via the United States Postal Service

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to the Applicant at the mailing address entered on the Food Stamp Card case.

h. The benefit amount placed onto a Food Stamp Card is generally based on the number of individuals in the household of the Applicant and the income level and expenses of the Applicant and the Applicant's household. Food stamp benefits, which have a monetary value, are generally credited to a Food Stamp Card on an ongoing monthly basis. In her capacity as an AJOS II, however, SYKES was able to add additional money on a one-time basis to a Food Stamp Card by requesting food stamp benefits for months that had already passed.

7. Based on my conversations with DOl investigators who have reviewed data from the Welfare Management System, I have learned in substance and in part, the following:

a. Between April 2007 and November 2010, an individual or individuals using a Worker ID recorded on the Welfare Management System as "SEPOT," created and/or processed approximately 1,500 food stamp benefit cases.

b. A review of a sample of these approximately 1,500 cases reveals that there were no social security numbers provided on these sample cases for members of the Applicant's household, other than the Applicant.

c. A review of a sample of these approximately 1,500 cases reveals that these sample cases did not include identification documents for the Applicant or members of the --Applicant's household, such as birth certificates, social security cards, and/or drivers licenses, that would reflect the identity and income level of the Applicants and their dependents.

d. The Food Stamp Cards and benefits that resulted from these approximately 1,500 cases were mailed from the Vendor to the Applicants' listed mailing addresses, including to mailing addresses in Manhattan and the Bronx.

e. Between April 2007 through November 2010, the total dollar amount credited onto the Food Stamp Cards issued in connection with these approximately 1,500 cases exceeded approximately $8,000,000.

f. Approximately eight of these Food Stamp Cards were sent to a post office box in Manhattan ("Johnson's P.O. Box") that, according to postal records, was opened by LOIS JOHNSON, the defendant.

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g. On or about December 13, 2007, an individual using Sykes' lD processed and approved ~ Food Stamp Card for a~ Applicant whose social security number did not match the Applicant's name.

8. I have learned_ that HRA investigators have visited '-ada.r~sses listed as the Applicant's mailing-address on about 19 of the Food Stamp Card cases described above in paragraph 7, and have determined, among other things, that the name of the Applicant listed on the Food Stamp Card case did not live and was not associated with the mailing address provided.

_ 9. I have learned that HRA and DOl investigators have compared the social security numbers provided on approximately 1,400 of the Food Stamp Card cases described above in paragraph 7, with data from the Social Security Administration and have determined, among other things:

a. Approximately 1,000 of the social security numbers listed as the Applicant's social security number on the Food Stamp Card cases were not actually assigned to the respective Applicant.

b. A review of a sample of the approximately 400 Food Stamp Card cases that identify an Applicant that does match the social security number provided shows that these Applicants were not eligible to be processed by SYKES' department at HRA, the Separate Determination Unit, for Food Stamp Cards or benefits.

10. On or about December I, 2010, and December 2, 2010, DOl investigators and detectives from DOl's New York Police Department Squad ("DOl Squad") interviewed VANEE SYKES, the defendant, and SYKES stated in substance and in part, the following:

a. From in or around 2007 through in or around November 2010, SYKES used her access to the Welfare Management System, to process and approve numerous Food Stamp Cards and benefits using false names, false social security numbers, and false income and expense information.

b. SYKES used the Worker lD "SEPOT" when SYKES processed and approved the fraudulent food stamp benefit cases.

c. When SYKES processed and approved fraudulent food stamp benefit cases, SYKES generally did not include supporting documents and generally did not include social security numbers for anybody other than the Applicant.

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d. SYKES used mailing addresses for these fraudulent Food Stamp Cards and benefit cases that SYKES had received from ALICE BRADFORD, the defendant, and TORI JACKSON, the defendant, among others.

e. SYKES received cash payments from BRADFORD for the Food Stamp Cards and benefits that SYKES processed, approved, and had sent to mailing addresses provided by BRADFORD.

11. On or about December I, 2010, acting at the direction of DOI investigators and DOI Squad detectives, VANEE SYKES, the defendant, made a consensually recorded telephone call to ALICE BRADFORD, the defendant, during which call, in substance and in part, BRADFORD agreed to meet SYKES and to provide SYKES with mailing addresses that SYKES could use for Food Stamp Card cases.

12. On or about December I, 2010, acting at the direction of DOI investigators and DOI Squad detectives, VANEE SYKES, the defendant, and ALICE BRADFORD, the defendant, met in Brooklyn, New York. During this meeting, which was monitored and recorded by DOI investigators a~d DOI Squad detectives, BRADFORD gave SYKES a document containing nine mailing addresses.

13. On or about December 2, 2010, a DOI investigator and DOI Squad detectives interviewed ALICE BRADFORD, the defendant,

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and BRADFORD stated in substance and in part, the followi-ng:

-a. In or around 2008, BRADFORD began providing VANEE SYKES, the defendant, with mailing addresses that SYKES used on fraudulent Food Stamp Card cases.

b. BRADFORD got these mailing addresses from acquaintances who BRADFORD would pay in cash in exchange for allowing BRADFORD to use their mailing addresses on Food Stamp Card cases.

c. BRADFORD sold the majority of the Food Stamp Cards that were mailed to these mailing addresses to a co-conspirator not charged herein ("CC-l"), who paid BRADFORD in cash for the Food 'Stamp Cards.

d. BRADFORD provided SYKES with a portion of the money that BRADFORD received from CC-l.

14. On or about December 3, 2010, a DOI investigator and a DOI Squad detective interviewed TORI JACKSON, the defendant, and JACKSON stated in substance and in part, the following:

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a. JACKSON worked at HRA in various positions from in or-around 2001 until in or 'around June 2010, including at times with VANEE SYKES, the defendant.

b. Shortly before approximately October 2006, while working for HRA, JACKSON took the following actions, among

ot.he r s:

i. JACKSON processed approximately four fraudulent Food Stamp Cards using false names and false security numbers.

11. Without aut.ho.r Lz at.Lon , JACKSON also reactivated a relative's closed Food Stamp Card case.

iii. JACKSON directed these approximately five Food Stamp Cards to be mailed to addresses to which JACKSON, her friends, or her family had access.

c. SYKES, who was working at the same HRA center at the time JACKSON engaged in the actions described above in paragraph 14, was aware that JACKSON processed at least one of the approximately five fraudulent Food Stamp Cards.

d. Beginning in or around October 2006 until approximately 2009, while working at HRA, JACKSON processed at least 30 additional Food Stamp Cards using false names and false social security numbers.

e. When processing at least some of these additional fraudulent Food Stamp Cards, JACKSON used Sykes' ID, which JACKSON obtained when JACKSON worked with SYKES.

f. JACKSON processed less than 10 fraudulent Food Stamp Cards that were sent to Johnson's P.O. Box.

g. In or around May 2010 or June 2010, JACKSON last used a fraudulent Food Stamp Card that JACKSON had processed and, obtained.

15. On or about December 2, 2010, DOI investigators interviewed LOIS JOHNSON, the defendant, and JOHNSON stated in substance and in part, the following:

a. JOHNSON has been an employee of HRA for over 30

years.

b. JOHNSON permitted TORI JACKSON, the defendant, to have Food Stamp Cards in the names of other people mailed to

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Johnson's P.O. Box in Manhattan.

c. In or around 2007, JOHNSON received a Food Stamp Card from JACKSON in someone else's name, which JOHNSON used.

d. On several occasions, after JOHNSON received mail containing a fraudulent Food Stamp Card at Johnson's P.O. Box, JOHNSON would provide the mail to JACKSON, who wouldr in turn provide, a fraudulent Food Stamp Card to JOHNSON for JOHNSON's personal use.

e. JOHNSON stated that she received several fraudulent Food st.amp Cards from JACKSON, each_containing appr():x:imately $1,000 to $2,000 in food stamp benefits.

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f. JOHNSON mailed at least one of the fraudulent Food

Stamp Cards that JOHNSON received from JACKSON to another individual.

g. ·The last time JOHNSON used a fraudulent Food Stamp Card that she received from JACKSON was in approximately September 2010.

WHEREFORE, deponent prays that an arrest warrant be issued for the above~named defendants and that they be arrested and imprisonE:d, .or bailed, as the case may be.

R~

Criminal Investigator

United States ~ttorney's Office for the Southern District of New York

Sworn to before me this 7~ day of Dec ber, 2010

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UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK

HON. M1CH,5\EL H. DOUr·JGER United St8tes MagistT3teJudge SOi 1 th ern DistTict o-f Ne\N York

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