JUDGE MARY STALEY CLARK GENERAL BILL OF INDICTMENT NO _Dedeeg S-W-9674, 15-W-9675, 10-W-NAST COB SUPERIOR COURT RE: Warrant ISWA891, WITNESSES Iny. Carol Burkes, Cobb County District Attorney's Office MARCH/APRIL TERM 2017 THE STATE OF GEORC Vv MICHAEL ROBERT SCHULLERMAN AND ERICA CLAUDE TE WHITE urder C9: Financial Transaction Murder C1. 10; Financial Tr Ct LE: Financial Transa Cun: Fin Cua Influenced izations Act D. VICTOR REYNOLDS, District Attorney, Cobb Judicial € uit The Defendant herein waives copy of The Defendant herein rndictment, list af witnesses, formal indictment, list of witnesses, formal __ Guilty veraigamennt and pleads Guilty. Defend ~ Defendant wey for Deten Afiomey Tor Delendani Assistant District Attoriey Assistant District AntomieySTATE OF GEORGIA, COUNTY OF COBB. IN THE SUPERIOR COURT OF SAID COUNTY THE GRAND JURORS selected, chosen and sworn for the County of Cobb, to wit: Donnie James Arrowood Jamie Faser Arthur, Asst. Foreperson SETrstoplier R-Brrgess, Alt Dana Reshaay Eason, Clerk Cynthia Rose Epperson Abbas Eshagieh-Meybodi David Rul on, Foreperson Pedro a Jo Ann Heller Ashley Elizabeth Hobbs Mary Jean Holnaider Sharletta Monique Lang Mallory Gail Low Donald Joseph Massaro, Jr. Jewel Saundrea Meertens 1 | Adriana Moore Kevin Shane Osborne Chayne Roujae Rector Melissa Maria Rivera Maria Victoria S. Roaquin Daryl Richard S| h Gregory Geoffrey Smith Zonia E, Tejada Jefferson Charles Vaughi Alt. 1 Kamvina Gabrialle WeimerCOUNT | The Grand Jurors, aforesaid, in the name and behalf of the eitizens of Georgia, charge and aveuse MICHAEL ROBERT SCHULLERD AN and ERICA CLAUDETTE WHITE, ties concerned in the commission of a crime, with the offense of individually and as p MALICE MURDER, O.€.G.A. 16-3-1(a). for that the said! accused persons, in the County of and between the 6th day of November, 2014, and the 8th Cobb and State of Geor her, 2014, did unlawlilly, with malice aforethought, eause the death of Tyrael day of Nov codeine to said MeFall, a human being, by administering # preseription medication containin od onder. child which was not prescribed for said child, contrary to the hows of said State, the hereot peace and dignity COUNT 2 and the Grand Jurors. aforesaid, in the name and behall of the citizens af Georgia, further charge and accuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE, ission of a crime, with the offense of ties concerned in the co individually and as FELONY MURDER, O.€.G.A. 16-5-1(¢), for that the said accused persons, in the County of per, 2014, and the Sth Cobb and State of Geor ahout and between the 6th day of Nov it, 0 day of November, 2014, while in the commission of the offense of Aggravated Battery, a felony, as more specifically alleged in Count 3, did cause the death of Tyrael MeFall, a human being, by aulministering a prescription medication containing codeine to said child which was not preseribed for said child, contrary to th sac Jaws of said State, the good order, peace und dignity thereofCOUNT 3 and the Grand Jurors, aforesaid, in the name and behalf of the citizens of Geor and aceuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE individually ed in the commission of a crime, with the aflense of AGGRAVA day parties conces D BATTERY, O.C.G.A. 16. 4, for that the said accused persons, in the County of Cobb and State of Georgia. on, about and between the 6" day of November, 2014, and the 8th day of November, 2014, did maliviously cause bodily harm w Tyrsel MeFall, by depriving said child of his brain, « member of said child’s body, by administering a prescription medication containing codeine te said child whieh was not prescribed for said child, contrary to the lnws of said State, the good order, peace and dignity thereot COUNTS further char and the Grand Jurors, aforesaid, in the name and behalf of the citizens of Geor and accuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDE WHITE .. with the offense of individually and as parties concerned in the commission of a MARKING A FALSE STATEMENT, 0.C.G.A. 16. 0-20, for that the said accused persons, in the County of Cobb and State of Georgia. on or about the 10th day of November, 2014, did knowingly and willfully make a false statement to Detective Adam Payne in a matter within the jurisdiction of the Cobb County Police Deparment, a depariment of Cobb County government, to ation into the death of Tyrael MeFall, Michael wit during an interview arising out of the investiy, un at Governor's Gun Club on the evenin, Schullerman did state that he had fired a han November 8. 2014, contrary to the huws of said State. the good order, peace and dignity thereotCOUNTS and the Grand Jurors, aforesaid, in the name and behalf of the citizens of Georgia. fiuther charge and accuse MICHAEL ROBERT SCHULLERMAN nd ERICA CLAUDETTE WHIT individually and as parties concerned in the commission of a crime, with the offense of IDENTITY FRAUD, O 16-9-121, for that the said aveused persons, in the County of Cobb and State of Georgia, on or about the I8th day of August, 2014, did willfully and traudulently use identifying information of ‘Tyrael McFall, an individual under 18 years of a over whom she accused exereised custodial authority. to wit: said accused did use the name of ‘Tyrael McFall to activate # credit acount with Capital One Bank, tw wit: a Mastercard end numbers 6266, contrary to the laws of sitid State, the good order, peace and dignity thereo! COUNT 6 and the Grand Jurors, aforesaid, in the name and behalf of the citizens of Georgia, lurther char and accuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE, sion of a crime, with the offense of individually and as parties concerned in the com MAKING A FALSE STATEMENT, 0.C.G.A, 16-10-20, for that the suid aveused persons, in the County of Cobb and State of Georgia, on ar about the 26th day af Mareh, 20158, know and willfully make a false statement to Detective Adam Payne ina matter within the jurisdiction of the Cobb County Police Department, a department of Cobb County government. to wit: during an ion into the cause of the death of Tyrael MeFall, Erica White interview arising out of the inve did deny that she had been prescribed Codeine, contrary to the kays of said State, the good order, ce and dignity thereo!COUNT 7 and the Grand Jurors, aforesaid. in the name and behalf of the citizens of Georgta, further charge und accuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE, individually and as parties concerned in the commission of a crime, with the offense af IDENTITY FRAUD, O.C.G.A. 16-9-121, for that the said accused persons, in the County of Cobb and Stute of Georgia, on ar about the Wth day of April, 2018, did willfully and fraudulently use ideatifying information concern Tyrael MeFall, deceased individual. to wit said accused persons did use the name of Tyrtel MeFall to activate a credit account throw, Citibank, said account ending in numbers 877. contrary to the luws of said State. the good order peace and dignity thereat, COUNTS. and the Grand Jurors, aforesaid, in the name and behalf of the citizens of Georgia, further ehatr TE WHI und accuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDE individually and as parties concerned in the commission of a crime, with the offense of IDENTITY FRAUD, O.C.G.A. 16-9-121, for that the said accused persons, in the County of Cobb and State of Georgia, on or about the 15th day of April, 2015, did willfully and fraudulently use identifying information concer Tyrael McFall, a deveased individual. w wit said accused persons did use the name of Tyrie} MePall 1 activate a credit tecount from Capital One Bank, saicl account ending in numbers contrary to the laws of said State, the good order, nd dignity thereot peaceCOUNT O and the Grand Jurors, aforesaid, in the name and behalf of the citizens of Georgia further char and accuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE, individually and as parties concerned in the commission of a crime, with the offense af FINANCIAL TRANSACTION CARD FRAUD, O.C.G.A, 16-9-33, for that the said accused persons, in the County of Cobb and State of Georgia, on or about the 19th day of April, 2015, with the intent to defraud the issuer. to wit: Citibank, did uninwfully use « financial transaction card which the accused knew was obtained through a fraudulent application for the purpose af obtaining goods from Best Buy, said financial transaction card ending in numbers $773, contrary to the laws of said State, the good order, peace and dignity thereof COUNT 10 and the Geand Jurors, aforesaid, in the name and behalf of the citizens of Georgia, farther char ICHAEL ROBERT SCHULLERMAN and FRICA CLAUDETTE WHITE, ed in the commission of a crime, with the offense of individually and as parties conce FINANCIAL TRANSACTION CARD FRAUD, O.C.G.A, 16-9-33, for that the said accused persons, in the County of Cobb and § ue of Georgia, on or about the 20th of April, 2015, With the intent to defraud Capital One Bank, the issuer, did unlawiully use the financial transaction card account number of a financial transaction card whieh the accused knew was obtained through { fraudulent application for the purpose of obtaining goods and services through PayPal, said Financial transaction card being @ Mastercard with account number ending iat 2313, conteary to the ss of said State, the good order, peace and dignity thereolCOUNT 11 and the Grand Jurors, aforesaid, in the name and behalf ol the citizens of Georgia, futher ebar and accuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE, individually «las parties concerned in the commission of a erime. with the offense of FINANCIAL TRANSACTION CARD FRAUD, O.C.G.A. 16-9-33(a)(1), for that the said accused persons, in the County of Cobb and State of Georgia. on or about the 21st day of April, 2015, with the intent to defraud Capital One Bank, the issuer. did unlavwtlly use the financial transaction card account number of financial transaction card which the accused knew was: obtained throug! ) a fraudulent application for the purpose of obtaining services trom Delta Airlines, said financial transaction card bei a Mastereard with account number ending in 2313. contrary to the thereat .vs of said State, the good order, peace and ¢ COUNT 12 and the Grand Jurors, aforesaid, in the name and behal! of the citizens of Georgia, further charge and accuse MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE, individually and as pai ies concerned in the commission of a crime, with the olfense of FINANCIAL TRANSACTION CARD FRAUD, 0.C.G.A, 16-9-33, for that the said accused persons, in the County of Cobb and State of Geor the Sth day of May, 2015, with the intent to defraud Capital One Bunk, the issuer, did unlawfully use the financial transaction eard account number of a financial transaction card which the accused knew was obtained through a fraudulent application for the purpose of obtaining goods from Thomas Drugs, said financial uansaction card being a Mastercard with account number ending in 2313. contrary 4o the laws of vod order, peace and dignity thereofCOUNT 13 and the Grand Jurors, aforesaid. in the name sind hehall'of the citizens of Ge ‘gia, firther charge and accuse MICHA fL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE with the offense ef VIOLATION OF RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT ~ CONSPIRACY TO ACQUIRE MONEY THROUGH A PATTERN OF RACKET ING ACTIVITY, O.C.G.A. V6-14-4(¢). for that the said accused persons. in the County of Cobb and State of Georgia. on, about. and between the 12" day of Mareh, 2013, the 20" day of May, 2015, did unlawfully conspire w acquire, directly and indirectly, control of money and personal property thro zh the patiern of racketecrin wctivity alleged in Counts 1-4 above, and in Predicate Acts S41 below, eae incorporated herein by reference. contrary to the kiws of said State, the good order, peace and dignity thereat 11 - Scheme Summary +r to support her lifestyle, drug habit and to obtain a fife tree of the care of a disabled udette White (°White”), slong with her co-defendant boyfriend, Michael Rabert Sehullerman (“Schullerman”), conspired and endeavored in a scheme to obtain money and property through the overt and predicate acts below aind by subsequently poisoning Tyrael MeFatl “Tyrael”) to death through codeine toxicity. Specifically, on October 29, 2012. when Ty was eight weeks old, his father Joseph Rucker McFall (“McFall”), severely and permanently injured him through the inflietion of blunt force trauma to Tyracl’s head and brain, On April 17, 2014, MeFall pled g gravated Battery and was sentenced to twenty years in prison, Around this time White met co-defendant Sehulle 1, through an online dating service. 1 to be with White in and around th Schullerman eventually moved trom Florida to Geo summer of 2014, and the twe resided together in White’ home located st 63 13 Wellington Way Austell. Shortly thereatier. White and Schullerman engayed in a scheme to detfaud banks and commercial providers of goods and services through the misappropriation of Tyrael’s idemt yininformation in order to access lines of eredit and cash advances in said child's name and by’ using a variation of said child's date of birth, Purehases included food, clothing, cleetronies and other household items, Late in the evening of November 2, 2084, White was transported vis ambulance to Cobb Hospital for pain she was experiencing from a urinary Iract infection, White requested medication for pain management and was preseribed Tylenol with codeine. A preseription for the same was filled and retrieved at approximately 11:24 a.m. the next day at the family’s long time pharmacy, Thomas Drugs, located in Austell, Georgi On November 5, 2014, Tyrael underwent an outpatient procedure with Chiblren’s 4 altheare of Atlanta (°CHOA”) wherein a mechanival devive was implanted into the child's neck to lessen the number and degree of his seizures. 1 no time did any CHO physician prescribe any medication containing codeine On November 6, 2014, White visited Reproductive Biology Associates (°RBA”) located in Marictts, Georgia, On November 7, 2014 White and Schullenman applied for a $20,000 loan through RBA with an Arizona company by the name of CapexMD, LLC, The application was immediately denied and an email stating the same was sent t@ White the same day ‘The day after the denial of the $20,000 loan, on the evening af November 8, 2014, White and Schullerman decided to set up a “date night” at Governors Gun Club located in Powder Springs. Georgia, Previously. White and Schullerman had activated the most expensive members p level there, the family “Platoon” membership, on October 26, 2014 and that 2014. membership had been used one time previously on October 2 With a potential alibi in place, in order to go out the night of November 8, 2014 White and Schullerman requested that White's daughter, Sierra Porter (“Sierra”), come to the house to sit with Tyrael, Sierra was promised $20 in addition to food for her and her husband, Tyler Porter }. which White and Schullerman would bring home later, White and Schullerman lett their home located at 6313 Wellington Way. A approximately §:00 pan, and returned home between 9:15 - 9:30 pam. that evening, While they were away from home, White and Schullerman called Sierra to see how Tyriel was doing, and White insisted that Sieera lay with:‘Tyrael in the bed. Onee White and Schullerman returned. Sierra and Tyler remained at the home for approximately an hour and ate the food purchased for them by White and Sehullerman belore returning to their home across the street. AU 10:43 p.m. a 911 call was received by Austell Police aand Fire and uniis responded to the home io find Tyrael on the living room Moor and no! bre: Fyravt was transported to Cobh Hospital by Puckett EMS and was pronounged dead at 11:24 p.m on November 8, 2014, ln the months to follow, as enumerated in the avert and predicate aets below, White and Schullerman continued their schem © to financially exploit ‘Tyrael in death to inelude the use ofa home computer, « laptop. to create false documents for Tyrac! and to communicate with banks and merchants using accounts and account information pertaining to Tyrael MeFall, Records from multiple accounts show that both White and Schullerman accessed said accounts and benetited from the fraudulent activities 11 Pattern of R: cketeering Activity ‘The acts below in concert with the scheme above constitute a conspiracy to engage in a patter of racketcering activity in that they were committed in furtherance of one or more incidents, schemes or transactions that had the same or similar intents. results, accomplices, victims or methods of commission or otherwise were interrelated by distin, Part Il1- Overt Acts and Predicate Acts of Racketee! The defendanis committed, attempted to commit, and conspired to commit the overt ated below, which are cha jaws of this state and which constitute “ricketecring activity’ OVERT ACTS. Act #5: Social Security Thefts Prior to his 2014 conviction for harming Tyrael. MeFall was eligible to receive Social Security benefits as a disabled person, and these payments were made t McFall via direet depositnl of S800, As the child of McFall, inlet draw fon a monthly basis in the amo Social Security benelits on his tather’s record as a minor, and that amount was paid at S66 per month for the benetit of Tyrael until he reached the age of 16 years, Because Tyrael was a minor he necded an adult capable of receiving said benetits on his behal!, anc the person assigned 10 serve in this capacity was his mother, Erica White. As a person caring for Tyrael, Defendant White was alse entitled to $66 per month for herself! These payments for Tyrael, totaling $132 per month (S66 x 2}, were deposited directly into a bank account designated by White.! Because the monthly payments fiom the Social Security Administration (SSA) for yracl’s benefit were only available if Tyrael was both living and under the age of 16 years. ‘yrael"s eligibility for these funds ceased upon his death on November 8. 2014, Therefore, Tyrael’s dat s of eligibility were September. 2012 = October. 2014. It was the doty and responsibility of White, as the receiver of these payments. to notily the SSA of Tyrael’s death, White never provided such notification, However, White diet vontaet the SSA on November 10, 2014, two days after Tyracl’s death, to request that Tyrael’s benelits be deposited into a different account than the one the SSA kad on file. On December 5. 2014 the S SA mailed two letters to White at 6313 Welli on Way, Austell to inform her that, duc to Tyrael's death the previous month, White was ne longer qualitied to receive any benelits fiom the SSA which stemmed from her care of Tyrael or for Tyrael’s benefit. One letter explained that “Tyrael McFall is not entitled to monthly benelits beginning November 2014, We cannot pay benefits for the month of death, or later.” The second letter further explained to White “You no longer qualify for Social Security benetits starting November 2014 because of the loss of your child Tyrael MeFall. To qualify, you must be taking care of a child who is entitled to benefits, That ehiid must be under age 16 or disabled.” Even though the SSA did immediately recall Tyrael's December. 2014 monthly payment of S675 «lt his own social security ming from his personal disability payments eonneet "Tyrael was found tw be a disabled person following his injuries hy Joseph MePall un October 29, 2012 Tyrael received monthly payments of S675 per mouth which were deposited int Defendant's bank account on Tyrael’s behalf. There was only one payment deposited tor $675 Follow wel's death, which occurred on 12/1/2014, but these funds were immediately reclainned by the United States Treasury on the same daynumber, Tyrael’s benetits through MeFall’s social security number continued to be paid in mnonthly installments of $66 for Tyrael and S66 for White five the child, ty fhe parent arin wasn’t until a state electronic d ath report generated tw the SSA on May 20, 2015 d benefits were cut off Additionally, White committed fraud upon the SSA by maki patterial misrepresentations in her request to be selected as a payee for Tyrael, and at the sume time continued to collect and dispose of MeFall’s Si si (00 SSA deposit after MeFall was confined and convicted on April 17. 2014 s liunded ificantly. McFall was no longer entitled to receive any SSA benelits while his cares through the Geor he funds obtained throug! 1a Department of Corrections, White's fraud on the SSA were used for the benefit of the household in which Schullerman and White shared, Act #6: Solicitation of Money on Social Media L. Facebook Facebook is social me a application, Macebook us ss have the cay bility to post articles and oth + comtent to a protile they create and maintain, and users can alse communicate privately with others using the direct messige funetion, On January 2013, White, using the protile “Teract McFall Helping Hand Func” and listing herself as the administrator, posted links to fundraiser requesting donations through “widget.chipin.com” with the stated purpose being for the sole care and henefit of Tyrael MePall 2. Giveforward Giveforward is a community fundraising website where anyone can create & fundraiser lor themselves. a family member or someone they know, must commonly to assist with the costs o! medical bills, equipment and treatments. Afier Tyrael was injured by McFall, White ereated at : Fundraiser in her own name as the “Team Captain” with the title “Tyrael’s Medical Fund.” o Included on the fundraiser page were stories and photographs of Tyrael and a request for $35,000. ty The fundraiser was closed on January 30, 2014 afier collection of only $75Act #7: White’s Palse Statements in het ids from the BRAIN AND SPINAL INJURY TRUST FUND application and collection of fu av the Na 1 Mefall ne of Ty The Brain and Spinal Injury Trust Fund Commission (BSITEC’) is located in Atlant residents for post-actte care and rehabilitation for Georgia. BSITEC provides grants to Gieor uraumatic brain and spinal eord injuries On March 12. 2013, White submitted an appheation to BSITFC requesting a grant in the ion for Tyrael to and amount of $10,000 towards the purchase of a vehiele 10 provide transpo from his medical appointments. In the applicition for vehicle purchase assistance, White fisted a monthly income from all sources of $6632 Before her applivation could be approved and the vequested funds could be distributed, White was required to provide medical documentation of ‘C. White then submitted a letter from Dr. Rogen L, Miller (*Dr. ‘Tyrael’s condition to BSIT! Mille ") with the Wellstar Pediatrie Group, dated March 22. 2013. which contirmed that Tyrael had a diagnosis of “traumatic brain injury.” White later provided vehicle purchase quotes to BSITFC for a 2011 Volkswagen Jetta, « 2013 Chrysler Dodge Journey and a 2012 Chevrolet Equinox. White's application was approved first by BSITFC on May 23, 2013. and then by the arded $10.00 by Governor of the State Georgia on June 17, 2013, and she was subsequently a the BSITEC. On October 1, 2013 White amended her application with BS o further include an auditional $5000. The request was initially made for funds to assist with therapy for Tyrael, but was then changed to a request of $5000 for home modifications, whieh White stated would be completed by her unnamed uncle. White was notified by BSITFC that the requested home improvements would not be made available for such use unless and until a BSITFC approved contractor was identified to pertiorm the work ice for Tyr Act #8: White's applic: ad acquisition of L ion On March 26, 2013 White obtained life insu we with Stile Farm Lile Insurance Ince COV Company (State Farm”) in the amount of $50,000, ‘This policy aumber wes: LF-3279-2746 and ats obtained ot the Social Seeurily Administration prove that White’s anoathly ewe was in excess of declared in the BSITEC application, Docu the amuthe proposed insured was Tyrael MeFall, The primary beneficiary was White, and White's mother Laura Cramer. was the successor bencligiary, White was simultaneously pursuing donations from BSITFC. White had access io medical documentation she requested from Wellstar physician Dr. Miller to establish Tyrael’s pre-eaisting condition of at matic brain injury. which she provided to BSITFC with a date of Mareh 22, 2013. White omitted this information trom conversations with State Farm Agent Robert Ashley and the lite insurance application documents signed just 4 days later On July 1013 White obtained a second (re icement) life insurance poli -y with State Farm, with slightly different terms. the amount of $50,000, ‘This policy number wa LF-3232-9866. The proposed insured and beneficiaries remained unchanged. White continued to conceal Tyrael’s pre-existing condition Act #9: White's fraudulent acceptan Coordinating Council of Geor oney through the Criminal Justice ‘The Criminal Justice Coordinating Cauneil (*CICC) of Gea «vis a State ageney which administers programs providing direct services and financial grants to vietims of crime. The CICC isa payer of last resort and certain requirements must be met before funds can be distributed. Eligible applicants may receive compensation benetits up to $25.000 throug! Crime Victims Ci the pensation Program (*CVCP") to help with medical and! dental eare, mental health counseling, economic support, crime scene clean-up, and funeral expenses when the wosts are not covered by a thir party payer On May 14, 2013 White began filing claims for benefits through the CICC based upon Tyrucl’s prior victimization by MeFail in October. 2012. Among these claims was Joss of economic support, which would cover wages White lost as a result of her eare for Tyrael aier be was injured. Aithough the total amount allowable from CVCP is $25,000 per victimization, the maximum amount allowable for this catey ury of benetit under the CVCP guidelines is $10,000, On September 26, 2014, White faxed «forged letter to the CICC purportedly trom the huernational School of Curacan (1SC°) with a tax number of ( 485-8447, This fax was two pages in total and ineluded « cover sheet and forg letter purportedly written by Jennifer van Gricken of the ISC. which stated that White was employed 38 uwwith ISC “fiom August 2012 to August 2013 ancl went on unpaid family leave from November 2012 to April 2013. Her monthly salary was 5180.86 ANG which converted te 3640.00 USD per nionth.”* Upon receipt of this correspondence. check #000044254 | in the amount of $10,009 wits written on an acount that of nated with the Georgia Bureau of Investivation to White, and which White later deposited into her cheeking account oa or about October 23, 2014. Act HL: Whi s Application for a Medical Services Li Gn October £6, 2014, White sent an email 10 RBA secking to schedule an appointment at the Marietta, Georgia office. On November 6, 2014. the day follow Tyrael’ outpatient procedure at CHOA, White visited RBA for suid appointment to initiate fenility treatment services tor the stated purpose of conceiving a child with her live-in boyfriend, Schullenman, whom White referred to as her “fiancé” when communicating with RBA, White paid $250 for this visit Because fertility treatment is not commonly covered by insuruice, RBA vffers fertility financing options through CapexMD, LLC located in Scottsdale. Arizona, On November 7. 2014 one day before Tyrael’s death, White applied for a loan in the amount of $20,000 through CapesMD. LLC. White listed Schullerman as a eo-borrower and provided a phone number ned to be that of Schullerman through T-Mobile records. On White's loan application, and under penalty of law, White made substantial misrepresentations to include an attestation of monthly income in the amount of $5,180, other income of $1400 and that she was employed as a teacher with ISC, in stark contrast to the representations that she made just months earlier to BSITEC, Act #11: White's Conspiracy to Commit Tay Fraud On December 17. 2015 White contacted ane! instructed her mother to File tay return for the year 2015 on White's behall listing two of White's grandchildren as dependents for the year 2013 so that the United States Treasury would issue a tax credit for the care of these two minor candchildeen for which White was not legally entitled docennented upon veceipt ofthis Fayed etter, bet there is neAdditionally. White previously collected a tax eredit for an individual by the Debra” (LNU), a person not related t White and whom White had not provided eare, al MeFall's name but fraudulent Act #12-16: Obtaining Credit Cards us information. After White applied for the following financial transaction cards in the name of T birth of $/30/1992, White and Schullermuan used the following cards Tor [ Contact fo Used McFall using a false date o} Card [Acta [ App Capital One Platinum Niawtereard | **6266_| S804 | White's phone and email | 13 [IP MorganiChase FIOS | QAO | White's phone and email | Schullecman’s work phone Treat Bayi FAT | AOBOIS [White's phon Capital One Quicksilver Mastereard | **2313 | a/13/2013 | White's phone and email Schullerman’s cell phone Lr Ta | Bank of America Visa I Act #17-20: Attempting to Obtain Credit Cards using Vyrael MeFall’s name but fraudulent information. White and Sehullerman also applied for the following wansaction cards in the name of Tyrael McFall using a false date of birth of $/30/1992 and a false driver's license number Net Applied For | Contact Info Used ee 7 WiOI201S Whites phone and email Schullerian’s cell phone 18 [Amazoncomeard | 1228/2014 | White's phone and email | 19 | Walhar [eemanTs White's phone ant eri an | Schullermian’s cell phone 2 | WalMart 19720) White's phone and enil alSPECIFIC PREDICATE ACTS OF RACKETEERING ACTIVITY Theft hy Taking, O.C.G.A, 16-8 MICHAEL ROBERT SCHULLERMAN J ERICA CLAUDETTE WHITE, individually nd sts parties concerned in the commission of a er did commit and attempt tw commit the offense of Theft by Ta ing, O.C.G.A. $16- 2, for that the said accused persons, in the County of Cobb and State of Georgia, on the dates and amounts listed below and incorporated herein by reference, did unlawfully cand 3 empt to tike, money, the property of Fyrae! MeFall, with the intent to deprive said owner of said property, as enumerated below, which constitutes racketeering activity pursuant 0 O.C.G.A, $16-14-3 (S)(A)ixii), which is racketeering activity under 0.C.G. A. § 16-14-3, contrary to the laws of said State. the good order, peace a dignity thereof ‘Act_| Date Scope of Condu 1 2 p01 io eash a $30,000 life insurance policy on Tyrael McFall thai misrepresentanions, «utomey (0 sue hospital where Tyrael McFall hail his surgery wrongful death when, in fact, she and Schuller 22 PTO [erica White hire allegi wan were responsible for his 23 2013 | Michael Schullerman purchased a plane ticket to Texas with Capital One Quicksilver Mastercard vthe name of Tyrael McFall and using a fenudulent date of birth, 24 [S/SRO1S | Michael Schullerman attempted to purchase medications Tor Eriea White at Thomas Drugs with Capital One Quicksilver Master ais the account was over its limi ‘ALT1:09 am, Michael Schollenman attempted to make 8 57.00 parehase at Delta | 13. The purchase was declined 23, | 2072015 Airlines in Atlanta, Georgia with Capital One Quicksilver Mastercard 2313. The purchase was declined as the account was over its limit 7 26 [SAORI | ALTT:1T am., Michael Schullermman attempted to make a S700 purchase at Deha Airlines in Atlanta, Georgia Capital One Quicksilver Mastercard **2313. The | purchase was declined! asthe aecount was over its fini 27 | S2072013 | AI9IO:ET pm. Michael Schullerman atrempted w purchase Suarise Mini Maat Austin, Tesas with Capital One Platinum Mastercard *%6266. The purchase was declined as wats over its imi S73W7BOTS [Av HLISA pm, Michael Schullermanattcmpied iv lke purchase at Sunrise Min | Manin Austin, Texas with Capital One Platinum Mastercard *6266."The purchase wae devlived as the aeeaunt was ever ils Kimi _ OATS | Michael Schullermn attempted to purelase food wt Olive Carden wn Rileen, Texas with Capital One Quicksilver Mastercard *#2313. The purchase was declines the 0B. Identity Fraud O.C.G.A. $16 21(a)(3) MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE, ally and as parties concerned in the commission of a er IDENTITY FRAUD, O.C.G.A. 16-9-121(4 did commit the offense of (3), for that the said! accused persons willfully and Faudulently, in the County of Cabb and State of Georgia, on the dates listed below and incorporaied herein by reference, did use and possess with intent to fraudulently use identifying information concerning a deceased individual, Tyrael McFall, by using his name to obtain eredit cards listed below and incorporated herein by reference, which is racketeering activity under OCGA. § 16-143 contrary to the laws of said State, the good order, peace and dignity thereof Neat [Date 71 *T105 [ras | 9773 | araraos | i | WTOFOTS | [23 | ansAos — ans 7© y Fraud O.C.G.A. §16-9-121(a)(3) MICHAEL ROBERT SCHULLERMAN and ERICA CLAUDETTE WHITE, individually and as parties concerned in the commission of a crime, did commit the offense of IDENTITY FRAUD, O.C.G.A, 16-9-121(4)(3), for that the said accused persons will fully and fraudulently, in the County of Cobb and State of Georgia, om the dates fisted below and incorporated herein by reference, did use and possess with iment 10 fraudulently use identifying information co ering a an individual, to wit: Tyrae] MeFall, under 18 years old over whem she exercised custodial authority, by using his name to obtain credit card Capital One Platinum Ma **6266, which is racketeering activity under O.C.G.A. § 16-14-3. contrary to the laws. al of said State, the good order, peace and dignity thereof ‘Act | Date Scope of Acit GAVIONS | Michael Schallemnan purchased a plane Wekt so Tess with Capital One Quicksilver Mastercard #42313 in the name of Tyre! MeFall ad us Fraudulent date of birth 3 | Micl Thom Schullernian aticmpled to purchase medications fav Dries White at 's Drugs with Capital One Quicksilver Master was declined as the account was ever its limit 37 [32072015 [ALI am., Michael Schullerman attempted to make a S700 purchase at Delia Airlines in Atlanta, Geo sand **2313. The purchase with Capital One Quicksilver Mastereard #2313. The purchase was declined as the account was over its limi 38 [SA0R01S [ALTTTT am. Michael Schallerman attempted to make a $7.00 purchase at Delia Airlines in Atlanta, Georgia Capital One Quicksilver Mastercard **23 The purchase was declined as the account was over its Hint 39 | SAWAOIS [ALS:19-11 pm, Michacl Schallerman attempted te make a purchase at Sunrise Mini Mae in Austin, Texas with Capital One Platinum Mastercard 46266. 1 urehase was declined as the ve its Hine 9:19: Tichael_ Schull Mini Martin Austin, Texas with Capital One Platinum Mastercard #46266, pin. pied fo make a purchase at Sunrise The purchase was dectined as the account was aver its Limit 20S | Michael Schullemaav an Texas with Capital One Quicksilver Mastercard **2313. The purchase was a Olive Garden in Killeen mpled te purchase foo declined as the account was over its finnit D. VICTOR REYNOLDS. District Auorney