IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF TENNESSEE

WESTERN DIVISION

UNITED STATES OF AMERICA, ) )

Plaintiff, ))

vs. ) Cr. No. )

MELISSA HARRIS, ) 18 U.S.C. ' 371ERIN CRUTCHER, ) 18 U.S.C. ' 641ANGELA JACOCKS, ) 18 U.S.C. ' 1028A(a)(1)BREUNCA SUTTON, ) JENNIFER FREEMAN, )and VIVIAN SHOLAR, ) )

Defendants. )

I N D I C T M E N T

THE GRAND JURY CHARGES:

INTRODUCTION

A. At all times material herein:

1. Defendants MELISSA HARRIS, ERIN CRUTCHER, ANGELA JACOCKS,

BREUNCA SUTTON, JENNIFER FREEMAN and VIVIAN SHOLAR resided in Shelby

County, Tennessee, within the Western District of Tennessee.

2. A "means of identification" was any name or number that may be used, alone or

in conjunction with any other information, to identify a specific individual, including a

name, social security number or date of birth.

3. The Internal Revenue Service ("IRS") was an agency of the United States

Department of the Treasury responsible for enforcing and administering the tax laws of

the United States, and collecting taxes owed to the United States.

COUNT 1

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. Beginning in the summer of 2010, the exact date being unknown to the Grand

Jury, and continuing up to and including July 27, 2011, in the Western District of

Tennessee, and elsewhere, the defendants,

MELISSA HARRIS,ERIN CRUTCHER,

ANGELA JACOCKS,BREUNCA SUTTON,JENNIFER FREEMAN

andVIVIAN SHOLAR

did unlawfully, knowingly and willfully combine, conspire, confederate and agree with

each other and persons unknown to the Grand Jury to commit certain offenses against

the United States of America, that is:

a. Title 18, United States Code, Section 641, which prohibits the theft of

public money or anything of value of the United States of America.

OBJECT OF THE CONSPIRACY

3. It was a principal object of the conspiracy for the defendants to profit financially by

stealing money belonging to the IRS and the Department of the Treasury, agencies of

the United States, by filing false tax returns and by directing the fraudulent tax refunds

generated by said false tax returns to bank accounts controlled by the defendants. The

total amount of loss to the United States was approximately $1,366,234

.

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MANNER AND MEANS OF THE CONSPIRACY

4. MELISSA HARRIS and ERIN CRUTCHER and others, both known and unknown

to the Grand Jury, would and did obtain stolen identity information such as names,

Social Security numbers and dates of birth. In some instances, this information was

unlawfully obtained from high schools in Memphis, Tennessee.

5. MELISSA HARRIS and ERIN CRUTCHER would and did use this information to

prepare and electronically file fraudulent federal income tax returns that falsely claimed

refunds.

6. ANGELA JACOCKS, BREUNCA SUTTON, JENNIFER FREEMAN and VIVIAN

SHOLAR agreed to participate in the conspiracy by opening bank accounts for the sole

purpose of receiving the tax refund proceeds generated by the fraudulent tax returns.

7. After opening their bank accounts, ANGELA JACOCKS, BREUNCA SUTTON,

JENNIFER FREEMAN and VIVIAN SHOLAR gave their account information to

MELISSA HARRIS and ERIN CRUTCHER, who then directed the tax refunds into

these accounts. The bank accounts received over $1.3 million in fraudulent tax refunds

generated by approximately 892 false claims.

8. Each of the conspirators received part of the refunds for their personal benefit and

use.

OVERT ACTS

9. In furtherance of the conspiracy, and to effect the objects thereof, the following

overt acts, among others, were committed by or caused to be committed by one or

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more members of the conspiracy, in the Western District of Tennessee, and elsewhere:

10. Between on or about August 6, 2010 and July 27, 2011, MELISSA HARRIS

recruited ANGELA JACOCKS, BREUNCA SUTTON, JENNIFER FREEMAN and

VIVIAN SHOLAR to open bank accounts for the purpose of receiving the tax refund

proceeds generated by fraudulent tax returns.

11. Between on or about August 6, 2010 and July 27, 2011, MELISSA HARRIS and

ERIN CRUTCHER unlawfully obtained personal identifying information of victims,

including high school students, and used this information to electronically file false

federal income tax returns claiming refund amounts. They directed the refunds to be

deposited into the bank accounts of ERIN CRUTCHER, ANGELA JACOCKS,

BREUNCA SUTTON, JENNIFER FREEMAN and VIVIAN SHOLAR.

12. MELISSA HARRIS and ERIN CRUTCHER prepared and filed, and caused to be

prepared and filed numerous false federal income tax returns, including those in the

name of each of the following individuals whose initials are listed below, on or about the

date and claiming a refund in the amount listed below:

Paragraph Individual Date of Filing Refund Claimed Deposit Bank Account

13. VT 1/31/2011 $1499 -9311

14. NL 3/3/2011 $3545 -9311

15. DJ 4/11/2011 $1480 -0122

15. CJ 5/12/2011 $1387 -9311

16. DW 5/11/2011 $1387 -0122

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17. Between on or about August 6, 2010 and March 14, 2012, ANGELA JACOCKS

received into her bank accounts at least 237 electronic refund deposits from the United

States Treasury Department totaling approximately $389,342.

18. Between on or about March 18, 2011 and June 3, 2011, BREUNCA SUTTON

received into her bank accounts at least 293 electronic refund deposits from the United

States Treasury Department totaling approximately $436,720.

19. Between on or about April 29, 2011 and June 10, 2011, JENNIFER FREEMAN

received into her bank accounts at least 126 electronic refund deposits from the United

States Treasury Department totaling approximately $183,337.

20. Between on or about March 18, 2011 and May 27, 2011, VIVIAN SHOLAR

received into her bank accounts at least 236 electronic refund deposits from the United

States Treasury Department totaling approximately $356,835.

21. On or about May 20, 2011, MELISSA HARRIS and ERIN CRUTCHER were

found in possession of several stolen high school student rosters containing personal

identifying information.

22. Between on or about March 18, 2011 and June 3, 2011, ANGELA JACOCKS,

BREUNCA SUTTON, JENNIFER FREEMAN and VIVIAN SHOLAR made over 160

withdrawals from their bank accounts totaling approximately $1,030,679.

All in violation of Title 18, United States Code, Section 371.

COUNTS 2-5

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

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2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS and

ERIN CRUTCHER

being aided and abetted each by the other, did knowingly steal, purloin, and convert to

their own use and the use of another, money of the United States, namely funds in the

amount listed below, administered by the Department of the Treasury in the form of a

federal tax refund in the name of the individual whose initials are listed below, which

was deposited into the bank account listed below, which funds the defendants knew

they were not entitled to receive:

Count Date of Deposit

Individual Amount Bank Account Number

2 3/4/2011 JW $3563 SunTrust -5100

3 4/15/2011 RB $3565 1st TN -2155

4 5/6/2011 ES $1407 1st TN -4995

5 3/18/2011 DR $3545 1st TN -0122

All in violation of Title 18, United States Code, Section 641.

COUNTS 6-9

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

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MELISSA HARRIS and

ANGELA JACOCKS

being aided and abetted each by the other, did knowingly steal, purloin, and convert to

their own use and the use of another, money of the United States, namely funds in the

amount listed below, administered by the Department of the Treasury in the form of a

federal tax refund in the name of the individual whose initials are listed below, which

was deposited into the bank account listed below, which funds the defendants knew

they were not entitled to receive:

Count Date of Deposit

Individual Amount Bank Account Number

6 3/4/2011 JW $3563 SunTrust -5100

7 2/11/2011 LT $3597 SunTrust -5100

8 4/22/2011 AS $1477 SunTrust -5100

9 4/22/2011 DS $1477 SunTrust -5100

All in violation of Title 18, United States Code, Section 641.

COUNTS 10-13

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS

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and BREUNCA SUTTON

being aided and abetted each by the other, did knowingly steal, purloin, and convert to

their own use and the use of another, money of the United States, namely funds in the

amount listed below, administered by the Department of the Treasury in the form of a

federal tax refund in the name of the individual whose initials are listed below, which

was deposited into the bank account listed below, which funds the defendants knew

they were not entitled to receive:

Count Date of Deposit

Individual Amount Bank Account Number

10 4/15/2011 RB $3565 1st TN -2155

11 3/18/2011 AS $3555 1st TN -2155

12 3/18/2011 DJ $3580 1st TN -2155

13 4/15/2011 QC $1481 1st TN -2155

All in violation of Title 18, United States Code, Section 641.

COUNTS 14-17

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS and

JENNIFER FREEMAN

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being aided and abetted each by the other, did knowingly steal, purloin, and convert to

their own use and the use of another, money of the United States, namely funds in the

amount listed below, administered by the Department of the Treasury in the form of a

federal tax refund in the name of the individual whose initials are listed below, which

was deposited into the bank account listed below, which funds the defendants knew

they were not entitled to receive:

Count Date of Deposit

Individual Amount Bank Account Number

14 5/6/2011 ES $1407 1st TN -4995

15 5/6/2011 SP $1407 1st TN -4995

16 5/6/2011 CW $1377 1st TN -4995

17 5/6/2011 KT $1387 1st TN -4995

All in violation of Title 18, United States Code, Section 641.

COUNTS 18-21

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS and

VIVIAN SHOLAR

being aided and abetted each by the other, did knowingly steal, purloin, and convert to

their own use and the use of another, money of the United States, namely funds in the

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amount listed below, administered by the Department of the Treasury in the form of a

federal tax refund in the name of the individual whose initials are listed below, which

was deposited into the bank account listed below, which funds the defendants knew

they were not entitled to receive:

Count Date of Deposit

Individual Amount Bank Account Number

18 3/18/2011 DR $3545 1st TN -0122

19 3/25/2011 CR $3150 1st TN -0122

20 3/25/2011 DS $3560 1st TN -0122

21 3/25/2011 SR $3175 1st TN -0122

All in violation of Title 18, United States Code, Section 641.

COUNTS 22-25

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS and

ERIN CRUTCHER

being aided and abetted each by the other, knowingly used the means of identification

of other persons without lawful authority during and in relation to the offenses in this

Indictment described as Related Counts below, that is, the defendants used the names

and Social Security numbers of the persons identified by their initials below, to commit

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theft of public funds in violation of Title 18 United States Code, Section 641 by obtaining

income tax refunds in the amount listed below:

Count Date of Offense Related Count Individual Refund Amount

22 3/4/2011 2 JW $3563

23 4/15/2011 3 RB $3565

24 5/6/2011 4 ES $1407

25 3/18/2011 5 DR $3545

All in violation of Title 18, United States Code, Section 1028A(a)(1).

COUNTS 26-29

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS and

ANGELA JACOCKS

being aided and abetted each by the other, knowingly used the means of identification

of other persons without lawful authority during and in relation to the offenses in this

Indictment described as Related Counts below, that is, the defendants used the names

and Social Security numbers of the persons identified by their initials below, to commit

theft of public funds in violation of Title 18 United States Code, Section 641 by obtaining

income tax refunds in the amount listed below:

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Count Date of Offense Related Count Individual Refund Amount

26 3/4/2011 6 JW $3563

27 2/11/2011 7 LT $3597

28 4/22/2011 8 AS $1477

29 4/22/2011 9 DS $1477

All in violation of Title 18, United States Code, Section 1028A(a)(1).

COUNTS 30-33

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS and

BREUNCA SUTTON

being aided and abetted each by the other, knowingly used the means of identification

of other persons without lawful authority during and in relation to the offenses in this

Indictment described as Related Counts below, that is, the defendants used the names

and Social Security numbers of the persons identified by their initials below, to commit

theft of public funds in violation of Title 18 United States Code, Section 641 by obtaining

income tax refunds in the amount listed below:

Count Date of Offense Related Count Individual Refund Amount

30 4/15/2011 10 RB $3565

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31 3/18/2011 11 AS $3555

32 3/18/2011 12 DJ $3580

33 4/15/2011 13 QC $1481

All in violation of Title 18, United States Code, Section 1028A(a)(1).

COUNTS 34-37

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS and

JENNIFER FREEMAN

being aided and abetted each by the other, knowingly used the means of identification

of other persons without lawful authority during and in relation to the offenses in this

Indictment described as Related Counts below, that is, the defendants used the names

and Social Security numbers of the persons identified by their initials below, to commit

theft of public funds in violation of Title 18 United States Code, Section 641 by obtaining

income tax refunds in the amount listed below:

Count Date of Offense Related Count Individual Refund Amount

34 5/6/2011 14 ES $1407

35 5/6/2011 15 SP $1407

13

36 5/6/2011 16 CW $1377

37 5/6/2011 17 KT $1387

All in violation of Title 18, United States Code, Section 1028A(a)(1).

COUNTS 38-41

1. The factual allegations contained in Paragraphs 1 through 3 of the Introduction

Section of this Indictment are realleged and incorporated herein as if copied verbatim.

2. On or about each of the dates listed below, within the Western District of

Tennessee, the defendants,

MELISSA HARRIS and

VIVIAN SHOLAR

being aided and abetted each by the other, knowingly used the means of identification

of other persons without lawful authority during and in relation to the offenses in this

Indictment described as Related Counts below, that is, the defendants used the names

and Social Security numbers of the persons identified by their initials below, to commit

theft of public funds in violation of Title 18 United States Code, Section 641 by obtaining

income tax refunds in the amount listed below:

Count Date of Offense Related Count Individual Refund Amount

38 3/18/2011 18 DR $3545

39 3/25/2011 19 CR $3150

40 3/25/2011 20 DS $3560

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41 3/25/2011 21 SR $3175

All in violation of Title 18, United States Code, Section 1028A(a)(1).

A TRUE BILL:

F O R E P E R S O N

DATE:

EDWARD L. STANTON IIIUNITED STATES ATTORNEY

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