54 Defendants Charged in $18 Million Food Stamp Fraud Conspiracy

INDICTMENT NO.
gp414-184
VIO: 18 U.S.C. 1349
Mail & Wire Fraud Conspiracy
18 U.S.C. 1956(h)
Money Laundering Conspiracy
Forfeiture Allegation
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UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA
V.
BRANDON SAPP,
a/k/a "B,"
KIMBERLY SAPP,
a/k/a "Kimberly Walker,"
a/k/a "The Money Wizard,"
CALVIN WILLIAMS,
a/k/a "Slick,"
ISAAC MARTIN,
a/k/a "Ike,"
JOHN P. JONES,
a/k/a "JP,"
WAYNE JACKSON,
a/k/a "15,"
GREGORY THOMAS,
a/k/a "Rich Greg,"
KERRY ADAMS,
a/kla "Big Skreed,"
a/k/a "Skrump,"
BRIAN LOCKHART,
a/k/a "Lock,"
HENRY WARD,
a/k/a "TY,"
a/k/a "TYE,"
a/k/a "Grand Hustle,"
VINCENT HARPER,
OSTRANDO S. BROCK,
a/k/a "Shun,"
a/k/a "Shawn,"
JESSE MCCOY,
a/k/a "Jay Mac,"
TERENCE COSBY,
Case 4:14-cr-00184-WTM-GRS Document 3 Filed 06/04/14 Page 1 of 34
a/k/a "Me Gold,"
)
RAYMOND HARGROVE,
)
JACQUELINE BEAUCHAMP,
)
a/k/a "Jackie,"
)
ELIZABETH BEAUCHAMP,
)
GERALD PATILLA,
)
a/k/a "PT,"
)
CLAYTON TALLEY,
)
EBONY JACOBS,
)
OLAJA WON SIMMONS,
)
a/k/a "Wan,"
)
a/k/a "Won,"
)
REGINALD SIMMONS,
)
a/k/a "Reggie,"
)
GARY CRIER,
)
a/k/a "Bundee,"
)
a/k/a "Dee,"
)
MAGREGOR WARNER,
)
a/k/a "KB,"
)
BENJAMIN TOOKES,
)
a "B,"
)
a/k/a "Ben,"
)
CARLOS DAVIS,
)
a/k/a "Lo,"
)
RAYMOND HIXON,
)
a/k/a "Dre,"
)
THOMAS THORTON,
)
a/k/a "Big Bo,"
)
BRANDEN JORDAN,
)
MARK WHITE,
)
TOBIAS RENDER,
)
a/k/a "Tee,"
)
a/k/a "Toby,"
)
ERIC BURKES,
)
a "E,"
)
ARYAY STRONG,
)
MARSHALL SEARS,
)
SULEYMA ARREOLA,
)
EMORY WHITE,
)
0 1
OBRYAN MOORE,
)
a/k/a "OB,"
)
TERRY MITCHELL, Jr.
)
COREY MITCHELL,
)
a/k/a "Stick,"
)
LUQUOISE CLAY,
)
a/Ida "Qui,"
)
JESSICA CAMERON,
)
a/k/a "Keta,"
)
JOSHUA DUNLAP,
)
MAURICE FUDGE,
)
a/k/a "Reese,"
)
QUINTON MATTHEWS,
)
a/k/a "Q,"
)
a/k/a "Chuck Matthews,"
)
CHARLES JACKSON,
)
a/k/a "Cooley Slim,"
)
a/k/a "Corey,"
)
RONNIE ZACHARY,
)
a/k/a "City,"
)
PORSHA DREWERY,
)
a/k/a "Parsha,"
)
TAQUILLA JOHNSON,
)
a/ida "Quilla,"
)
RAHEEM WALLER,
)
TRAVIS RICH,
)
MARLON DOBBINS,
)
DERRICK HEARD,
)
a/Ida "Da Man,"
)
a/Ida "Heard,"
)
RAHDRIQ TURNER,
)
a/k/a "Rah Rah,"
)
ANTONIO DORSEY,
)
a/Ida "Bear,"
)
Defendants.
)
3
THE GRAND JURY CHARGES THAT:
INTRODUCTION
At all times relevant to this Indictment:
Georgia's Women, Infant and Children's Program ("WIC")
1. Georgia's Women, Infant, and Children ("WIC") program provides supplemental
food, health care referrals, and nutrition for low-income pregnant and postpartum women, and to
infants and children up to age five who are nutritionally at risk. The WIC program provides
infant formula, infant and adult cereal, juice, eggs, milk, bread, cheese, peanut butter, fresh fruits
and vegetables, and dried beans or peas. The WIC program is funded and administered through-
the United States Department of Agriculture's ("USDA") Food and Nutrition Services Division.
The Georgia Department of Community Health ("DCH")(now known as the Georgia Department
of Public Health) administers the WIC program at the state level.
2. In order to participate in WIC, a retail grocery vendor must submit a signed
application for Vendor Authorization. Every owner with 5% or more financial interest in the
grocery store must be listed in the application. Authorized vendors in the WIC program may
only accept and redeem WIC vouchers in connection with the sale of eligible WIC items
specifically described on each WIC food voucher. WIC vouchers cannot be purchased or sold in
exchange for cash. Vendors are prohibited from substituting WIC eligible foods with ineligible
foods and from delivering WIC food items. Vendors may not accept vouchers before or after the
30 -day period during which the WIC vouchers are marked valid. Each participating store owner
4
or representative must sign a form attesting to his or her understanding of the WIC rules and
regulations.
3. Once approved to participate in WIC, a grocery store is issued a unique 4-digit
vendor number. The grocery store will receive a stamp that is embossed with their vendor
number along with the wording "GA WIC VENDOR." WIC vendors agree that WIC vouchers
will only be accepted at an authorized store and that WIC vouchers will not be transferred
between stores.
4. When a WIC program participant or guardian of a participant uses a WIC voucher
at an authorized grocery store, the store must verify that the participant is only buying the listed
items on the voucher. A store representative must fill out the amount of WIC items actually
purchased, the date of purchase, and the total price on each WIC voucher before having the
participant or guardian verify the information and sign each WIC voucher at the point of sale.
Failure to properly fill out the required information prior to obtaining the customer's signature
renders the WIC voucher void. Before an authorized store can deposit a WIC voucher, the store
must stamp the front of the voucher with their unique vendor stamp. The WIC voucher is then
deposited into a designated store bank account, just like a regular check. Once deposited with
the required information, the vouchers may then be funded by the WIC program.
The Supplemental Nutrition Assistance Program ("SNAP"
The Supplemental Nutrition Assistance Program ("SNAP"), formerly known as
the Food Stamp Program, is a program also funded and administered through the USDA. Its
purpose is to alleviate hunger and malnutrition among low-income families by providing "food
stamp" benefits. These food stamp benefits are provided to recipients through Electronic Benefit
Transfer ("EBT") cards, which are similar to debit cards. Recipients use the EBT cards to
purchase eligible food items at approved retail stores, and the amount of the purchase is then
debited from that recipient's SNAP benefit account. Recipients may not use their EBT card to
purchase non-food items nor to obtain cash.
6. For a retail store to become authorized to participate in SNAP, the business owner
or representative must apply with the USDA's Food and Nutrition Service. Applicants are
instructed and cautioned that EBT cards can be accepted and redeemed only in connection with
the sale of eligible food items. Participating stores are prohibited from debiting food stamp
benefit accounts for the purchase of non-food items. Such stores are also prohibited from
exchanging cash for food stamp benefits. Each participating store owner or representative must
sign a form attesting to his or her understanding of the SNAP rules and regulations.
7. When a recipient uses his or her EBT card in an authorized store, the store's
point-of-sale terminal sends an electronic message to determine whether the card is funded. If
the EBT card is funded, the store is notified electronically and is able to complete the SNAP
transaction. Once completed, the point-of-sale terminal in the store sends another electronic
message requesting payment. An entity acting on behalf of SNAP processes a debit to the SNAP
recipient's allotted funding and eventually a transfer of funds is wired into the store's bank
account.
The Stores
8. The following stores applied for and received authorization by the USDA's Food
and Nutrition Service to participate as retail stores in SNAP:
a. Super Kids Variety Store, LLC, located at 30 2 West Victory Drive, Ste. E,
Savannah, Georgia;
b. Platinum Kids, LLC, located at 612 US Highway 80 , West, Garden City, Georgia;
rei
C. Pink and Blue Variety Store, LLC, located at 370 7 Houston Ave., Macon,
Georgia;
d. Wayne's World Variety Store, LLC, located at 80 4 Whitesville Street, Suite F,
LaGrange, Georgia;
e. Toddler World, LLC, located at 1394 Moreland Ave. SE, Atlanta, Georgia;
f. Small Mart Variety Store, LLC, located at 819 A New Franklin Road, LaGrange,
Georgia;
g. Small Steps Variety Store, LLC, located at 2310 Cascade Road SW, Atlanta,
Georgia;
h. Babies of Elegance, LLC, located at 6124 Covington Highway, Lithonia, Georgia;
Small World, LLC, located at 650 4 Church Street, Suite #1, Riverdale, Georgia;
j. Kids Paradise Variety Store, LLC (formerly Tiny Tots), located at 1977 South
Cobb Drive SE, Ste. 270 , Marietta, Georgia;
k. Baby's and More, located at 5455 Riverdale Road, Atlanta, Georgia;
I. Kreative Kids Variety Store, LLC, located at 5611 Riverdale Road C, College
Park, Georgia;
M. C and J Nutritional Variety Store, LLC, located at 7173 Covington Hwy. Fl,
Lithonia, Georgia;
n. Star Babies Variety Store, LLC, located at 4812 B Redan Road, Stone Mountain,
Georgia;
9. From in or around December 20 0 9 through December 20 12, these stores
redeemed over $1,0 0 0 ,0 0 0 in SNAP benefits.
10 . In addition to being authorized to participate in SNAP, the following stores
applied for authorization and were authorized by DCH to participate as retail stores in WIC:
a. Super Kids Variety Store, LLC;
b. Pink and Blue Variety Store, LLC;
C. Small World, LLC;
7
d. Toddler World, LLC; and,
e. Small Mart Variety Store, LLC.
11. From in or around December 20 0 9 through December 20 12, these stores
redeemed over $18,0 0 0 ,0 0 0 in WIC vouchers.
12. All of the stores identified in this Indictment were owned and/or operated by the
defendants, who were collectively involved in the illegal purchase of over $18,0 0 0 ,0 0 0 worth of
WIC and SNAP benefits for cash.
The Defendants
13. Defendant Brandon Sapp, a/k/a, "B," was the listed owner of Super Kids
Variety Store, in Savannah, and Baby's and More, in Riverdale. Sapp was the actual owner of
all of the stores listed in the Indictment. Sapp was also a signator on all of the store bank
accounts. Sapp further recruited and trained many members of the conspiracy regarding the
illegal purchase of WIC vouchers and SNAP benefits for cash, and regarding other unlawful
exchanges of WIC and SNAP benefits.
14. Defendant Kimberly Sapp, a/k/a "Kimberly Walker," a/k/a "The Money
Wizard," the wife of Brandon Sapp, was the listed owner of Toddler World, in Atlanta. Sapp
was the actual owner of all of the stores listed in the Indictment. Sapp was also a signator on all
of the store bank accounts. Sapp further recruited and trained many members of the conspiracy
regarding the illegal purchase of WIC vouchers and SNAP benefits for cash, and regarding other
unlawful exchanges of WIC and SNAP benefits. In addition, Sapp oversaw the deposit of tens
of thousands of WIC vouchers unlawfully obtained.
8
15. Defendant Calvin Williams, a/k/a "Slick," was the manager of Small Steps
Variety Store, in Atlanta. Williams withdrew thousands of dollars in cash almost daily from
numerous bank accounts, which he then supplied to others in the conspiracy for the illegal
purchase of WIC vouchers. Williams also collected thousands of vouchers that had been
unlawfully purchased for cash by numerous coconspirators, which he then transported to central
locations to be processed for deposit.
16. Defendant Isaac Martin, a/Ida "Ike," regularly withdrew thousands of dollars in
cash from numerous bank accounts, which he then supplied to others in the conspiracy for the
illegal purchase of WIC vouchers. Martin also collected thousands of vouchers that had been
unlawfully purchased for cash by numerous coconspirators, which he then transported to central
locations to be processed for deposit.
17. Defendant John P. Jones, a/k/a "JP," was a part owner of Babies of Elegance, in
Lithonia. Jones, aided and abetted by others, unlawfully purchased WIC vouchers for cash and
otherwise illegally exchanged WIC and SNAP benefits. Jones also recruited and trained other
members of the conspiracy to unlawfully exchange WIC and SNAP benefits.
18. Defendant Wayne Jackson, a/Ida "J5," was a part owner of Wayne's World
Variety Store, in LaGrange. Jackson, aided and abetted by others, unlawfully purchased WIC
vouchers for cash and otherwise illegally exchanged WIC and SNAP benefits. Jackson also
recruited and trained other members of the conspiracy to unlawfully exchange WIC and SNAP
benefits.
19. Defendant Gregory Thomas, a/k/a "Rich Greg," was a part owner of Tiny Tots,
in Macon, and the manager of Tiny Tots, in Marietta. Thomas, aided and abetted by others,
unlawfully purchased WIC vouchers for cash and otherwise illegally exchanged WIC benefits.
9
Thomas
also recruited and trained other members of the conspiracy to unlawfully exchange
WIC benefits.
20 . Defendant Kerry Adams, a/k/a "Big Skreed," a/k/a "Skrump," was the
manager of Small Steps Variety Store, in Atlanta; he also worked out of Baby's and More, in
Riverdale. Adams, aided and abetted by others, unlawfully purchased WIC vouchers for cash
and otherwise illegally exchanged WIC and SNAP benefits. Adams also recruited and trained
other members of the conspiracy to unlawfully exchange WIC and SNAP benefits.
21. Defendant Brian Lockhart, a/k/a "Lock," worked out of Small Steps, in Atlanta,
and Baby's and More, in Riverdale. Lockhart, aided and abetted by others, unlawfully
purchased WIC vouchers for cash and otherwise illegally exchanged WIC benefits. Lockhart,
aided and abetted by others, also fabricated receipts for a number of different stores identified in
the Indictment, all in an effort to conceal the unlawful exchange of WIC benefits.
22. Defendant Henry Ward, a/k/a "Ty," a/k/a "Tye," a/ida "Grand Hustle," was
the manager of Super Kids Variety Store, in Savannah; he also worked out of Platinum Kids, in
Garden City. Ward, aided and abetted by others, unlawfully purchased WIC vouchers for cash
and otherwise illegally exchanged WIC and SNAP benefits. Ward also recruited and trained
other members of the conspiracy to unlawfully exchange WIC and SNAP benefits.
23. Defendant Vincent Harper was a part owner of Star Babies, in Stone Mountain.
Harper, aided and abetted by others, unlawfully purchased WIC vouchers for cash and
otherwise illegally exchanged WIC and SNAP benefits. Harper also recruited and trained other
members of the conspiracy to unlawfully exchange WIC and SNAP benefits.
10
24. Defendant Ostrando Brock, a/k/a "Shun," a/k/a "Shawn," aided and abetted by
others, unlawfully purchased WIC vouchers for cash and otherwise illegally exchanged WIC
benefits. Brock also transported illegally obtained WIC vouchers to central locations in order to
be processed for deposit.
25. Defendant Jesse McCoy, a/k/a "Jay Mac," was a part owner of Star Babies, in
Stone Mountain. McCoy, aided and abetted by others, unlawfully purchased WIC vouchers for
cash and otherwise illegally exchanged WIC benefits.
26. Defendant Terence Cosby, a/Ida "Me Gold," worked out of Super Kids Variety
Store, in Savannah. Cosby, aided and abetted by others, unlawfully purchased WIC vouchers for
27. Defendant Raymond Hargrove, worked out of Super Kids Variety Store, in
Savannah. Hargrove, aided and abetted by others, unlawfully purchased WIC vouchers for cash
and otherwise illegally exchanged WIC and SNAP benefits.
28. Defendant Jacqueline Beauchamp, a/k/a "Jackie," worked out of Super Kids
Variety Store, in Savannah, and Platinum Kids, in Garden City. Beauchamp, aided and abetted
by others, unlawfully purchased WIC vouchers for cash and otherwise illegally exchanged WIC
benefits.
29. Defendant Elizabeth Beauchamp worked out of Super Kids Variety Store, in
Savannah. Beauchamp, aided and abetted by others, unlawfully purchased WIC vouchers for
30 . Defendant Gerald Patilla, a/Ida "PT," worked out of Super Kids Variety Store,
in Savannah. Patilla, aided and abetted by others, unlawfully purchased WIC vouchers for cash
and otherwise illegally exchanged WIC benefits.
11
31. Defendant Clayton Talley worked out of Platinum Kids, in Garden City. Talley,
aided and abetted by others, unlawfully purchased WIC vouchers for cash and otherwise illegally
exchanged WIC benefits.
32. Defendant Ebony Jacobs worked out of Platinum Kids, in Garden City, Super
Kids Variety Store, in Savannah, as well as other stores listed in the Indictment. Jacobs, aided
and abetted by others, unlawfully purchased WIC vouchers for cash and otherwise illegally
exchanged WIC and SNAP benefits.
33. Defendant Olajawon Simmons, a/k/a "Wan," a/k/a "Won," worked Out of
Super Kids Variety Store, in Savannah, and Platinum Kids, in Garden City. Simmons, aided and
abetted by others, unlawfully purchased WIC vouchers for cash and otherwise illegally
34. Defendant Reginald Simmons, a/k/a "Reggie," worked out of Super Kids
Variety Store, in Savannah, and Platinum Kids, in Garden City. Simmons, aided and abetted by
others, unlawfully purchased WIC vouchers for cash and otherwise illegally exchanged WIC
benefits.
35. Defendant Gary Grier, a/k/a "Bundee," a/k/a "Dee," was a manager at Baby's
and More, in Atlanta, and also worked out of Toddler World, in Atlanta. Grier, aided and
36. Defendant Magregor Warner, a/k/a "KB," worked out of Baby's and More, in
Atlanta. Warner, aided and abetted by others, unlawfully purchased WIC vouchers for cash and
otherwise illegally exchanged WIC and SNAP benefits.
12
37. Defendant Benjamin Tookes, a/Ida "B," a/k/a "Ben," worked out of Baby's and
More, in Atlanta. Tookes, aided and abetted by others, unlawfully purchased WIC vouchers for
38. Defendant Carlos Davis, a/ida "Lo," worked out of Baby's and More, in Atlanta,
Small Steps Variety Store, in Atlanta, and other stores listed in the Indictment. Davis, aided and
39. Defendant Raymond Hixon, a/k/a "Dre," worked out of Baby's and More, in
Atlanta, and Wayne's World Variety Store, in LaGrange. Hixon, aided and abetted by others,
unlawfully purchased WIC vouchers for cash and otherwise illegally exchanged WIC and SNAP
benefits.
40 . Defendant Thomas Thorton, a/k/a "Big Bo," worked out of Small World, in
Riverdale, and other stores listed in the indictment. Thorton, aided and abetted by others,
41. Defendant Branden Jordan worked out of Baby's and More, in Riverdale.
Jordan, aided and abetted by others, unlawfully purchased WIC vouchers for cash and otherwise
illegally exchanged WIC benefits.
42. Defendant Mark White was the manager of Babies of Elegance, in Lithonia, and
worked with other stores identified in the Indictment. White, aided and abetted by others,
43. Defendant Tobias Render, a/k/a "Tee," a/Ida "Toby," worked out of Babies of
Elegance, in Lithonia, and with other stores identified in the Indictment. Render, aided and
13
44. Defendant Eric Burkes, a/k/a "E," worked out of Babies of Elegance, in
Lithonia. Burkes, aided and abetted by others, unlawfully purchased WIC vouchers for cash and
otherwise illegally exchanged WIC benefits.
45. Defendant Aryay Strong worked out of Babies of Elegance, in Lithonia. Strong,
aided and abetted by others, unlawfully purchased WIC vouchers for cash and otherwise illegally
46. Defendant Marshall Sears worked out of Kids Paradise Variety Store, in
Marietta. Sears, aided and abetted by others, unlawfully purchased WIC vouchers for cash and
47. Defendant Suleyma Arreola worked out of Kids Paradise Variety Store, in
Marietta. Arreola, aided and abetted by others, unlawfully purchased WIC vouchers for cash
and otherwise illegally exchanged WIC and SNAP benefits.
48. Defendant Emory White worked out of Wayne's World Variety Store, in
LaGrange. White, aided and abetted by others, unlawfully purchased WIC vouchers for cash
and otherwise illegally exchanged WIC benefits.
49. Defendant Obryan Moore, a/k/a "OB," worked out of Wayne's World Variety
Store, in LaGrange. Moore, aided and abetted by others, unlawfully purchased WIC vouchers
for cash and otherwise illegally exchanged WIC benefits.
50 . Defendant Terry Mitchell, Jr. worked out of Wayne's World Variety Store, in
LaGrange, and with other stores listed in the indictment. Mitchell, aided and abetted by others,
14
benefits.
51. Defendant Corey Mitchell, a/k/a "Stick," worked out of Small Steps Variety
Store, in Atlanta, and Pink and Blue Variety Store, in Macon. Mitchell supervised the unlawful
exchange of WIC vouchers by other conspirators. Mitchell, aided and abetted by others,
benefits. Mitchell, aided and abetted by others, also fabricated receipts for a number of different
stores identified in the Indictment, all in an effort to conceal the unlawful exchange of WIC and
SNAP benefits.
52. Defendant Luquoise Clay, a/k/a "Qui," was a part owner of Small Mart Variety
Store, LaGrange. Clay, aided and abetted by others, unlawfully purchased WIC vouchers for
53. Defendant Jessica Cameron, a/Ida "Keta," worked out of Small Mart Variety
Store, in LaGrange. Cameron conspired to, and aided and abetted the unlawful purchase of
WIC vouchers for cash.
54. Defendant Joshua Dunlap worked out of Pink and Blue Variety Store, in Macon.
Dunlap, aided and abetted by others, unlawfully purchased WIC vouchers for cash and
55. Defendant Maurice Fudge, a/k/a "Reese," worked out of Pink and Blue Variety
Store, in Macon. Fudge, aided and abetted by others, unlawfully purchased WIC vouchers for
cash and otherwise illegally exchanged WIC and SNAP benefits.
15
56. Defendant Quinton Mathews, a/k/a "Q," a/k/a "Chuck Mathews," worked out
of Pink and Blue Variety Store, in Macon. Mathews, aided and abetted by others, unlawfully
purchased WIC vouchers for cash and otherwise illegally exchanged WIC benefits.
57. Defendant Charles Jackson, a/k/a "Cooley Slim," a/k/a "Corey," worked out
of Toddler World, in Atlanta, and with other stores listed in the indictment. Jackson, aided and
58. Defendant Ronnie Zachary, a/k/a "City," worked out of Pink and Blue Variety
Store, in Macon. Zachary, aided and abetted by others, unlawfully purchased WIC vouchers for
59. Defendant Porsha Drewery, a/k/a "Parsha," unlawfully purchased WIC
vouchers for cash and resold them to other members of the conspiracy.
60 . Defendant Taquilla Johnson, a/k/a "Quilla," unlawfully purchased WIC
61. Defendant Raheem Wailer, worked at Toddler World, in Atlanta. Wailer, aided
62. Defendant Travis Rich, was a manager of Toddler World, in Atlanta, and, aided
63. Defendant Marion Dobbins, a/k/a "Mark," worked out of Kids Paradise Variety
Store, in Marietta, and with other stores identified in the indictment. Dobbins, aided and abetted
112-4
by others, unlawfully purchased WIC vouchers for cash and otherwise illegally exchanged WIC
benefits.
64. Defendant Derrick Heard, a/Ida "Da Man," a/Ida "Heard," was the manager of
Kids Paradise Variety Store, in Marietta. Heard, aided and abetted by others, unlawfully
purchased WIC vouchers for cash and otherwise illegally exchanged WIC benefits.
65. Defendant Rahdriq Turner, a/Ida "Rah Rah," unlawfully purchased WIC
66. Defendant Antonio Dorsey, a/Ida "Bear," unlawfully purchased WIC vouchers
for cash and resold them to other members of the conspiracy.
COUNT ONE
18 U.S.C.

1349
Conspiracy to Commit Mail and Wire Fraud
67. Paragraphs I through 66 are incorporated by reference herein.
68. Beginning in or around December 20 0 9 and continuing through in or around
December 20 12, in Chatham, Bibb, Cobb, Clayton, DeKalb, Fulton, Monroe, Troup, within the
Southern, Northern and Middle Districts of Georgia, and elsewhere, the defendants:
BRANDON SAPP,
a/k/a "B,"
KIMBERLY SAPP,
a/ida "Kimberly Walker,"
CALVIN WILLIAMS,
a/k/a "Slick,"
ISAAC MARTIN,
a/k/a "Ike,"
JOHN P. JONES,
17
a/k/a "JP,"
WAYNE JACKSON,
a/k/a "15,"
GREGORY THOMAS,
a/k/a "Rich Greg,"
KERRY ADAMS,
a/k/a "Big Skreed,"
a/k/a "Skrump,"
BRIAN LOCKHART,
a/k/a "Lock,"
HENRY WARD,
a/k/a "TY,"
a/k/a "lYE,"
VINCENT HARPER,
OSTRANDO S. BROCK,
a/k/a "Shun,"
a/k/a "Shawn,"
JESSE MCCOY,
a/k/a "Jay Mac,"
TERENCE COSBY,
a/k/a "Me Gold,"
RAYMOND HARGROVE,
a/k/a "Jackie,"
GERALD PATILLA,
a/k/a "PT,"
CLAYTON TALLEY,
EBONY JACOBS,
OLAJA WON SIMMONS,
a/k/a "Wan,"
a/k/a "Won,"
REGINALD SIMMONS,
a/k/a "Reggie,"
GARY GRIER,
a/k/a "Bundee,"
a/k/a "Dee,"
MAGREGOR WARNER,
18
a/k/a "KB,"
BENJAMIN TOOKES,
a/Ic/a "B,"
a/k/a "Ben,"
CARLOS DAVIS,
a/k/a "Lo,"
RAYMOND HIXON,
a/k/a "Dre,"
THOMAS THORTON,
alicia "Big Bo,"
BRANDEN JORDAN,
MARK WHITE,
TOBIAS RENDER,
a/k/a "Tee,"
a/k/a "Toby,"
ERIC BURKES,
a/Ic/a
ARYAY STRONG,
MARSHALL SEARS,
SULEYMA ARREOLA,
EMORY WHITE,
OBRYAN MOORE,
a/k/a "OB,"
TERRY MITCHELL, Jr.
COREY MITCHELL,
a/k/a "Stick,"
LUQUOISE CLAY,
a/k/a "Qui,"
JESSICA CAMERON,
a/k/a "Keta,"
JOSHUA DUNLAP,
MAURICE FUDGE,
a/k/a "Reese,"
QUINTON MATTHEWS,
a/k/a "Q,"
CHARLES JACKSON,
a/k/a "Corey,"
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RONNIE ZACHARY,
a/k/a "City,"
PORSHA DREWERY,
a/k/a "Parsha,"
TAQUILLA JOHNSON,
a/k/a "Quilla,"
RAHEEM WALLER,
TRAVIS RICH,
MARLON DOBBINS,
DERRICK HEARD,
a/k/a "Da Man,"
a/k/a "Heard,"
RAHDRIQ TURNER,
a/k/a "Rah Rah,"
ANTONIO DORSEY,
a/k/a "Bear,"
being aided and abetted by each other and others, did knowingly and willfully combine,
conspire, confederate, and agree with each other and with others, to commit offenses against the
United States, that is:
a. to knowingly and willfully devise a scheme and artifice to defraud the WIC program
and SNAP of money, and to obtain from the WIC program and SNAP money by
means of false and fraudulent pretenses, representations, and promises, and to send or
cause to be sent by commercial interstate carrier and U.S. Mail WIC vouchers and
other items for the purpose of executing the scheme and artifice, in violation of Title
18, United States Code, Section 1341; and
b. to knowingly and willfully devise a scheme and artifice to defraud the WIC program
and SNAP of money, and to obtain from the WIC program and SNAP money by
means of materially false and fraudulent pretenses, representations, and promises, and
20
to transmit and cause to be transmitted by wire in interstate commerce some
communication for the purpose of executing the scheme and artifice, in violation of
Title 18, United States Code, Section 1343;
with some conspirators joining the conspiracy earlier than others.
Manner and Means of the Conspiracy
69. It was part of the conspiracy that some of the defendants, aided and abetted by
each other and others, would seek to open purported grocery stores throughout the state of
Georgia.
70 . It was further part of the conspiracy that some of the defendants, aided and
abetted by each other and others, would apply to USDA Food and Nutrition Service as a
purported grocery store, in an effort to become an authorized vendor in SNAP.
71. It was further part of the conspiracy that some of the defendants, aided and
abetted by each other and others, would apply to the DCH (now the Georgia Department of
Public Health) as a purported grocery store, in an effort to become an authorized vendor in the
WIC program.
72. It was further part of the conspiracy that, once the purported grocery stores
became authorized SNAP and/or WIC program vendors, some of the conspirators, aided and
abetted by each other and others, would stock the stores with enough food items to pass
inspections by the WIC program and SNAP, and to falsely appear that the stores were operating
as legitimate grocery stores.
73. It was further part of the conspiracy that the defendants, aided and abetted by each
other and others, would canvass neighborhoods throughout Georgia and solicit SNAP recipients
and WIC participants to illegally sell their WIC and SNAP benefits for cash.
21
other and others, would agree with WIC participants, the guardians of WIC participants, and
with SNAP recipients to the exchange of WIC vouchers and SNAP benefits for cash at a fraction
of the amount for which the vouchers and benefits could be redeemed.
abetted by each other and others, would withdraw cash from numerous bank accounts, which
cash would be used to illegally purchase WIC vouchers and SNAP benefits.
other and others, would purchase WIC vouchers and SNAP benefits for cash and at a fraction of
the amount the defendants would eventually receive from the redemption of the benefits.
other and others, would regularly and unlawfully exchange unauthorized items for WIC
vouchers, and would unlawfully deliver items to WIC participants.
other and others, would unlawfully pay cash to SNAP recipients in order to use their EBT
benefits to stock the purported grocery stores.
other and others, would hold frequent meetings to discuss, among other things: the cash amounts
that would be paid for various WIC vouchers and for SNAP benefits; and, how to evade
detection of their illegal activities from SNAP and the WIC program.
80 . It was further part of the conspiracy that the some of the defendants, aided and
abetted by each other and others, would exchange WIC vouchers at stores that were not
authorized to accept WIC vendors.
22
other and others, would regularly deliver and send WIC vouchers to a central location, by
commercial carrier, U.S. Mail, and otherwise.
abetted by each other and others, would make, and cause to be made, false and fabricated
information upon WIC vouchers, which vouchers would then be deposited into various store
bank accounts.
abetted by each other and others, would cause false and fabricated information to be
communicated to SNAP in an effort to have SNAP fund transactions involving the unlawful
exchange of SNAP benefits for cash.
other and others, would create false receipts and other documents in an effort to hide their
scheme and artifice upon the WIC program and SNAP.
abetted by each other and others, would create an organization named WE IN CONTROL
(WIC), which was used to pay and reward numerous coconspirators for their unlawful activities,
and to receive and transfer large amounts of the proceeds of the scheme and artifice upon the
WIC program and SNAP.
Overt Acts of the Conspiracy
In furtherance of the conspiracy and to effect the objects thereof, the defendants, aided
and abetted by each other and others, committed the following acts, among others:
23
86. Members of the conspiracy opened purported grocery stores in Savannah, Garden
City, Macon, LaGrange, Atlanta, Marietta, Lithonia, Riverdale and elsewhere.
87. Members of the conspiracy applied to the USDA and to DCH to become
authorized vendors of the WIC program and SNAP.
88. Members of the conspiracy opened numerous bank accounts in the names of the
purported grocery stores listed in the Indictment, in the name of We In Control, and in other
names.
89. Members of the conspiracy purchased WIC vouchers and SNAP benefits for cash
at a fraction of the amount for which the benefits were redeemed by members of the conspiracy.
90 . Members of the conspiracy allowed the substitution of WIC eligible food items
for non WIC eligible food items at the various purported grocery stores listed in the Indictment.
91. Members of the conspiracy used recipient EBT cards to stock purported grocery
stores with enough food items to insure that the stores would pass WIC program and SNAP
inspections.
92. Members of the conspiracy from across the state attended meetings in person, via
Skype, and through other means.
93. Members of the conspiracy sent and delivered WIC vouchers by mail, commercial
carrier and otherwise to central locations so that the vouchers could be processed with false and
fabricated information before their deposit into bank accounts.
94. Members of the conspiracy caused false and fabricated interstate electronic
communications to be sent to SNAP in an effort to cause SNAP to fund fraudulent transactions.
All done in violation of Title 18, United States Code, Section 1349.
24
18 U.S.C. 1956(h)
Money Laundering Conspiracy
95. Paragraphs I through 94 are incorporated by reference herein.
96. Beginning in or around December 20 0 9, and continuing through in or around
December 20 12, in Chatham, Bibb, Cobb, Clayton, DeKaib, Fulton, Monroe, Troup, within the
Southern, Northern and Middle Districts of Georgia, and elsewhere, the defendants,
BRANDON SAPP,
a "B,"
KIMBERLY SAPP,
CALVIN WILLIAMS,
a/k/a "Slick,"
ISAAC MARTIN,
a/k/a "Ike,"
JOHN P. JONES,
a/k/a "JP,"
WAYNE JACKSON,
a/k/a "J5,"
GREGORY THOMAS,
a/k/a "Rich Greg,"
KERRY ADAMS,
a/k/a "Big Skreed,"
a/k/a "Skrump,"
BRIAN LOCKHART,
a/k/a "Lock,"
HENRY WARD,
a/k/a "TY,"
a/k/a "TYE,"
VINCENT HARPER,
OSTRANDO S. BROCK,
a/k/a "Shun,"
25
a/k/a "Shawn,"
JESSE MCCOY,
a/k/a "Jay Mac,"
TERENCE COSBY,
a/k/a "Me Gold,"
RAYMOND HAROROVE,
a/k/a "Jackie,"
GERALD PATILLA,
a/k/a "PT,"
CLAYTON TALLEY,
EBONY JACOBS,
OLAJA WON SIMMONS,
a/k/a "Wan,"
a/k/a "Won,"
REGINALD SIMMONS,
a/k/a "Reggie,"
GARY GRIER,
a/k/a "Bundee,"
a/k/a "Dee,"
MAGREGOR WARNER,
a/k/a "KB,"
BENJAMIN TOOKES,
a "B,"
a/k/a "Ben,"
CARLOS DAVIS,
a/k/a "Lo,"
RAYMOND HIXON,
a/k/a "Dre,"
THOMAS THORTON,
a/k/a "Big Bo,"
BRANDEN JORDAN,
MARK WHITE,
TOBIAS RENDER,
a/k/a "Tee,"
a/k/a "Toby,"
ERIC BURKES,
a
26
ARYAY STRONG,
MARSHALL SEARS,
SULEYMA ARREOLA,
EMORY WHITE,
OBRYAN MOORE,
a/kla "OB,"
TERRY MITCHELL, Jr.
COREY MITCHELL,
a/k/a "Stick,"
LUQUOISE CLAY,
a/k/a "Qui,"
JESSICA CAMERON,
a/k/a "Keta,"
JOSHUA DUNLAP,
MAURICE FUDGE,
a/k/a "Reese,"
QUINTON MATI'HEWS,
a/k/a "Q,"
CHARLES JACKSON,
a/k/a "Corey,"
RONNIE ZACHARY,
a/k/a "City,"
PORSHA DREWERY,
a/k/a "Parsha,"
TAQUILLA JOHNSON,
a/k/a "Quilla,"
RAHEEM WALLER,
TRAVIS RICH,
MARLON DOBBINS,
DERRICK HEARD,
a/k/a "Da Man,"
a/k/a "Heard,"
RAHDRIQ TURNER,
a/Ida "Rah Rah,"
ANTONIO DORSEY,
a/k/a "Bear,"
27
being aided and abetted by each other and others, did knowingly combine, conspire, and agree
with each other and with others, to commit the following offenses:
a. Money Laundering to Promote a Specified Unlawful Activity.
To conduct and attempt to conduct financial transactions affecting interstate and foreign
commerce involving the proceeds of specified unlawful activity, that is, wire fraud and mail
fraud; with the intent to promote said specified unlawful activity; and knowing that the funds
represented the proceeds of some form of unlawful activity; in violation of Title 18, United
States Code, Section 1 956(a)( I )(A)(I).
b. Money Laundering to Conceal and Disguise the Proceeds of Unlawful
Activity.
To conduct and attempt to conduct financial transactions affecting interstate and foreign
commerce involving the proceeds of specified unlawful activity, that is, wire fraud and mail
fraud; knowing that the transactions were designed in whole or in part to conceal and disguise
the nature, location, source, ownership and control of the proceeds of the specified unlawful
activity; and, knowing that the funds represented the proceeds of some form of unlawful activity;
in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).
c. Engaging in Financial Transactions Exceeding $10,000 in Criminally Derived
Proceeds.
To knowingly engage and attempt to engage in monetary transactions exceeding $10 ,0 0 0 ,
which funds were derived from specified unlawful activity, that is, wire fraud and mail fraud;
and knowing that the funds represented the proceeds of some form of unlawful activity; in
violation of Title 18, United States Code, Section 1957.
28
Manner and Means of the Conspiracy
97. It was part of the conspiracy that the coconspirators, aided and abetted by each
other and by others, would open bank accounts in Savannah, Macon, Columbus, Atlanta and
elsewhere through which they would transfer funds obtained from their fraud upon from the WIC
program and SNAP.
98. It was further part of the conspiracy that the coconspirators, aided and abetted by
each other and by others, would conduct multiple financial transactions designed to conceal and
disguise the nature, location, source, ownership and control of the proceeds of their fraud upon
the WIC program and SNAP and WIC.
99. It was further part of the conspiracy that the coconspirators, aided and abetted by
each other and by others, would use the illicit proceeds from their fraud upon the WIC program
and SNAP to promote said unlawful activity by purchasing additional WIC vouchers illegally,
paying for more EBT benefits and paying the operating and business expenses of the stores
identified herein.
10 0 . It was a further part of the conspiracy that the coconspirators, aided and abetted
by each other and others, would engage in transactions exceeding $10 ,0 0 0 in funds that were
obtained from their fraud upon the WIC program and SNAP.
All done in violation of Title 18, United States Code, Sections 1956(h).
FORFEITURE ALLEGATION
The allegations contained in Counts One and Two of the Indictment are hereby
realleged and incorporated by reference for the purpose of alleging forfeitures pursuant to Title
29
18, United States Code, Sections 982(a) and 981(a)(1)(C) And Title 28, United States Code,
Section 2461.
2. Upon conviction of one or more offenses set forth in this indictment, the
defendants,
BRANDON SAPP,
a "B,"
KIMBERLY SAPP,
CALVIN WILLIAMS,
a/k/a "Slick,"
ISAAC MARTIN,
a/k/a "Ike,"
JOHN P. JONES,
a/k/a "JP,"
WAYNE JACKSON,
a/k/a 66J5,"
GREGORY THOMAS,
a/k/a "Rich Greg,"
KERRY ADAMS,
a/k/a "Big Skreed,"
a/k/a "Skrump,"
BRIAN LOCKHART,
aik/a "Lock,"
HENRY WARD,
a/k/a "TY,"
a/k/a "TYE,"
VINCENT HARPER,
OSTRANDO S. BROCK,
a/k/a "Shun,"
a/k/a "Shawn,"
JESSE MCCOY,
a/k/a "Jay Mac,"
TERENCE COSBY,
a/k/a "Me Gold,"
30
RAYMOND HARGROVE,
a/k/a "Jackie,"
GERALD PATILLA,
a/k/a "PT,"
CLAYTON TALLEY,
EBONY JACOBS,
OLAJA WON SIMMONS,
a/k/a "Wan,"
a/k/a "Won,"
REGINALD SIMMONS,
a/k/a "Reggie,"
GARY GRIER,
a/k/a "Bundee,"
a/k/a "Dee,"
MAGREGOR WARNER,
a/k/a "KB,"
BENJAMIN TOOKES,
a "B,"
a/k/a "Ben,"
CARLOS DAVIS,
a/k/a "Lo,"
RAYMOND HIXON,
a/k/a "Dre,"
THOMAS THORTON,
a/k/a "Big Bo,"
BRANDEN JORDAN,
MARK WHITE,
TOBIAS RENDER,
a/k/a "Tee,"
a/k/a "Toby,"
ERIC BURKES,
a/k/a "E,"
ARYAY STRONG,
MARSHALL SEARS,
SULEYMA ARREOLA,
EMORY WHITE,
OBRYAN MOORE,
31
a/k/a "OB,"
TERRY MITCHELL,
COREY MITCHELL,
a/k/a "Stick,"
LUQUOISE CLAY,
a/k/a "Qui,"
JESSICA CAMERON,
a/k/a "Keta,"
JOSHUA DUNLAP,
MAURICE FUDGE,
a/k/a "Reese,"
QUINTON MATI'HEWS,
a/k/a "Q,"
CHARLES JACKSON,
a/k/a "Corey,"
RONNIE ZACHARY,
a/k/a "City,"
PORSHA DREWERY,
a/k/a "Parsha,"
TAQUILLA JOHNSON,
a/k/a "Quilla,"
RAHEEM WALLER,
TRAVIS RICH,
MARLON DOBBINS,
DERRICK HEARD,
a/k/a "Da Man,"
a/Ida "Heard,"
RAHDRIQ TURNER,
a/Ida "Rah Rah,"
ANTONIO DORSEY,
a/k/a "Bear,"
shall forfeit to the United States of America any property, real or personal, which constitutes or
is derived from proceeds traceable to the offense(s), as well as any property, real or personal,
32
involved in such offense(s), or any property traceable to such property. The property to be
forfeited includes, but is not limited to, the following:
Bank Accounts
a. ING Account Ending X0 70 5, Value: $89,992.88;
b. ING Account Ending Xl90 8, Value: $33,20 2.60 ;
C. ING Account Ending X60 16, Value: $53,934.07;
d. Bank of America Account Ending X0 894, Value: $9,0 70 .0 5;
e. Bank of America Account Ending X0 90 2, Value: $10 0 .0 0 ;
f. Bank of America Account Ending X410 8, Value: $18,976.56; and
g. Bank of America Account Ending X60 56, Value: $2,926.43.
Vehicles
a. 20 0 8 Mercedes Benz S Class S65AMG, VIN Ending 80 33; and
b. 20 0 8 Land Rover Ranger Rover Wesminster, VIN Ending 6920 .
Personal Money Judgment
A sum of money equal to all proceeds the defendants obtained directly or indirectly as a
result of the offenses charged in Counts One and Two of this indictment, and all property used or
intended to be used to facilitate such offenses, and equal to the value of all property, and any
property traceable to such property, involved in money laundering transactions conducted as part
of the money laundering conspiracy charged in Count Two of this indictment, that is, a minimum
of $20 ,0 0 0 ,0 0 0 in United States currency, and all interest and proceeds traceable thereto.
3. If any of the property described above, as a result of any act or omission
of the defendants:
a. cannot be located upon the exercise of due diligence;
33
b.
has been transferred or sold to, or deposited with, a third party;

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 divided without
difficulty,
the United States of America shall be entitled to forfeiture of substitute property pursuant to Title
21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section
982(b)(1) and Title 28, United States Code, Section 2461(c).
A True Bill.
FOIEPERSON
A
Edward J. Tarver (
United States Attorney
Brian T. Rafferty
Criminal Division
mes D. Durham* *
First Assistant United States Attorney
E. Gregory Gill
ul y **
Assistant United States Attorney
** Denotes Lead Counsel
34

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INDICTMENT NO.

has been transferred or sold to, or deposited with, a third party;

has been placed beyond the jurisdiction of the court;

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