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Knowles Indictment
Knowles Indictment
Knowles Indictment
FILED
rz ,
2018
IN THE DISTRICT COURT OF THE UNITED STATES
FOR THE MIDDLE DISTRICT OF ALABAMA
SOUTHERN DIVISION CLERK
U.S. D;STRICT COURT
MOLE DIST. OF ALA.
UNITED STATES OF AMERICA )
)
v. ) CR. NO. I: NeA 5‘
) [18 U.S.C. § 1343;
ANNA MARIE KNOWLES ) 18 U.S.C. § 641;
) 18 U.S.C. § IOW ;
) 18 U.S.C. § 2]
)
) 1NDICTMENT
INTRODUCTION
of Agriculture(USDA). The FSA was tasked with regulating and providing assistance to
farmers and ranchers throughout the United States. National and administrative functions of the
FSA were managed out of offices in Washington, District of Columbia. Implementation offarm
policy through FSA programs was the responsibility of the FSik's state and field offices. The
FSA operated one state office in each state. It operated multiple field offices in each state.
Traditionally, field offices served a single county. During the period alleged in this indictment,
some field offices served multiple adjacent counties. A county committee, consisting of
individuals elected by the farmers within the county(or set of adjacent counties), assisted in
when low yields, loss of inventory, or prevented planting occurred due to natural disasters. To
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be eligible for NAP coverage, an individual or entity was required to:(1) be a landowner, tenant,
share of that crop; and(4) have an average adjusted gross income not in excess of $900,000.
Eligible crops were, among other things, crops grown for food.
3. NAP was funded using government money that was under the custody and control
of the United States Treasury and administered by the USDA's FSA Commodity Credit
Corporation, a wholly owned government corporation within the USDA. NAP was a CCC
coverage and submit that application to the field office serving the area in which the insured crop
was to be grown. On that application, the producer was required to specify the crops for which
she was seeking coverage. Thereafter, the producer was required to report to the FSA field
office that the covered crop had been planted, the location ofthe planting, the number of acres
5. To obtain payment under a NAP policy, a producer was required to complete and
submit to the field office a notice ofloss and application for payment. On that document, the
producer had to provide the following information:(1)the crop name;(2)the crop type;(3)the
crop's intended use;(4) whether irrigation was or was not used to grow the crop;(5)the number
of acres planted;(6)the disaster that caused the loss;(7)the number of acres affected by the
disaster;(8)the cultivation practices employed on the damaged crop;(9) whether any of the
disaster affected crop acreage had been harvested for the intended use. The producer was also
required to sign a certification stating that she "certifies that all information in [the notice of loss]
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payment, a producer seeking to obtain payment under a NAP policy was required to submit to
the field office documentation to show that the producer had attempted to farm the land. For
example, a producer might submit receipts showing the purchase of seed, fertilizer, or pesticide.
7. After a NAP claim was submitted, it was reviewed by the county committee. If
the county committee approved, then it was reviewed by the field office's executive director. lf
the executive director approved, then payment was made. NAP payments were made by
transfers using wires in interstate commerce from the United States Treasury to the financial
institution account designated by the producer. The maximum that a single producer could
receive for a NAP claim in a given crop production year was $116,500.
Alabama FSA field office. She worked as a program technician. Among her responsibilities
were administering NAP within Houston County. Specifically, she was responsible for receiving
COUNT 1
(Wire Fraud)
10. Beginning on or about February 10, 2016 until on or about August 25, 2016, in
Houston County, within the Middle District of Alabama, and elsewhere, the defendant,
aiding and abetting another and aided and abetted by another, knowingly and willfully executed
and attempted to execute a scheme and artifice to obtain, by means of materially false and
fraudulent representations, money and property, in violation of Title 18 United States Code,
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FSA field office a NAP application. In that application, she stated her intention to grow crops
for food.
b. At some time later, Knowles reported to the Houston County FSA field
office that she had planted more than 44 acres of summer squash.
c. On or about July 7, 2016, Knowles filed with the Houston County FSA
field office a notice of loss and request for payment. In that document, Knowles stated that
"[d]rought, hear was the natural disaster that had caused her loss. She reported that all of her
planted acres of squash had been damaged by this disaster. Houston County, Alabama did not
actually experience drought conditions or unusual heat during the 2016 squash season.
Nevertheless, Knowles signed the certification on the document stating that the information in
field office in conjunction with her notice of loss and request for payment. She intended for
those receipts to reflect that she had purchased fertilizer, squash seeds, and chemicals from the
chemical company listed at the top of the receipts. The receipts were forgeries. Knowles had
not in fact purchased fertilizer, squash seeds, or chemicals from the chemical company listed at
e. On or about August 10, 2016, the Houston County FSA county committee
approved Knowles's claim of loss and request for payment. Thereafter, the county executive
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THE CHARGES
12. On or about each of the dates set forth below, in Houston County, within the
for the purpose of executing the scheme described above, and attempting to do so, caused to be
transmitted by means of wire communication in interstate commerce the signals and sounds
described as follows: a wire transfer in the amount of$116,500, made on or about August 25,
2016,from the United States Treasury to Knowles's personal bank account located at a financial
institution in Dothan, Alabama. All in violation of Title 18, United States Code, Section 1343
COUNT 2
(Theft of Government Property)
14. Beginning on or about February 10, 2016 until on or about August 25, 2016, in
Houston County, within the Middle District of Alabama, and elsewhere, the defendant,
aiding and abetting another and aided and abetted by another, did willfully and knowingly steal
and purloin NAP proceeds to which she was not entitled, having a value in excess of $1,000 and
constituting the goods and property of the United States, in violation of Title 18, United States
Code, Section 641 and Title 18, United States Code, Section 2.
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COUNT 3
(Making a False Writing or Document)
16. On or about July 7, 2016, in Houston County, within the Middle District of
knowingly made a false writing and document, knowing that document to contain a materially
false, fictitious, and fraudulent statement and entry in a matter within the jurisdiction of the
United States Department of Agriculture, by stating on a NAP notice of loss and request for
payment that a natural disaster consisting of drought and heat had damaged all of the defendant's
summer squash crop, consisting of more than 44 planted acres, thus making her eligible for
payment under her NAP policy, when in fact, as the defendant then knew, drought and heat had
not damaged more than 44 acres of any summer squash crop the defendant may have had, and
that the defendant was thus not entitled to payment under her NAP policy, in violation of Title
FORFEITURE ALLEGATION
A. The allegations contained in counts 1 and 2 of this Indictment are hereby realleged and
incorporated by reference for the purpose of alleging forfeiture pursuant to Title 18, United States
Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c).
B. Upon conviction of the offenses in violation of Title 18, United States Code, Sections
1343 and 641, set forth in counts 1 and 2 of this Indictment, the defendant,
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shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C)
and Title 28, United States Code, Section 2461(c), all proceeds obtained, directly or indirectly,
from the offenses in violation of Title 18, United States Code, Sections 1343 and 641 including,
but not limited to, a Forfeiture Money Judgment in the amount of $116,500.00, more or less.
C. lf any ofthe property described above, as a result of any act or omission of the
defendant:
(2) has been transferred or sold to, or deposited with, a third party;
(5) 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 28, United States Code, Section
2461(c).
All pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United
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A TRUE BILL:
Foreperson
evin P. Davidson
Assistant United States Attorney