3:24-cr-00252-SAL Date Filed 04/02/24 Entry Number 3 Page 1 of 13

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION

UNITED STATES OF AMERICA ) CRIMINAL NO. f : )d/-~;2_

) 18 u.s.c. §2
) 18 U.S.C. § 666(a)(l)(B)
) 18 U.S.C. § 981(a)(l)(C)
v. ) 18 U.S.C. § 982(a)(l)
) 18 U.S.C. § 1343
) 18 U.S.C. § 1346
) 18 U.S.C. § 1349
CHRISTINE MARY LIVINGSTON, ) 18 U.S.C. § 1952(a)(3)
a/k/a "Liza Jacobs," ) 18 U.S.C. § 1957
a/k/a "Red," ) 28 U.S.C. § 2461(c)
a/k/a "Hell Rell's Queen," )
JERELL REAVES ) SEALED INDICTMENT
a/k/a "Hell Rell" )

THE GRAND WRY CHARGES:

BACKGROUND

At all times material to this Indictment:

1. The Defendant, CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs,"

a/k/a "Red," a/k/a "Hell Rell's Queen," resided and worked in the District of South Carolina.

2. From on or about September 5, 2005 through on or about November 16, 2021, the

Defendant, CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red," a/k/a

"Hell Rell's Queen," served as a Correctional Officer ("CO") with the South Carolina Department

of Corrections ("SCDC"), the South Carolina state prison system. On or about April 16, 2016, she

was promoted to Captain, which is a supervisory position. As Captain, she was responsible for

supervising and managing the security operations at the prison facility where she was assigned,

including the Broad River Correctional Institute ("BRCI").

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3. As a CO, the Defendant, CHRISTINE MARY LIVINGSTON, a/k/a "Liza

Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen," was a certified Class II law enforcement officer

in the State of South Carolina.

4. At all times while she was employed as a CO, SCDC maintained a policy that

employees maintain professional relationships with inmates and that COs conduct themselves in a

way that would avoid situations that "compromise their professional integrity, compromise

security, or cause embarrassment to the Department of Corrections." SCDC policy also prohibited

COs from entering into any kind of personal relationship with inmates, including romantic or

business relationships. COs were also prohibited from engaging in services not in keeping with

SCDC operations or from receiving gifts from inmates or inmate family members. SCDC policy

further prohibited COs from receiving or accepting money from anyone other than the state for the

performance of their official duties, from using official facilities for private gain, and from

receiving a thing of value that could be viewed as being for the purpose of influencing official

action by the CO.

5. State law also prohibited COs from accepting bribes in exchange for performing or

failing to perform acts within the CO's official responsibilities, including under S.C. Code Ann. §

8-13-705(A) and (B) and S.C. Code Ann. § 16-9-220.

6. The Defendant, JERELL REAVES, a/k/a "Hell Rell," was a prisoner in SCDC

who was housed at BRCI.

7. While employed as a CO, the Defendant, CHRISTINE MARY LIVINGSTON,

a/k/a "Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen," accepted at least $219,360.87 in

bribes from inmates and their associates in exchange for smuggling contraband into SCDC. That

contraband included approximately 173 cell phones, as well as headphones, screen protectors,

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phone chargers, sim cards, and other types of contraband. During her time as CO, she accepted

payments from approximately 48 peer-to-peer payment accounts associated with SCDC inmates

and their family members.

8. One of those inmates was the Defendant, JERELL REAVES, a/k/a "Hell Rell,"

who paid and caused to be paid at least $42,640.00 in bribes to the Defendant, CHRISTINE

MARY LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen," who in

exchange smuggled contraband, violated SCDC contraband policy, violated state bribery law, and

violated her duty to render honest and faithful services to the public.

COUNT 1
(Honest Services Wire Fraud Conspiracy-18 US.C. §§ 1343, 1346, 1349)

9. The allegations in paragraphs 1 through 8 of this Indictment are realleged and

incorporated herein by reference as if set forth fully herein.

The Scheme

10. From in or around July 2018, through in or around November 2021, in the District

of South Carolina and elsewhere, the Defendants, CHRISTINE MARY LIVINGSTON, a/k/a

"Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen," and JERELL REAVES, a/k/a "Hell

Rell" knowingly did conspire and agree with each other and others, both known and unknown to

the Grand Jury, to devise and intend to devise a scheme and artifice to defraud and deprive South

Carolina and its citizens of the right to the honest and faithful services of CHRISTINE MARY

LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen," through bribery

and to knowingly and intentionally transmit and cause to be transmitted by means of wire

communications in interstate commerce signals, signs, and sounds for the purpose of executing

such a scheme and artifice.

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Manner and Means

11. It was part of the scheme that the Defendant, CHRISTINE MARY

LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen," operated

approximately fourteen peer-to-peer payment accounts, including through the mobile payment

application Cash App. Those accounts were operated primarily under pseudonyms, and they were

linked to financial accounts in her genuine name.

12. It was further part of the scheme that the Defendant, CHRISTINE MARY

LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen," used those

accounts to accept bribes from dozens of inmates and their associates, including from JERELL

REAVES, a/k/a "Hell Rell."

13. In exchange for the bribes, the Defendant, CHRISTINE MARY LIVINGSTON,

a/k/a "Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen," obtained contraband for inmates,

including by purchasing approximately 173 cellular phones through Amazon. She then smuggled

the contraband into the prison and cause it to be delivered to the inmates. In the process, she

engaged in certain acts and failed to perform certain acts in violation of her job responsibilities,

SCDC policy, state bribery law, and her duty to the public to provide honest and faithful services.

14. The Defendant, CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs,"

a/k/a "Red," a/k/a "Hell Rell's Queen," would then transfer the bribery proceeds to accounts in

her name, spend the proceeds, and enrich herself in the process.

All in violation of Title 18, United States Code, Section 1343, 1346, and 1349.

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COUNTS 2-12
(Honest Services Wire Fraud and Aid/Abet- 18 USC§§ 1343, 1346, 2)

15. The allegations in paragraphs 1 through 14 of this Indictment are realleged and

incorporated herein by reference as if set forth fully herein.

16. On or about the dates below, in the District of South Carolina and elsewhere, the

Defendants as identified below, devised and intended to devise a scheme and artifice to defraud

and deprive the public, South Carolina, and its citizens, of the right to the honest and faithful

services of CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red," a/k/a

"Hell Rell's Queen," through bribery and to knowingly and intentionally transmit and cause to be

transmitted by means of wire communications in interstate commerce the following signals, signs,

and sounds for the purpose of executing such a scheme and artifice in furtherance of the scheme

as described herein, and did aid and abet another in the commission of the aforementioned offense:

Count Date Defendants Amount Description

2. 11/19/2019 CHRISTINE $1,000 Bribe sent on behalf of K.B., an inmate

MARY at BRCI, to Livingston's Cash App
LIVINGSTON account for contraband phone and
phone accessories.

3. 8/15/2020 CHRISTINE $3,000 Bribe sent on behalf of C.D., an inmate

MARY at BRCI, to Livingston's Cash App
LIVINGSTON account for contraband phone and
phone accessories.

4. 8/16/2020 CHRISTINE $1,100 Bribe sent on behalf of Jerell Reaves,

MARY an inmate at BRCI, to Livingston's
LIVINGSTON Cash App account for contraband phone
and phone accessories.
and

JERELL
REAVES

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5. 12/2/2020 CHRISTINE $1,520 Bribe sent on behalf of E.A., an inmate

MARY at BRCI, to Livingston's Cash App
LIVINGSTON account for contraband phone and
phone accessories.

6. 12/2/2020 CHRISTINE $3,000 Bribe sent on behalf of E.A., an inmate

MARY at BRCI, to Livingston's Cash App
LIVINGSTON account for contraband phone and
phone accessories.

7. 12/05/2020 CHRISTINE $7,000 Bribe sent on behalf ofE.B., an inmate

MARY at BRCI, to Livingston's Cash App
LIVINGSTON account for contraband phone and
phone accessories.

8. 3/12/2021 CHRISTINE $5,000 Bribe sent on behalf of Jerell Reaves,

MARY an inmate at BRCI, to Livingston's
LIVINGSTON Cash App account.

and

JERELL
REAVES

9. 6/30/2021 CHRISTINE $4,000 Bribe sent on behalf of Jerell Reaves,

MARY an inmate at BRCI, to Livingston's
LIVINGSTON Cash App account for contraband phone
and phone accessories.
and

JERELL
REAVES

10. 7/5/2021 CHRISTINE $3,000 Bribe sent on behalf of Jerell Reaves,

MARY an inmate at BRCI, to Livingston's
LIVINGSTON Cash App account for contraband phone
and phone accessories.
and

JERELL
REAVES

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11. 7/6/2021 CHRISTINE $1,530 Bribe sent on behalf of Jerell Reaves,

MARY an inmate at BRCI, to Livingston's
LIVINGSTON Cash App account for contraband phone
and phone accessories.
and

JERELL
REAVES

12. 10/10/2021 CHRISTINE $2,000 Bribe sent on behalf of Jerell Reaves,

MARY an inmate at BRCI, to Livingston's
LIVINGSTON Cash App account.

and

JERELL
REAVES

In violation of Title 18, United States Code, Section 1343, 1346, and 2.

COUNT 13
(Use of Interstate Facility to Facilitate Bribery and Aid/Abet- 18 US. C. § l 952(a)(3) and 2)

17. The allegations in paragraphs 1 through 14 of this Indictment are realleged and

incorporated herein by reference as if set forth fully herein.

18. From on or about August 16, 2020 through on or about October 10, 2021, in the

District of South Carolina and elsewhere, the Defendants, CHRISTINE MARY LIVINGSTON,

a/k/a "Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen" and JERELL REAVES, a/k/a

"Hell Rell" used a facility in interstate commerce, with the intent to promote, establish, carry on,

and facilitate unlawful activity, to wit:

a. Bribery in violation of S.C. Code Ann. § 8-13-705; that is, the Defendant,

CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red," a/k/a

"Hell Rell's Queen," directly and indirectly, knowingly accepted, received, and

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agreed to receive something of value as a public official and employee in South

Carolina for herself and another in return for being influenced in the discharge of

her official responsibilities; and

b. Bribery in violation of S.C. Code Ann. § 16-9-220; that is, the Defendant,

CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red," a/k/a

"Hell Rell's Queen," corruptly accepted something of value and a promise to

supply something of value as an officer in South Carolina for her benefit in

exchange for the improper use of the power of her position;

and thereafter performed and attempted to perform an act to promote, establish, carry on, and

facilitate the unlawful activity, and did aid and abet another in the commission of the

aforementioned offense;

In violation of Title 18, United States Code, Section 1952(a)(3) and 2.

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COUNT 14
(Money Laundering- 18 USC§ 1957)

19. The allegations in paragraphs 1 through 14 of this Indictment are realleged and

incorporated herein by reference as if set forth fully herein.

20. From in or around July 2018 through in or around November 2021, in the District

of South Carolina and elsewhere, the Defendant, CHRISTINE MARY LIVINGSTON, a/k/a

"Liza Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen" did knowingly engage or attempt to

engage in monetary transactions, that is the deposit, withdrawal, transfer, or exchange of funds or

a monetary instrument, through or to a financial institution, affecting interstate or foreign

commerce, in criminally derived property of a value greater than $10,000, such property having

been derived from a specified unlawful activity, that is, Honest Services Wire Fraud and

Conspiracy as charged in Counts 1 through 12 of this Indictment, bribery in violation ofS.C. Code

Ann. § 8-13-705(A) and (B) and S.C. Code Ann. § 16-9-220, and Bribery Concerning an Agency

Receiving Federal Funds as charged in Count 15 of this Indictment;

In violation of Title 18, United States Code, Section 1957.

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COUNT 15
(Bribery Concerning Agency Receiving Federal Funds- 18 USC§ 666)

21. The allegations in paragraphs 1 through 14 of this Indictment are realleged and

incorporated herein by reference as if set forth fully herein.

22. From on or about January 1, 2021 through on or about December 31, 2021, in the

District of South Carolina, the Defendant, CHRISTINE MARY LIVINGSTON, a/k/a "Liza

Jacobs," a/k/a "Red," a/k/a "Hell Rell's Queen" being an agent, officer, and employee of SCDC,

an agency that received in that period benefits in excess of $10,000 under a Federal program

involving any form of Federal assistance, corruptly did solicit and demand for the benefit of

herself, corruptly did solicit and demand for the benefit of herself, and did accept and agree to

accept a thing of value, that is, payments as alleged in this Indictment, intending to be influenced

and rewarded in connection with business, transactions, and a series of transactions involving

SCDC in connection with protecting and smuggling shipments of contraband, which invovled a

thing of value of $5,000 or more.

In violation of Title 18, United States Code, Section 666(a)(l)(B).

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FORFEITURE

HONEST SERVICES WIRE FRAUD CONSPIRACY/BRIBERY:

Upon conviction for violations of Title 18, United States Code, Sections 666, 1343 and

1349 as charged in the Indictment, the Defendants, CHRISTINE MARY LIVINGSTON, a/k/a

''Liza Jacobs," a/k/a ''Red," a/k/a "Hell Rell's Queen and JERELL REAVES, a/k/a "Hell

Rell", shall forfeit to the United States any property, real or personal, constituting, derived from

or traceable to proceeds the Defendants obtained, directly or indirectly, as the result of such

violations.

USE OF INTERSTATE FACILITY TO FACILITATE BRIBERY AND AID/ABET:

Upon conviction for violation of Title 18, United States Code, Section 1952 as charged in

the Indictment, the Defendants, CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs,"

a/k/a "Red," a/k/a "Hell Rell's Queen and JERELL REAVES, a/k/a "Hell Rell", shall forfeit

to the United States firearms (by 18 U.S.C. § 924), and any property, real or personal, constituting,

derived from or traceable to proceeds the Defendants obtained, directly or indirectly, as the result

of such violation.

MONEY LAUNDERING:

Upon conviction for violation of Title 18, United States Code, Section 1957 as charged in

this Indictment, the Defendant, CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs,"

a/k/a "Red," a/k/a "Hell Rell's Queen", shall forfeit to the United States any property, real or

personal, constituting, derived from or traceable to proceeds the Defendant obtained, directly or

indirectly, as a result of such offense and any property, real or personal, involved in a transaction

or attempted transaction in violation of 18 U.S.C. § 1957, and any property traceable thereto.

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PROPERTY:

Pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and 982(a)(l), and Title

28, United States Code, Section 2461(c), the property which is subject to forfeiture upon

conviction of the Defendants for the offenses charged in this Indictment includes, but is not limited

to, the following:

A. Cash Proceeds/ Forfeiture Judgment:

A sum of money equal to all property the Defendants obtained as a result of

the offenses charged in the Indictment, that is, a minimum of $219,360.87
in United States currency and all interest and proceeds traceable thereto as
a result of their violations of 18 U.S.C. §§ 666, 1343 and 1349.

B. Money Laundering /Forfeiture Judgment:

A sum of money equal to all property involved in the money

laundering offense charged in the Indictment, and all interest and
proceeds traceable thereto, for which the Defendant is liable as the result
of his violation of 18 U.S.C. § 1957.

SUBSTITUTION OF ASSETS:

If any of the property described above as being subject to forfeiture, as a result of any act

or omission of a Defendant:

A. cannot be located upon the exercise of due diligence;

B. has been transferred or sold to, or deposited with, a third person;
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 subdivided
without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) to seek

forfeiture of any other property of a Defendant up to an amount equivalent to the value of the

above-described forfeitable property;

Pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and 982(a)(l), and Title

28, United States Code, Section 2461 (c).

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--

A _ _/_r-_·v\._(_c_'!,_ _ _ _ _ _ _ BILL

OREPERSON

ADAIR F. BOROUGHS
UNITED STATES ATTORNEY

~ , I (Jr] - ,, ~
By:2~
Elliott B. Daruels (Fed. ID # 11931)
Assistant United States Attorney
United States Attorney's Office
1441 Main Street, Suite 500
Columbia, SC 29201
Telephone 803-929-3000
Facsimile 803-256-0233
Ellliott.Daniels@usdoj.gov

13

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RECORD OF GRAND JURY BALLOT

UNITED STATES OF AMERICA v. CHRISTINE MARY LIVINGSTON, a/k/a "Liza Jacobs," a/k/a "Red,"
a/k/a "Hell Rell's Queen," ET AL.

(SEALED UNTIL FURTHER ORDER OF THE COURT)