Katrina Pierce Indictment

Case: 1:21-cr-00564 Document #: 12 Filed: 09/27/21 Page 1 of 29 PageID #:47
FIL ED JMK
7/2021
9/2
. BRUTO N UNITED STATES DISTRICT COURT
THOMA.SDGIS T R ICT COURT
CLERK, U .S NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA ) No.2t CR 564

) Violations: Title 18,
v. ) United States Code,
) Sections IOI4,1028(a)(4),
KATRINA PIERCE ) 1028A(a)(1), and 1343
COUNT ONE JUDGE KENDALL

(Wire Fraud) MAGISTRATE JUDGE VALDEZ
The SPECIAL NOVEMBER 2020 GRA,ND JURY charges:
1. At times relevant to Counts One through Seven of this indictment:
a. Defendant KATRINA PIERCE was a resident of Chicago, Illinois.
b. The Coronavirus Aid, Relief, and Economic Security (CARES) Act
was a federal law enacted to provide emergency relief to American workers and small
businesses suffering from the economic effects of the Coronavirus pandemic.
c. Pursuant to the CARES Act, the U.S. Department of the Treasury
provided Economic Impact Payments (so-called "stimulus" payments) to American
households. The first stimulus payments were issued in amounts up to $1,200 per
adult earning less than $99,000, and $500 per child under the age of 17 . These initial
stimulus payments were automatic for eligible taxpayers who fiIed a 2079 federal
income tax return.
d. Low- to moderate-income families qualifying for Earned Income
Tax Credits and Additional Child Tax Credits could reduce the amount of taxes they
owed, while increasing the amounts of their tax refunds, based in part on the number
of children in their families.

e. A representative ofa deceased taxpayer could claim a refund due
to that deceased taxpayer, for federal income taxes overpaid by or on behalf of the
decedent, by filing a form with the Internal Revenue Service (IRS Form 1310),
verifiring under penalty of perjury that the claim was true, correct, and complete.
f. The Cook County Clerk's Office was the official keeper of vital
records, including records of births and deaths occurring in Chicago.
' g. A relative of a deceased person could request a death certifi.cate
from the Clerk's Office by mailing a written application certifiring that the requestor
is a relative of the decedent and is entitled to the record pursuant to Illinois law; by
providing a copy of an identification card; and by paying a processing fee.

Alternatively, a requestor could submit an application electronically through a
computer system at a neighborhood currency exchange.
2. Beginning in or about 2019 and continuing until on or about September
L4, 2021, at Chicago, in the Northern District of Illinois, Eastern Division, and
elsewhere,
KATRINA PIERCE,
defendant herein, deyised, intended to devise, and participated in a scheme to
defraud and to obtain money from the U.S. Treasury by means of materially false and
fraudulent pretenses, representations, and promises, as described below.
3. It was part of the scheme that PIERCE requested and obtained death
certificates from certain government bureaus of vital statistics, including those of
Cook County and Springfield, Illinois, and the States of California, Michigan,
2
Minnesota, Missouri, and North Carolina, so that she could obtain personal identity
information of deceased persons and then use that identity information to defraud
the federal government. PIERCE fraudulently obtained death certificates in part by
falsely claiming to be a relative of deceased victims.
4. It was further part of the scheme that PIERCE knowingly filed false and
fraudulent income tax returns with the IRS, and caused false and fraudulent income
tax returns to be filed with the IRS, electronically and by mail. PIERCE fiIed such
tax returns under her own name, under the name of an alias ("Rajona Pierce"), and
under the names of other persons, including deceased persons, whose personal
identity information had been fraudulently obtained by her. PIERCE did so with the
intent of fraudulently obtaining tax refunds and stimulus payments from the
Treasury.
5. It was further part of the scheme that the federal income tax returns
filed and caused to be filed by PIERCE contained materially false information

regarding the purported taxpayers' personal information, business information, and
income, among other things. For example, in an income tax return that PIERCE filed
in her own name, she falsely claimed to be a "Head of Household," with a deceased
boy listed as a dependent child, so that she could fraudulently claim certain tax
credits and a larger tax refund to which she was not otherwise entitled.
6. It was further part of the scheme that PIERCE attempted to support the
false representations in those income tax returns by attaching, and causing to be

attached, certain false schedules and forms, falsely reporting and claiming, among
other things, additional income and adjustments to income (Schedule 1); additional
taxes (Schedule 2); income and expenses from business (Schedule C); earned income
credit (Schedule EIC); self-employment tax (Schedule SE); additional child tax credit
(Schedule 8812); and an IRS Form 1310 (Statement of Person Claiming Refund Due
a Deceased Taxpayer).
7. It was further part of the scheme that PIERCE attached fabricated birth
certificates to income tax returns, and caused fabricated birth certificates to be
attached to income tax returns, falsely claiming deceased children as dependents.
8. It was further part of the scheme that the false and fraudulent income
tax returns filed and caused to be filed by PIERCE listed accounts that she controlled
for purposes of receiving deposits of tax refunds or stimulus payments to which she
was not entitled.
9. It was further part of the scheme that PIERCE concealed,

misrepresented, and hid, and caused to be concealed, misrepresented, and hidden,
the existence of the scheme, the purposes of the scheme, and the acts committed in
furtherance of the scheme.
10. On or about April 4,2020, at Chicago, in the Northern District of Illinois,
Eastern Division, and elsewhere,
KATRINA PIERCE,
defendant herein, for the purpose of executing the scheme described above, knowingly
transmitted and caused to be transmitted by means of wire communication in
interstate commerce, certain writings, signs, and signals, namely, a false and
4
fraudulent U.S. Individual Income Tax Return (IRS Form 1040), for tax year 2019, in
the name of an alias, "Rajona Pierce," which income tax return was transmitted to
the IRS electronically via an interstate network;
In violation of Title 18, United States Code, Section 1343.

COUNT TWO
(Wire Fraud)
The SPECIAL NOVEMBER 2020 GRAND JURY further charges:
1. Paragraphs 1 through 9 ofCount One are incorporated here.
2. On or about April 29, 2020, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,
KATRINA PIERCE,
her own name, which income tax return was transmitted to the IRS electronically via
an interstate network;
In violation of Tit1e 18, United States Code, Section 1343.
6
COUNT THREE
(Wire Fraud)
The SPECIAL NO\IEMBER 2020 GRAND JURY further charges:
2. On or about May 26, 2020, at Chicago, in the Northern District of
KATRINA PIERCE,
fraudulent U.S. Individual Income Tax Return (IRS Form 1040) for tax year 2019, in
the name of a deceased person ffictim 1), which income tax return was transmitted
to the IRS electronically via an interstate network;

COUNT FOUR
(Wire Fraud)
The SPECIAL NO\IEMBER 2020 GRAND JURY further charges:
2. On or about June 76, 2020, at Chicago, in the Northern District of
KATRINA PIERCE,
fraudulent U.S. Individual Income Tax Return (IRS Form 1040) for tax year 2019, in
the name of a deceased person (Victim 2), which income tax return was transmitted

COUNT FIVE
(Wire Fraud)
2. On or about February L4, 2021, at Chicago, in the Northern District of
KATRINA PIERCE,
her own name, which income tax return was transmitted to the IRS electronically via
an interstate network;
I
COUNT SD(
(Wire Fraud)
1. Paragraphs 1 through 9 of Count One are incorporated here.
2. On or about February 74, 2021, at Chicago, in the Northern District of
KATRINA PIERCE,
the name of an alias, "Rajona Pierce," which income tax return was transmitted to
the IRS electronically via an interstate network;
In violation of Tit1e 18, United States Code, Section 1343.
10
COUNT SEVEN
(Wire Fraud)
KATRINA PIERCE,
transmitted. and caused to be transmitted by means of wire communication in
fraudulent U.S. Individual Income Tax Return (IRS Form 1040) for tax year 2020, rn
the name of a deceased person (Victim 1), which income tax return was transmitted
11
COUNT EIGHT
(Aggravated Identity Theft)
2. On or about April 29, 2020, at Chicago, in the Northern District of
KATRINA PIERCE,
defendant herein, knowingly transferred, possessed, and used, and caused to be
transferred, possessed, and used, without lawful authority, a means of identification
of another person, specifically, the name and social security number of Victim 3,
during and in relation to a felony violation, namely, the wire fraud offense described
in Count Two;
In violation of Title 18, United States Code, Section 1028A(a)(1).
T2
COUNT NINE
2. On or about May 26, 2020, at Chicago, in the Northern District of
KATRINA PIERCE,
in Count Three;
13
COUNT TEN
2. On or about June 16, 2020, at Chicago, in the Northern District of
KATRINA PIERCE,
in Count Four;
t4
COUNT ELEVEN
1. Paragraphs 1 through g ofCount One are incorporated here.
KATRINA PIERCE,
defendant herein, knowingly transferred, possessed, and used, and caused. to be
of another person, specifi"cally, the name and social security number of Victim B,
in Count Five;
In violation of Title 18, United States Code, Section 102SA(a)(1).
15
COUNT TWELVE
2. On or about February 20, 202L, at Chicago, in the Northern District of
KATRINA PIERCE,
in Count Seven;
16
COUNT THIRTEEN
(Possession of Identification Documents)
The SPECIAL NOVEMBER 2020 GRA.ND JURY further charges:
2. On or about September 14,2021, at Chicago, in the Northern District of
Illinois, Eastern Division,
KATRINA PIERCE,
defendant herein, knowingly possessed identification documents, namely, more than
35 death certifi.cates issued by the States of California, Illinois, Michigan, Minnesota,
Missouri, and North Carolina, with the intent that such documents be used to defraud
the United States;
In violation of Title 18, United States Code, Section 1028(aX ).
t7
COUNT FOURTEEN
(Wire Fraud)
1. At times relevant to Counts Fourteen through Sixteen of this

indictment:
a. The COVID-l9 Economic Injury Disaster Loan (EIDL) program
was a financial assistance program for small businesses suffering from a temporary
loss of revenue because of the Coronavirus pandemic. Pursuant to this EIDL
program, eligible small business owners could obtain low-interest, long-term loans in
amounts up to $150,000, and advances on such loans in amounts up to $10,000.
b. The EIDL program was administered by the U.S. Small Business
Administration (SBA). SBA was authorized to provide EIDL loans and advances to
enable small business owners to satisfiz financial obligations and operating expenses
that they otherwise could have satisfied if the pandemic had not occurred. SmaII
business owners could use the proceeds of EIDL loans and advances for working
capital and normal business operating expenses, such as employee payroll, health
care benefits, and rent.
c. Applications for EIDL loans and advances could be transmitted
to SBA electronically, using a portal on SBA's internet website.
d. Defendant KATRINA PIERCE was not an ElDl,-eligible small
business owner.
2. During August 2020, at Chicago, in the Northern District of Illinois,
Eastern Division, and elsewhere,
18
KATRINA PIERCE,
defendant herein, d.evised, intended. to devise, and participated in a scheme to
defraud and to obtain money from the U.S. Treasury by means of materially false and
fraudulent pretenses, representations, and promises, as described below.
3. It was part of the scheme that PIERCE submitted EIDL applications to
SBA, and caused EIDL applications to be submitted to SBA, in which she falsely
claimed to be a small business owner with employees.
4. It was further part of the scheme that PIERCE submitted false and
fraudulent EIDL applications to SBA, and caused false and fraudulent EIDL
applications to be submitted to SBA, under the names of other persons, including
farmers and small business owners in Illinois and other states, whose personal
identity information was unlawfully taken and used without their knowledge and
consent.
5. It was further part of the scheme that PIERCE knowingly made
materially false statements in EIDL applications, and caused materially false
statements to be made in EIDL applications, concerning the existence and nature of
the purported small businesses on whose behalf she sought EIDL loans and loan
advances. For example, in separate EIDL applications, PIERCE falsely claimed that
she was the owner of a manufacturing business with 106 employees and a retail
electronics business with 14 employees, both businesses purportedly located at the
same address (an apartment where PIERCE was then residing), when in fact,
PIERCE did not own or operate any such businesses.
19
6. It was further part of the scheme that PIERCE intentionally listed false
telephone numbers and email addresses in her false and fraudulent EIDL
applications to prevent SBA from contacting the purported small business owners/
loan applicants and then uncovering the fraud scheme.
7. It was further part of the scheme that the false and fraudulent EIDL
applications that PIERCE knowingly submitted to SBA, and caused to be submitted
to SBA, listed bank accounts that she controlled for purposes of receiving deposits of
EIDL loan proceeds.
8. It was further part of the scheme that PIERCE transmitted false and
fraudulent EIDL applications to SBA electronically, and caused false and fraudulent
EIDL applications to be transmitted to SBA electronically, via SBA s online portal.
9. It was further part of the scheme that PIERCE concealed,

misrepresented, and hid, and caused to be concealed, misrepresented, and hidden,
the existence of the scheme, the purposes of the scheme, and the acts committed in
furtherance of the scheme.
10. On or about August L7, 2020, at Chicago, in the Northern District of
KATRINA PIERCE,
fraudulent EIDL application in which she (PIERCE) falsely claimed to be the owner
20
of a retail electronics business with 14 employees, which false and fraudulent EIDL
application was transmitted to SBA electronically via an interstate network;
2t
COUNT FIFTEEN
(Wire Fraud)
1. Paragraphs 1 through 9 ofCount Fourteen are incorporated here.
2. On or about August 24, 2020, at Chicago, in the Northern District of
KATRINA PIERCE,
fraudulent EIDL application in which she (PIERCE) falsely claimed to be the owner
of a manufacturing business with 106 employees, which false and fraudulent EIDL
22
COUNT SD(TEEN
(Wire Fraud)
1. Paragraphs 1 through 9 ofCount Fourteen are incorporated here.
KATRINA PIERCE,
fraudulent EIDL application under the name of the owner of an agriculture business
in Ramsey, Illinois ffictim 4), a person whose identity information was taken and
used without his knowledge and consent, which false and fraudulent EIDL
23
COUNT SEVENTEEN
(False Statements)
1. Paragraph 1 ofCount Fourteen is incorporated here.
KATRINA PIERCE,
defendant herein, knowingly made false statements to SBA, and caused false
statements to be made to SBA, for the purpose of influencing the action of SBA upon
an EIDL application. More specifically, in an EIDL application transmitted

electronically to SBA, PIERCE falsely stated, among other things, that:
a. she was the owner of a retail electronics business;
b. the business was established on March 19, 2008;
c. the business had 14 employees as of January 31, 2020;
d. for the 12-month period prior to January 31, 2020, the business
had $178,000 in gross revenues;
e. the cost of goods sold for the 12-month period prior to January
31,2020, was $85,000;
f. the business lost $62,000 in rents because of the disaster; and
g. the non-profit or agricultural enterprise cost of operation for the

12-month period prior to January 37,2020, was $47,000;
when in fact, as PIERCE then knew, this alleged business did not exist;
24
COUNT EIGHTEEN
(False Statements)
KATRINA PIERCE,

a. she was the owner of a manufacturing business;
b. the business was established on September 8, 2010;
c. the business had 106 employees as of January 31, 2020;
d. for the l2-month period prior to January 3I,2O2O, the business

had $670,000 in gross revenues; and
e. the cost of goods sold for the l2-month period prior to January
31,2020, was $280,000;
when in fact, as PIERCE then knew, this alleged business did not exist;
In violation of Tit1e 18, United States Code, Section L014.
25
COUNT NINETEEN
(False Statements)

KATRINA PIERCE,

a. "KATRINA PIERCE" was the trade name for an agriculture

business in Ramsey, Illinois;
b. mh[xxxxxxxxxx]@mail.com was the email address for that

agriculture business and its owner; and
c. the business held a certain bank account (ending in 8204) at a

certain bank;
when in fact, as PIERCE then knew, her name was not the trade name for that
business, she had no legitimate relationship with or connection to that business, the
listed email address was false, and the listed bank account was her account;
26
COUNT TWENTY
The SPECIAL NOVEMBER 2O2O GRAND JURY further charges:
1. Paragraphs 1 through g ofCount Fourteen are incorporated here.
KATRINA PIERCE,
of another person, namely, the name and social security number of Victim 4, during
and in relation to a felony violation, namely, the wire fraud offense described in Count
Sixteen;
27
FORFEITURE ALLEGATION
(Proceeds of Tax Fraud Scheme)
The SPECIAL NOVEMBER 2020 GRAND JURY further alleges:
1. The allegations in Counts One through Seven are incorporated here 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 2a6l@).
2. As a result of her violations of Title 18, United States Code, Section
1343, as alleged in Counts One through Seven,
KATRINA PIERCE,
defendant herein, 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),
any and all right, title, and interest she may have in any property, real and personal,
which constitutes and was derived from proceeds traceable to such violations.
3. If any of the forfeitable property described above, as a result of any act
or omission by PIERCE:
a. cannot be located upon the exercise of due diligence;
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,
28
the United States shall be entitled to forfeiture of substitute property under the
provisions of Title 21, United States Code, Section 853(p), as incorporated by Title 28,
United States Code, Section 246t(c);
All pursuant to Title 18, United States Code, Section 981(aX1)(C), and Title
28, United States Code, Section 2aGI@).
A TRUE BILL:
FOREPERSON
Signed by Jason Yonan on behalf of the

UNITED STATES ATTORNEY
29

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Case: 1:21-cr-00564 Document #: 12 Filed: 09/27/21 Page 1 of 29 PageID #:47

UNITED STATES OF AMERICA ) No.2t CR 564

COUNT ONE JUDGE KENDALL

1. At times relevant to Counts One through Seven of this indictment:

a. Defendant KATRINA PIERCE was a resident of Chicago, Illinois.

b. The Coronavirus Aid, Relief, and Economic Security (CARES) Act

businesses suffering from the economic effects of the Coronavirus pandemic.

c. Pursuant to the CARES Act, the U.S. Department of the Treasury

provided Economic Impact Payments (so-called "stimulus" payments) to American

income tax return.

d. Low- to moderate-income families qualifying for Earned Income

of children in their families.

e. A representative ofa deceased taxpayer could claim a refund due

records, including records of births and deaths occurring in Chicago.

' g. A relative of a deceased person could request a death certifi.cate

providing a copy of an identification card; and by paying a processing fee.

computer system at a neighborhood currency exchange.

2. Beginning in or about 2019 and continuing until on or about September

defendant herein, deyised, intended to devise, and participated in a scheme to

fraudulent pretenses, representations, and promises, as described below.

certificates from certain government bureaus of vital statistics, including those of

the federal government. PIERCE fraudulently obtained death certificates in part by

falsely claiming to be a relative of deceased victims.

filed and caused to be filed by PIERCE contained materially false information

false representations in those income tax returns by attaching, and causing to be

certificates to income tax returns, and caused fabricated birth certificates to be

attached to income tax returns, falsely claiming deceased children as dependents.

was not entitled.

9. It was further part of the scheme that PIERCE concealed,

furtherance of the scheme.

10. On or about April 4,2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

transmitted and caused to be transmitted by means of wire communication in

the IRS electronically via an interstate network;

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

The SPECIAL NOVEMBER 2020 GRAND JURY further charges:

1. Paragraphs 1 through 9 ofCount One are incorporated here.

2. On or about April 29, 2020, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

transmitted and caused to be transmitted by means of wire communication in

In violation of Tit1e 18, United States Code, Section 1343.

The SPECIAL NO\IEMBER 2020 GRAND JURY further charges:

1. Paragraphs 1 through 9 ofCount One are incorporated here.

2. On or about May 26, 2020, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

transmitted and caused to be transmitted by means of wire communication in

to the IRS electronically via an interstate network;

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

The SPECIAL NO\IEMBER 2020 GRAND JURY further charges:

1. Paragraphs 1 through 9 ofCount One are incorporated here.

2. On or about June 76, 2020, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

transmitted and caused to be transmitted by means of wire communication in

to the IRS electronically via an interstate network;

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

The SPECIAL NOVEMBER 2020 GRAND JURY further charges:

1. Paragraphs 1 through 9 ofCount One are incorporated here.

2. On or about February L4, 2021, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

transmitted and caused to be transmitted by means of wire communication in