u.s. attorney indictment against sutherland, wilson & mccollum

FILED UNITED STATES DISTRICTz61~UJRT

c. Ul 2~ PM 3 39 DISTRICT OF CONNECTItt~TDIS

•. TRlcr COURT N-12-3 NEW HAVEN, CT.

UNITED STATES OF AMERICA Criminal No. 3:13CR I Y0C.f:JJq

v.

THERESA SUTHERLAND, GINA MARIE WILSON and TUW ANDA MCCOLLUM

The Grand Jury charges:

VIOLATIONS:

18 U.S.C. Section 1343 (Wire Fraud) 18 U.S.C. Section 1349 (Conspiracy) 18 U.S.c. Section 1 028A(a))(1) (Aggravated Identity Theft) 18 U.S.C. Section 2 (Aiding and Abetting)

INDICTMENT

COUNTS ONE through SIX (18 U.S.c. § 1343 - Wire Fraud)

1. At all times relevant to this Indictment, the defendants THERESA SUTHERLAND

("SUTHERLAND") and GINA MARIE WILSON ("WILSON") were employed by Mass Mutual

Financial Group ("Mass Mutual") as claims examiners. At all times relevant to this Indictment,

TUW ANDA MCCOLLUM ("MCCOLLUM") was employed by Mass Mutual as a customer service

representative.

2. As employees of Mass Mutual, SUTHERLAND, WILSON and MCCOLLUM were

entitled to $8,500 in college tuition reimbursement yearly and up to $5,000 reimbursement per child

for the expenses associated with the adoption of a child if they incurred qualifying expenses.

The Scheme and Artifice to Defraud

3. On or about the dates set forth below in the District of COlU1ecticut and elsewhere,

SUTHERLAND, WILSON and MCCOLLUM did knowingly and willfully devise and intend to

Case 3:13-cr-00140-AVC Document 1 Filed 07/24/13 of 5

devise, and participate in, a scheme and artifice to defraud and to obtain money and property by

means of materially false and fraudulent pretenses, representations and promises.

Purpose of the Scheme

4. The purpose of the scheme and artifice to defraud was for SUTHERLAND, WILSON

and MCCOLLUM to enrich themselves by converting and stealing money from Mass Mutual by

,lor electronically submitting fraudulent claims for tuition reimbursement an, adoption expenses that

never occurred and for which they were not entitled.

Manner and Means of the Scheme

The manner and means by which SUTHERLAND, WILSON and MCCOLLUM exploited

their status as employees of Mass Mutual and accomplished the scheme included the following:

5. It was part of the scheme and artifice to defraud that SUTHERLAND, WILSON and

MCCOLLUM submitted fraudulent claims and fraudulent documents for tuition reimbursement to

Mass Mutual for college courses allegedly taken when in fact they had never taken such courses.

6. It was further part of the scheme and artifice to defraud that SUTHERLAND and

WILSON submitted fraudulent claims and fraudulent documents for adoption-related expenses to

Mass Mutual when in fact neither SUTHERLAND nor WILSON had any such adoption-related

expenses.

7. On or about the dates listed below, in the District of Connecticut and elsewhere,

SUTHERLAND, WILSON and MCCOLLUM, for the purpose of executing the aforesaid scheme

and artifice to defraud and to obtain money and property by means of materially false and fraudulent

pretenses, representations, and promises, did knowingly transmit and cause to be transmitted, by

means of wire communications in interstate and foreign commerce the writings, signs, signals,

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pictures, sounds and communications described below for each count, each transmission constituting

a separate count:

I Count

I Date

I Use ofInterstate Wires

1 12116/08 UJ ·r~ SUTHERLAND's ..eJ,6. submission for adoption reimbursement expenses allegedly incurred by SUTHERLAND and sent from Mass Mutual in Connecticut to Springfield, Massachusetts

2 1/2/09 SUTHERLAND's Wl't:.e b' . --.::>"ICl "" su mISSIon for education

reimbursement allegedly incurred by SUTHERLAND and sent from Mass Mutual III Connecticut to Springfield, Massachusetts .. -

3 3/23/09 MCCOLLUM's W'~+ b .. ...eUl:a't su mISSIOn for education reimbursement allegedly incurred by MCCOLLUM and sent from Mass Mutual III Connecticut to Springfield, Massachusetts

4 4/3/09 WILSON's~aft~bmission for education reimbursement allegedly incurred by WILSON and sent from Mass Mutual in Connecticut to Springfield, Massachusetts

5 12/7/09 ~ WILSON' s ~' . submission for adoption reimbursement expenses allegedly incurred by WILSON and sent from Mass Mutual in Connecticut to Springfield, Massachusetts

6 1119110 SUTHERLAND's ~,~ b' . em(\! su mISSIOn for adoption reimbursement expenses allegedly incurred by SUTHERLAND and sent from Mass Mutual in Connecticut to Springfield, Massachusetts

All in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT SEVEN ( Conspiracy)

I

8. The allegations contained in paragraphs 1 through 7 are realleged and incorporated

by reference as though fully set forth herein.

9. From approximately 2008 to approximately 2010, the exact dates being unknown to

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the Grand Jury, in the District of Connecticut and elsewhere, SUTHERLAND, WILSON and

MCCOLLUM did unlawfully, knowingly, and intentionally conspire, combine, confederate, and

agree with each other and others known and unknown to the Grand Jury, to commit an offense

against the United States, namely, to devise and intend to devise a scheme and artifice to defraud,

and to obtain money and property from their employer by means of materially false and fraudulent

pretenses, representations, and promises, and, for the purpose of executing and attempting to execute

the scheme and artifice did knowingly transmit and cause to be transmitted, by means of wire

communications in interstate and foreign commerce, writings, signs, signals, pictures, and sounds,

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

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

TW6,L,...Ve COUNTS E1 GRT iliJ:Ounb r.o,J J lUlM!:j>./

(18 U.S.C. § 1 028A(a)(1) - Aggravated Identity Theft)

10. The allegations contained in paragraphs 1-7 are realleged and incorporated by

reference as though fully set forth herein.

11. On or about the dates listed below, in the District of Connecticut and elsewhere,

SUTHERLAND and WILSON did knowingly transfer, possess and use, without lawful authority,

a means of identification of another person during and in relation to a violation of Title 18, United

States Code, Section 1343 , namely, SUTHERLAND and WILSON transferred, possessed, and used,

oor without lawful authority, the names, social security number ~ birth dates, among other things, of

'" the following individuals, whose identities are known to the Grand Jury, when submitting fraudulent

adoption reimbursement requests to Mass Mutual, during and in relation to a scheme to commit wire

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fraud, as set forth above in paragraphs 1-7:

I Count

I Date I Victim

8 12116/08 A.J.T.

9 12116108 T.I.T.

10 1217/09 J.C.M.

11 1217/09 S.D.O.

12 119/10 L.M.K.

All in violation of Title 18, United States Code, Sections 1 048A(a)(1) /tild 1:-e ~

UNITED STATES OF AMERICA

A D:~A('M ATTORNEY

~ P. MORABITO ASSISTANT UNITED STATES ATTORNEY

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u.s. attorney indictment against sutherland, wilson & mccollum

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