Fl LED U.S. DISTRICT COURT EASTERN DISTRICT OF TEXAS IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MAY O2 2018 BEAUMONT DIVISION BY UNITED STATES OF AMERICA § DEPUTY~~~~~~- § V. § CRIMINAL NO. 1:18-CR- /4 3 § PATRICK WAYNE BRONNON (1) § GLENN DELL ETIENNE (2) § GERALDINE WELDON JOSEPH (3) § MORRIS BROUSSARD § aka "Bruiser" ( 4) § KEISHA WINDON LEWIS (5) § HELENE WILLIAMS CALCOTE (6) § CYNTHIA LYNN BANION (7) § EARNEST HAMILTON (8) § NATHANIEL JOSEPH CHEVALIER (9) § KENDRA CHEVALIER (10). § RODRIC LEDAE WALLACE (11) § RILEY MOSS REED (12) § INDICTMENT THE UNITED STATES GRAND JURY CHARGES: Count One Violation: 18 U.S.C. § 1349 (Conspiracy to Commit Mail Fraud) The Conspiracy Beginning on or about December, 2011, and continuing until on or about May 25, 2017, Patrick Wayne Bronnon (Bronnon), Glenn Dell Etienne (Etienne), Geraldine Weldon Joseph (Joseph), Morris Broussard, aka "Bruiser" (Broussard), Keisha 1 Windon Lewis (Lewis), Helene Williams Calcote (Calcote), Cynthia Lynn Banion (Banion), Earnest Hamilton (Hamilton), Nathaniel Joseph Chevalier (N. Chevalier), Kendra Chevalier (K. Chevalier), Rodric Ledae Wallace (Wallace), and Riley Moss Reed (Reed), defendants, did lrnowingly and intentionally combine, conspire, confederate, and agree with each other, and with other persons, both lrnown and unknown to the Grand Jury, to commit Mail Fraud, that is, to devise a scheme and artifice to defraud, and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, and for the purpose of executing such scheme and artifice, place in an authorized depository for mail matter any matter or thing to be sent or delivered by the Postal Service, take or receive from an authorized depository for mail matter any matter or thing, and lrnowingly cause to be delivered by mail or by any private or commercial interstate carrier any matter or thing, according to the direction thereon or at the place at which it is directed to be delivered by the person to whom it is addressed, in violation of 18 U.S.C. § 1341. Object of the Conspiracy It was the object of the conspiracy to obtain money and funds from various insurance providers through fraudulent insurance claims, including claims for fire casualty, water damage, and theft, in the Port Arthur, Texas and greater Southeast Texas area. Manner and Means of the Conspiracy 2 Defendants Bronnon and Etienne approached several individuals about purchasing a home and insurance in their names. Bronnon or Etienne would select the home, and sometimes provide the policy owners with funds for the down payment and the initial insurance payment. Within a few weeks of the insurance becoming effective, Bronnon, Etienne or one of the policy owners would intentionally cause damage to the home, typically through fire or water damage. The policy owner would then initiate the claims process, knowing that the damage was intentional, causing a fraudulent claim to be filed. The insurance policies included the cost to replace the structure, the contents of the home, and emergency living expenses. 1. The homes were generally low value properties, with purchase prices as low as $25,000. However, the insurance policies purchased by the defendants covered the cost to replace the home with a new, up-to-code structure, and as such, the cost of replacement was significantly higher than the purchase price of the home. 2. In addition to the cost of replacement of the structure, the insurance policies covered the contents of the home. In order to make a claim for the contents of the home, the insured homeowner must make a detailed list of all personal items damaged in the fire or other event underlying the insurance claim, such as furniture, clothes, kitchen supplies, electronics and personal effects. The list must also include an estimated value of the damaged items. 3 . • 3. The insurance policies purchased by the defendants also covered "Additional Living Expenses" (ALE). Additional Living Expense coverage provides compensation to the insured when they are unable to live in their own home due to an insured loss or claim and while the home is being repaired. ALE provides the insured money to allow them to maintain their usual lifestyle, and compensate for the additional costs of living elsewhere when the home is destroyed or uninhabitable until it is repaired, or until the ALE policy limits are reached. 4. In addition to claims for loss of the property itself, Bronnon and other co­ defendants filed fraudulent claims for burglaries that never occurred. 5. The following acts were committed by the following defendants in furtherance of the conspiracy: a. On or about December 1, 2011, Bronnon intentionally caused water damage to the home of Joseph at 4300 4th Street, Port Arthur, Texas. b. On or about December 2, 2011 Joseph told Allstate Insurance Company (Allstate) that her home at 4300 4th Street, Port Arthur, Texas flooded due to a burst pipe, when she knew that Bronnon intentionally caused the water damage for the purpose of filing a fraudulent insurance claim. c. On or about January 11, 2013, Bronnon and Broussard went to Joseph's home at 4300 4th Street, Port Arthur, Texas and intentionally started a fire in the home. 4 d. On or about January 12, 2013, Joseph told Allstate that she was at 4300 4th Street, Port Arthur, Texas frying pork chops, started having chest pains, and left the home to go to the hospital, forgetting about the pork chops, which ultimately caused the fire, and which Joseph knew to be untrue. e. On or about May 20, 2013, Joseph reported to Allstate that while 4300 4th Street, Port Arthur, Texas was being repaired from the previous fire, thieves stole a number of items from the home, totaling approximately $29,437.71. However, as Joseph was aware at the time she filed the claim, no theft took place and no property was stolen. f. On or about October 28, 2014, Bronnon intentionally caused a fire in Joseph's home at 4300 4th Street, Port Arthur, Texas. g. On or about October 28, 2014, Joseph contacted Allstate to file a claim for 4300 4th Street, Port Arthur, Texas, and claimed that she was unaware of how the fire began, which she knew at the time to be untrue. h. On April 15, 2013, Broussard secured insurance through American Hallmark Insurance Company of Texas (Hallmark) for 13118 Worthington Street; Sugarland, Texas for the purpose of committing fraud. 1. On or about April 22, 2013, Broussard called Hallmark and claimed that 13118 Worthington Street, Sugarland, Texas burned down as a result of the co-defendant Banion leaving a foil wrapped chicken in the microwave, and then leaving the home, which he knew to be untrue. 5 J. On or about October 3, 2014, Calcote and Bronnon signed a document titled "Sworn Statement in Proof of Loss." In the "Sworn Statement in Proof of Loss," Bronnon and Calcote stated that at least $80,000 worth of property was stolen from 13118 Worthington Street, Sugarland, Texas, which they both knew to be untrue. k. On or about March 3, 2015 Banion claimed to sign a contract for sale of 13118 Worthington Street, Sugarland, Texas with Bronnon, who then transferred title to the home to her. 1. On March 4, 2015, Banion purchased homeowners insurance for 13118 Worthington Street, Sugarland, Texas from GeoVera Specialty Insurance Company (Geo Vera). m. On or about March 11 , 2015, Banion called Geo Vera and told them that she went to the house that day to find that a pipe burst in the celling and as a result, the house was flooded and that the flooding was accidental. n. Sometime just prior to on or about March 11, 2016, Etienne approached N. Chevalier about purchasing the home at 1049 Nederland Ave., Port Arthur, Texas. o. On or about March 11, 2016, N. Chevalier purchased 1049 Nederland Ave., Port Arthur, Texas for the purpose of filing a fraudulent insurance claim. p. Sometime just prior to March 11, 2016, Etienne provided N. Chevalier $5 ,000 to use as a down payment for 1049 Nederland Ave., Port Arthur, Texas to further the scheme to defraud Farmers Insurance Group (Farmers). 6 ·. q. On or about March 24, 2016, Bronnon intentionally set a fire at 1049 Nederland Ave., Port Arthur, Texas, causing significant damage. r. Sometime between March 24, 2016 and May 20, 2016, Etienne provided N. Chevalier and K. Chevalier a list of contents for 1049 Nederland Ave., Port Arthur, Texas to submit to Farmers as part of their insurance claim, knowing those items were not in their home. s. On or about May 20, 2016, N. Chevalier and K. Chevalier submitted a list of contents for 1049 Nederland Ave., Port Arthur, Texas to Farmers that they claimed were lost in the fire, when they knew that list to be fraudulent. t. On or about May 20, 2016, N. Chevalier and K. Chevalier signed a Proof of Loss for 1049 Nederland Ave., Port Arthur, Texas, in which they attested that the fire "did not originate or continue by any act, design, procurement, or willful neglect on the part of the insured," which they knew to be false. u. On or about March 24, 2012, Hamilton purchased the home at 824 Richmond, Port Arthur, Texas for the purpose of filing a fraudulent insurance claim. v. On or about March 31, 2012, Bronnon intentionally burned 824 Richmond, Port Arthur, Texas down in order to collect insurance proceeds. w. On or about April 1, 2012, Hamilton instructed Reed to sign a letter stating that the fire at 824 Richmond, Port Arthur, Texas was caused by Reed's generator, when . Hamilton knew that the fire was intentionally started.