Inpicromnr dein het 74s19-19cams—_cincurr court no. Blk 9G-EFP Fraudulent Representations §97-7-10 20 Counts Wire Fraud §97-19-83 - 20 Counts FTlCeD THE STATE OF MISSISSIPPI Circuit Court FIRST DISTRICT, HINDS COUNTY APR 05 2024 January Term, A.D., 2024 ZACK WALLACE, cIRCUTTCLERK First Judicial District P co! Hinds County TThe Grand Jurors of the State of Mississippi, taken from the body of good and lawful persons of the First Judicial District of Hinds County, in the State of Mississippi, elected, impanelled, swom and charged to inquice in and for said District, County and State aforesaid, in the name and by the authority of the State of Mississippi, upon their oath present: That Kenjarell Thomas ‘while acting in concert and/or aiding, assisting or encouraging another or others known and unknown tothe grand jury In said District, County and State COUNTI on, about and between the 1° day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighieen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Cedric Curry without Cedrie Curry’s authorization with the intent to unlawfully use such information to fraudulenily obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Cedric Curry, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $106.00 toa Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, COUNT ‘based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 and the 30 day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state ot local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made anyfalse, fictitious and fraudulent statements or representations, or made or used Be writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or ‘made false, fictitious and fraudulent statements or representations, and/or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Cedric Curry an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $106.00 to a Way2Go Visa Debit Card for Cedric Curry which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-T-10, Mississippi Code Annotated (1972, as amended); and, COUNT IIL based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the I* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining ‘money, property ot services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting s0 10 do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the ‘grand jury, unemployment benefits purporting to be for the benefit of Cedric Curry an inmate at the Mississippi Department of Corrections, wio was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $106.00 to a Way2Go Visa Debit Card for Cedrie Curry which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state Jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within theau-Bao-EFP jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, ‘as amended); and, COUNT IV on, about and between the 1" day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighieen (18) years, did willfully, unlawfully, and feloniously, obiain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Cornealous Williams without Comealous Williams’ authorization ‘with the intent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Comealous Williams, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, COUNT V based upon a series of acts connected together and constituting parts of a common scherne and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 and the 30" day of September, 2020, willfully, ‘unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and freudulent statements or entries, To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any false ‘writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Comealous Williams an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card for Comealous Williams which funds were then accessed andaui-aale-EFP converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT VI based upon a series of acts connected together and constituting parts of a common scheme ‘and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the l* day of June, 2020, and the 30 day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining ‘money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or 10 sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempied to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Comealous Williams an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such ‘unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $2,118.00 to. 2 Way2Go Visa Debit Card for Comealous Williams which funds were then accessed and converted to Kenkarell Thomas’ use, by means of false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and, COUNT VII ‘on, about and between the 1% day of June, 2020, and the 30" day of September, 2020, the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighteen (18) years, did willfully, unlawfully, and feloniously, obiain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Dorian Record without Dorian Record’s authorization with the Intent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Dorian Record, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the totalamount of $2,118.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, COUNT VII based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 and the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, ‘agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, ‘To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defiaud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Dorian Record an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card for Dorian Record which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT IX based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years. did, on, about and between the I* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining ‘money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice ora4-date-EFP attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Dorian Record an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $2,118,00 10 a Way2Go Visa Debit Card for Dorian Record which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, ‘as amended); and, NT X oon, about and between the 1" day of June, 2020, and the 30 day of September, 2020, . in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighicen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Gilbert Chim without Gilbert Chim’ s authorization with the intent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Gilbert Chim, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total ‘amount of $212.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring Within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, COUNT XI based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 and the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries,‘To-wit: Kenjarell Thomas, while acting in concert and/or aiding, wining ce: ee and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or ‘made false, fictitious and fraudulent statements or representations, and/or made or used any false ‘writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury. unemployment benefits purporting 10 be for the benefit of Gilbert Chim an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $212.00 to a Way2Go Visa Debit Card for Gilbert Chim which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT XII based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, oF to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, ot anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Gilbert Chim an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $212.00 to a Way2Go Visa Debit Card for Gilbert Chim which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, ‘as amended); and,COUNT XIII QY-Ite FP ‘on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighieen (18) years, did willfully, unlawfully, and feloniously, obiain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Jacarius Beiley without Jacarius Bailey's authorization with the Fhtent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Jacarius Bailey, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies inthe total amount of $106.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding. the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the I day of June, 2020 and the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any false ‘writing or document knowing that the same contained false, fictitious and fraudulent statements or centries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, tinempioyment benefits purporting to be for the benefit of Jacarius Bailey an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $ 106.00 to a Way2Go Visa Debit Card for Jacarius Bailey which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction ofthis court and in violation of Section 97-17-10, Mississippi Code Annotated (1972, as amended); and.COUNT XV aul-dab-EFP based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining ‘money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security ot other article, or anything represented to be of intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting s0 to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Jacarius Bailey an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $106.00 to a Way2Go Visa Debit Card for Jacarius Bailey which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, ‘as amended); and, COUNT XVI ‘on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, . in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighieen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of James Conner without James Conner’s authorization with the intent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of James Conner, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $1,218.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and,COUNT XVIL OU-9ab-EP based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 and the 30” day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, ‘To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to deffaud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device @ material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any false ‘writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, ‘unemployment benefits purporting to be for the benefit of James Conner an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material faet(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $1,218.00 to a Way2Go Visa Debit Card for James Conne: which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT XVIII based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did. on, about and between the 1" day of une, 2020, and the 30 day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, secutity or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious end fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of James Conner an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon byQt-sab- EFP the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $1,218.00 to a Way2Go Visa Debit Card for James Conner which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or: artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and, (COUNT IXx ‘on, about and between the 1* day of June, 2020, and the 30" day of September, 2020. , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighteen (18) years, did willfully, unlawfully, and feloniously. ‘obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Kevin Harden without Kevin Harden's authorization with the Intent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Kevin Harden, which unauthorized use of such personal identity information caused the Mississippi Departrnent of Employment Security to electronically transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring, within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, COUNT XX based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 and the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any falseQu 4040-EFP writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Kevin Hardenan an inmate at the Mississippi Department of Corrections, who was not eligible or entitted to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card for Ke' Harden which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT XXI based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the I" day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, secutity or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the ‘grand jury, unemployment benefits purporting to be for the benefit of Kevin Harden an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card for Kevin Harden which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice ‘or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and,COUNT XXII adeaoy oP ‘on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighieen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information ‘of Michael Goodwin without Michael Goodwin's authorization with the intent to unlawfully use such information to fiaudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Michael Goodwin, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi ‘Code Annotated (1972, as amended); and, COUNT XXIII based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the I* day of June, 2020 and the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully ‘made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or ‘made false, fictitious and fraudulent statements or representations, and/or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Michael Goodwin an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card for Michael Goodwin which funds were then accessed and converted to Kenkarell Thomas” use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and,COUNT XxIVv ay aoe - EFF based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise @ scheme or artifice, or for obtaining ‘money, property or services, ot for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, orto sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the ‘grand jury, unemployment benefits purporting to be forthe benefit of Michael Goodwin an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such ‘unemployment benefits, false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card for Michael Goodwin which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and, COUNT XxV ‘on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighteen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Michael Conway without Michael Conway's authorization with the intent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Michael Conway, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $1,334.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended),COUNT XXVI Uf-92-EFP based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1 day of June, 2020 and the 30 day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Michael Conway an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $1324.00 to a Way2Go Visa Debit Card for Michael Conway which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT XXVII based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the {* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Michael Conway an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) wereada - EP relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount ‘of $1,324.00 to a Way2Go Visa Debit Card for Michael Conway which funds were then accessed and converted to Kenkarell Thomas’ use, by ‘means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or ‘other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and, COUNT XXVIII con, about and between the 1** day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being @ male human being above the age of eighteen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Jimmy Davidson without Jimmy Davidson’s authorization with the intent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Jimmy Davidson, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $512.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, COUNT XXIX based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1 day of June, 2020 and the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, ‘To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any false\writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Jimmy Davidson an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $512.00 toa Way2Go Visa Debit Card for Jimmy Davidson which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT XxX based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining ‘money, property ot services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements of representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Jimmy Davidson an inmate at the Mississippi Department of Corrections, who was not cligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $512,00 to a Way2Go Visa Debit Card for Jimmy Davidson which funds were then accessed and converted to Kenkarell Thomas’ use, by ‘means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter ‘across county of state jurisdictional lines for the purpose of defrauding the State of Mississippi, all ‘occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and,COUNT XXxXxI au-4p -eFP on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighteen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Joseph Cook without Joseph Cook’s authorization with the intent {fo unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Joseph Cook, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $1,324.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, COUNT XXXII based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 and the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, ‘unemployment benefits purporting to be for the benefit of Joseph Cook an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $1,324.00 to a Way2Go Visa Debit Card for Joseph Cook which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and,COUNT XXXL ue 224- ep based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1" day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining money, property ot services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Joseph Cook an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $1,324.00 to a Way2Go Visa Debit Card for Joseph Cook which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jusisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972 ‘as amended); and, COUNT XXXIV on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighicen (18) years, did willfully, unlawfully, and feloniously, obiain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Kendrick Crockett without Kendrick Crockett’s authorization ‘with the intent to unlawfully use such information to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Kendrick Crockett, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $512.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and,COUNT XXXV_ dap -EFP based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 2nd the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully ‘made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, or made Or used any false writing or document knowing that the same contined false, fictitious and fraudulent statements or entries, ‘To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any false ‘writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury. unemployment benefits purporting to be for the benefit of Kendrick Crockett an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $512.00 to a Way2Go Visa Debit Card for Kendrick Crockett which funds were then accessed. and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT XXXVI based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, of to sell, dispase of, loan, exchange, alter, give away, distribute, supply, or fumish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting 50 to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements ot representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Kendrick Crockett an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) wereQU-22lo- EP relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $512.00 to a Way2Go Visa Debit Card for Kendrick Crockett which funds were then accessed and converted to Kenkarell Thoms’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted ot caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and, COUNT XXXVI on, about and between the 1 day of June, 2020, and the 30 day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a mate human being above the age of eighteen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Kenneth Dennis without Kenneth Dennis’ authorization with the intent to unlawfully use such information to fraudulently obtain for himself and/or others known ‘and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Kenneth Dennis, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total ‘amount of $106.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code ‘Annotated (1972, as amended); and, COUNT XVIII based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1*' day of June, 2020 and the 30” day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made, falsified, concealed or covered up by trick, scheme or device a material fact or made any false, fictitious and fraudulent statements or representations, ot made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, ‘To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or made false, fictitious and fraudulent statements or representations, and/or made or used any falseUE do- EP writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Kenneth Dennis an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $106.00 to 2 Way2Go Visa Debit Card for Kenneth Dennis which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and, COUNT XXXIX based upon a series of acts connected together and constituting parts of ¢ common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, o furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Kenneth Dennis an inmate at the Mississippi Department of Corrections, who was not cligible or entitled to such ‘unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county or state jurisdictional lines, transfer funds by issuing monies in the total amount of $106.00 to a Way2Go Visa Debit Card for Kenneth Dennis which funds were then accessed and converted to Kenkarell Thomas’ use, by ‘means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other matter across county ot state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and,COUNT XL a4 -dd -EFP ‘on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighteen (18) years, did willfully, unlawfully, and fetoniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Mark Bradford without Mark Bradford's authorization with the intent to unlawfully use such information to fraudulently obtain for himself and/or others known ‘and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Mark Bradford, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total ‘amount of $2,118.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring, within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and, COUNT XLI based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020 and the 30" day of September, 2020, willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi, or any department, agency, office, or other subdivision of the state or local government, knowingly and willfully made. falsified, concealed or covered up by trick, scheme or device @ material fact or made any false, fictitious and fraudulent statements or representations, or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, To-wit: Kenjarell Thomas, while acting in concert and/or aiding, assisting or encouraging another and/or others known and unknown to the grand jury, with the intent to defraud the State of Mississippi, and the Mississippi Department of Employment Security, knowingly and willfully made, falsified, concealed and/or covered up by trick, scheme or device a material fact and/or lade false, fictitious and fraudulent statements or representations, and/or made or used any false writing or document knowing that the same contained false, fictitious and fraudulent statements or entries, to fraudulently obtain for himself and/or others known and unknown to the grand jury, unemployment benefits purporting to be for the benefit of Mark Bradford an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card for Mark Bradford which funds were then accessed and converted to Kenkarell Thomas’ use, all occurring within the jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972, as amended); and,COUNT XLII au-d0le~ EFF based upon a series of acts connected together and constituting parts of a common scheme and plan, said Kenjarell Thomas, being a male human being above the age of eighteen (18) years, did, on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, willfully, unlawfully, and feloniously devised or intended to devise a scheme or artifice, or for obtaining ‘money, property or services, or for securing a business or personal advantage by means of false or fraudulent pretenses, representations or promises, ot to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security ot other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, defrauded or attempted to defraud the Mississippi Department of Employment Security into paying unemployment benefits, by making false, fictitious and fraudulent statements or representations, to fraudulently obtain for himself and/or others known and unknown to the {grand jury, unemployment benefits purporting to be for the benefit of Mark Bradford an inmate at the Mississippi Department of Corrections, who was not eligible or entitled to such unemployment benefits, which false statements and misrepresentation of a material fact(s) were relied upon by the Mississippi Department of Employment Security and caused that Department of the State of Mississippi to electronically, across county of state jurisdictional lines, transfer funds by issuing monies in the total amount of $2,118.00 to a Way2Go Visa Debit Card for Mark Bradford which funds were then accessed and converted to Kenkarell Thomas’ use, by means of a false or fraudulent pretenses, represented or promised, for the purpose of executing such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other means of communication or by person, any writings, signs, signals, pictures, sounds, data, or other mattet across county or state jurisdictional lines for the purpose of defrauding the State of Mississippi, all occurring within the jurisdiction of this court and in violation of Section 97-19-83, Mississippi Code Annotated (1972, ‘as amended); and, COUNT XLII on, about and between the 1* day of June, 2020, and the 30" day of September, 2020, , in the county aforesaid and within the jurisdiction of this Court, the said defendant being a male human being above the age of eighieen (18) years, did willfully, unlawfully, and feloniously, obtain a Mississippi Department of Employment Security Way2Go Visa Debit Card using the personal identity information of Matthew Bailey without Matthew Bailey's authorization with the {ntent to unlawfully use such information to fraudulently obtain for himself and/or others known fand unknown to the grand jury, unemployment benefits purporting to be for the benefit of Matthew Bailey, which unauthorized use of such personal identity information caused the Mississippi Department of Employment Security to electronically transfer funds by issuing monies in the total amount of $106.00 to a Way2Go Visa Debit Card, in furtherance of the illegal act of defrauding the State of Mississippi in violation of Section 97-7-10, Mississippi Code Annotated all occurring within the jurisdiction of this court and in violation of Section 97-45-19, Mississippi Code Annotated (1972, as amended); and,