Date: May 19, 2022 Contact: firstname.lastname@example.org Pittsburgh, PA — Two residents of Texas and a resident of Tennessee pleaded guilty in federal court this week for their roles in defrauding federally funded meal programs, United States Attorney Cindy K. Chung announced today. Charles Simpson and Paige Jackson, both of Dallas, Texas, as well as Tanisha Jackson of Memphis, Tennessee, pleaded guilty to conspiracy to commit mail and wire fraud before United States District Judge Arthur J. Schwab. Simpson and Tanisha Jackson also pleaded guilty to conspiracy to commit money laundering. During Simpson's, Tanisha Jackson's, and Paige Jackson's plea hearings on May 18 and 19, 2022, the defendants admitted, among other things, that they controlled and operated HOIN, Inc. (HOIN), a Texas-based non-profit organization. The defendants caused HOIN (a/k/a"Helping Others In Need) to enroll as a "sponsor" in two programs funded by the United States Department of Agriculture (USDA) for the purpose of providing meals to underprivileged youth—the Child and Adult Care Feeding Program (CACFP) and the Summer Food Service Program (SFSP) (collectively, the feeding programs). CACFP funded after-school meal service during the school year, while SFSP operated in the summer months. In Pennsylvania, the Pennsylvania Department of Education (PADOE) administered the USDA-funded feeding programs. Each defendant further admitted having previously been excluded from participating in the feeding programs in other states. As part of the conspiracy, Simpson and Tanisha Jackson caused the submission of false enrollment documentation to PADOE on behalf of HOIN in connection with its participation in CACFP and SFSP between 2015 and 2019. Among other misrepresentations, HOIN's applications to PADOE used aliases for Simpson and Tanisha Jackson as a means to obscure their involvement and falsely certified that none of its principals had been excluded from the feeding programs. The defendants further admitted causing HOIN to submit reimbursement claims for hundreds of thousands of meals that were never served to eligible children by either inflating the number of meals that, in fact, were served, or by seeking reimbursements for meals purportedly served on days on which the identified feeding site was not operating at all. To conceal their fraudulent conduct and justify HOIN's claimed meal service, Simpson and Tanisha Jackson admitted submitting fabricated documents to PADOE in connection with periodic program reviews, and Tanisha Jackson admitted that on certain occasions she would impersonate Paige Jackson, her daughter, in interactions with PADOE. Likewise, Paige Jackson admitted that she used a fictitious name in dealings with PADOE. In total, PADOE issued reimbursement payments to HOIN in excess of approximately $4 million between 2015 and 2019. In connection with the money laundering conspiracy, Simpson and Tanisha Jackson also admitted engaging in numerous financial transactions involving the proceeds of the fraud. Specifically, Simpson and Tanisha Jackson admitted spending hundreds of thousands of dollars in HOIN reimbursements on shopping sprees at high-end apparel stores, personal air travel and lodging, and the acquisition of at least nine luxury vehicles, including a Bentley, two Land Rovers, two Maseratis, two Mercedes, a Hummer, and a Porsche. Simpson and Tanisha Jackson also withdrew cash from HOIN bank accounts in excess of $10,000 on more than a dozen occasions. In connection with their guilty pleas, Simpson and Tanisha Jackson have agreed to pay restitution to USDA totaling $1,500,000, and Paige Jackson has agreed to pay restitution of approximately $190,000. Simpson and Tanisha Jackson have each also agreed to forfeit approximately $427,000. Conspiracy to commit mail and wire fraud carries a maximum term of imprisonment of twenty years and a fine not more than the greater of $250,000 or an alternative fine in an amount not more than the greater of twice the gross pecuniary gain to any person or twice the pecuniary loss to any person other than the defendant. Likewise, the money laundering conspiracy carries a maximum term of imprisonment of ten years and a fine of not more than $250,000 or an alternative fine of not more than twice the amount of the criminally derived property involved in the relevant transactions. Under the Federal Sentencing Guidelines, the actual sentence imposed would be based upon the seriousness of the offenses and the prior criminal history, if any, of the defendants. Assistant United States Attorneys Eric G. Olshan and Nicole Vasquez Schmitt are prosecuting this case on behalf of the government. The Internal Revenue Service – Criminal Investigation, United States Department of Agriculture – Office of Inspector General, and Federal Bureau of Investigation conducted the investigation of the defendants in this case.