Case 1:16-cr-00266-WS Document 1 Filed 12/28/16 Page 1 of 6 t( ?s "r4r^ cHB %uo.%^ rN rHE uNrrED srArES DrsrRrcr couRr \ "% i%o^ :::sT::,,:l:GLusw usAo No. ,t v ,s JONATHAN JERNIGAN J * 16R00287 VIOLATION: 18 USC S 1343 INDICTMENT THE GRAND JURY CHARGES: At all times material to this Indictment: 1. From on or about January 2014,to on or about December, 2015, JONATHAN JERNIGAN was a financial specialist for the Children's Medical Group in Mobile, Alabama responsible for managing accounts payable and receivable and maintaining various financial records. JONATHAN JERNIGAN devised and intending to devise a scheme and artifice to defraud Children's Medical Group by obtaining money from Children's Medical Group's corporate purchasing card (PNC Bank Visa Signature Business Option credit card with number ending in2414) "PNC credit card," by means of false and fraudulent pretenses, representations and promises, well knowing atthe time that the pretenses, representations and promises were and would be false when made, did cause to be transmitted in interstate commerce certain signs signals and sounds by means of wire communication, via the internet. 2. JONATHAN JERNIGAN in furtherance of the execution of the above described scheme and attempting to do so, used his company PNC credit/debit card for personal use either as a separate purchase or comingled with acceptable purchases causing a loss to Children's 1 ""-^ Case 1:16-cr-00266-WS Document 1 Filed 12/28/16 Page 2 of 6 Medical Group of approximately $L67,737. COUNT ONE The Grand Jury realleges and incorporates numbered paragraphs 1-2 of this Indictment as if fully set forth herein. From on or about January 2014, to on or about December, 2015, in the Southern District of Alabama, Southern Division, the defendant, JONATHAN JERNIGAN having devised and intending to devise a scheme and artifice to defraud and in furtherance of executing the above described scheme and attempting to do so, knowingly caused to be transmitted by wire interstate commerce, via the internet from Alabama to Pittsburgh, Pennsylvania, a uedit card purchase on Children's Medical Group credit card, wherein on or about September 19,2015, JONATHAN JERNIGAN purchased services in the amount of $8794.03 from Diamond's Men's Club in Mobile, Alabama,thereby causing a loss to Children's Medical Group. In violation of Title 18, United States Code, Section 1343. COUNT TWO The Grand Jury realleges and incorporates numbered paragraphs 1-2 of this Indictment as if fully set forth herein. From on or about January 2014, to on or about December, 2015, in the Southern District of Alabama, Southern Division, the defendant, JONATHAN JERNIGAN having devised and intending to devise a scheme and artifice to defraud and in furtherance of 2 Case 1:16-cr-00266-WS Document 1 Filed 12/28/16 Page 3 of 6 executing the above described scheme and attempting to do so, knowingly cause to be transmitted by wire interstate commerce via the internet from Alabama to Pittsburgh, Pennsylvania a credit card purchase on Children's Medical Group credit card, wherein on or about November 77,2075, JONATHAN JERNIGAN purchased services in the amount of $604.99 from Walmart in Mobile, Alabama, thereby causing a loss to Children's Medical Group. In violation of Title 18, United States Code, Section 1343. COUNT TTIREE The Grand Jury realleges and incorporates numbered paragraphs 1-2 of this Indictment as if fully set forth herein. From on or about January 2014, to on or about December, 2015, in the Southern District of Alabama, Southern Division, the defendant, JONATHAN JERNIGAN having devised and intending to devise a scheme and artifice to defraud and in furtherance of executing the above described scheme and attempting to do so, knowingly cause to be transmitted by wire interstate commerce via the internet from Alabama to Pittsburgh, Pennsylvania a credit card purchase on Children's Medical Group credit card wherein on or about November 29,2015, JONATHAN JERNIGAN purchased services in the amount of $7,570.00 from Diamond's Men's Club in Mobile, Alabama, thereby causing a loss to Children's Medical Group. In violation of Title 18, United States Code, Section 1343. a J Case 1:16-cr-00266-WS Document 1 Filed 12/28/16 Page 4 of 6 COUNT FOUR The Grand Jury realleges and incorporates numbered paragraphs 1-2 of this Indictment as if fully set forth herein. From on or about January 2014, to on or about December, 2015, in the Southem District of Alabama, Southem Division, the defendant, JONATHAN JERNIGAN having devised and intending to devise a scheme and artifice to defraud and in furtherance of executing the above described scheme and attempting to do so, knowingly cause to be transmitted by wire interstate commerce via the internet from Alabama to Pittsburgh, Pennsylvania a credit card purchase on Children's Medical Group credit card wherein on or about November 29,2015, JONATHAN JERNIGAN purchased services in the amount of $3,340.00 from Diamond's Men's Club in Mobile, Alabama, thereby causing a loss to Children's Medical Group. In violation of Title 18, United States Code, Section 1343. COUNT FIVE The Grand Jury realleges and incorporates numbered paragraphs 1-2 of this Indictment as if fully set forth herein. From on or about January 2014, to on or about December, 2015, in the Southern District of Alabama, Southern Division, the defendant, JONATHAN JERNIGAN having devised and intending to devise a scheme and artifice to defraud and in furtherance of 4 Case 1:16-cr-00266-WS Document 1 Filed 12/28/16 Page 5 of 6 executing the above described scheme and attempting to do so, knowingly cause to be transmitted by wire interstate commerce via the internet from Alabama to Pittsburgh, Pennsylvania a credit card purchase on Children's Medical Group credit card wherein on or about November 29,2015, JONATHAN JERNIGAN purchased services in the amount of $1,820.00 from Diamond's Men's Club in Mobile, Alabama, thereby causing a loss to Children's Medical Group. In violation of Title 18, United States Code, Section 1343. F'ORF'EITURE NOTICE The Grand Jury realleges and incorporates numbered paragraphs 1-2 of this Indictment as if fully set forth herein for the purpose of alleging forfeitures pursuant to Title 1 8, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2a6t@). Upon conviction of the offenses set forth in Counts 1-5 of this Indictment, the defendant, JONATHAN JERNIGAN shall forfeit to the United States of America, pursuant to Title 18, United States Code, 981(aXlXC) and Title 28, United States Code, Section 2461(c), any property, real or personal, that constitutes or is derived from proceeds traceable to the offense. If any of the property described above, as a result of any act or omission of the defendant: a. cannot be located uponthe exercise ofdue diligence; b" has been transferred or sold to, or deposited c. has been placed beyond the d. has been substantially diminished in value; or e. has been commingled with, a third party; jurisdiction of the court; with other property which cannot be divided 5 Case 1:16-cr-00266-WS Document 1 Filed 12/28/16 Page 6 of 6 without difficulty, the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 21, United States Code, Section 853@), as incorporated by Title 28, United States Code, Section 2461(c). All pursuant to Title 18, United States Code, Section 981(a)(l)(C) and Title 28, United States Code, Section 2461(c). A TRUE BILL FOREMAN, UNITED STATES GRAND JURY SOUTHERN DISTRICT OF ALABAMA KENYEN R. BROWN UNITED STATES ATTORNEY By: PHER BAUGH ted States Attorney VICKI M. DAVIS Assistant U. S. Attorney Chief, Criminal Division DECEMBER 2016 6 Case 1:16-cr-00266-WS Document 1-1 Filed 12/28/16 Page 1 of 1 4 PENALTY PAGE STYLE OF'CASE: UNITED STATES v. JONATHAN JERNIGAN DEF'ENDANT: JONATHAN JERNIGAN USAO NO: 16R00287 AUSA: Christopher H. Baugh CODE VIOLATION: COUNTS 1 - 5: 18 USC 1343, Wire Fraud PENALTY: COUNTS 1 .5: 20yrs/$250,000/3yrs SRT/$100 SA 7