Case 1:19-cr-10013-CBK Document 33 Filed 08/07/19 Page 1 of 4 PageID #: 79

UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH DAKOTA
NORTHER DIVISION

cR 19-10013

UNITED STATES OF AMERICA,
Plaintiff,

FACTUAL BASIS STATEMENT
VS

CANDACE CROW GHOST,

Defendant

The Defendant states that the following facts are true, and the parties
agree that they establish a factual basis for the offense(s) to which the Defendant

is pleading guilty pursuant to Fed. R. Crim. P. 11(bX3).
On or about between t}:,e 21st day of December,2016, and the 27th day of

March, 2Ol7 , in Corson Count5r, in the District of South Dakota, Candace Crow
Ghost, being an employee of the Grand River Casino, a gaming establishment
operated by and for and licensed by an Indian tribe pursuant to an ordinance

and resolution approved by the National Indian Gaming Commission, did
ernbezzle, abstract, purloin, willfully misapply, and take and carry away with

intent to steal moneys, funds, assets, and other property of said casino, in excess
of $ 1,000, in violation of 18 U.S.C. S 1 16S(b).

On October 4, 2016, Candace Crow Ghost, the Defendant, was hired as
the Marketing Director for the Grand River Casino, located on the Standing Rock
Sioux Indian Reservation. As part of her duties/authority, the Defendant had
1

 Case 1:19-cr-10013-CBK Document 33 Filed 08/07/19 Page 2 of 4 PageID #: 80

the ability to adjust "points" on individual players club rewards cards. The
points carried a cash value, allowing players to redeem points at the rate of 100
points per dollar.
The Defendant began purchasing prescription pain pills from numerous
people within the

first few months of her employment. The Defendant would

pay for the pills she received by using her positional authority at the casino to

adjust the player points balance on the individuals'players club reward cards
and then issue them vouchers to redeem the points for cash. The scheme was
discovered and the Defendant was terminated from her position

in March of

2017.
The casino developed a list of suspicious transactions and compiled a list

of 10 individuals who were ultimately banned from the casino based upon the
Defendant's actions of inappropriately adjusting their players' club

points. In

the short time that she worked at the casino, the Defendant improperly added
426,000 points to various player accounts, costing the casino $4,260. In
addition, the Defendant comped another $1,040.83 in rooms and meals. The
people identified by the casino as receiving improper benefits are:
NAME
M. M., Jr
K. C. N.

POINTS
133,000

Q.B.
J. R.

49,000
20,000
8,000
16,000
30,000
3,000

O.

E. R., Sr
H. M., Sr.

C.C
Y.

S.

l47,OOO

VALUE
$ 1,330
$ 1,470
$4eo
$zoo
$so

COMPS
$ 102.60
$413.41

TOTAL
$ 1,432.50
$ t,88s.+ 1

$tsz.t+

$o+z.t+

$zos.oz
$zs.+s

$408.67

$too

$
$

$soo
$so
2

t+.zs
tz.ss
$z.zs

tos.+s
$tz+.zs
$s tz.qs
$sz.zs
$

 Case 1:19-cr-10013-CBK Document 33 Filed 08/07/19 Page 3 of 4 PageID #: 81

M. Y.

R.O.F
G.C.G
TOTALS

9,000
1 1,000

$qo

N/A

$tto

N/A
N/A

N/A

$so. t t

$+,260

$t,o+0.83

426,OOO

$go

$t to

$so. t t

$s,soo.gg

The Defendant was interviewed by the FBI and admitted to adjusting the
player points, as listed in the above table, in order to purchase prescription pain

pills.

The Defendant paid various people $25 for a 10 mg pill of Oxycodone, $ 15

for a 10 mg pill of Hydrocodone, and $10 for a 5 mg pill of Hydrocodone. When

"customers" would come

to the casino with pills, they would

Defendant and she would meet them on the casino

message the

floor. The Defendant would

direct her "customers" to an area without cameras for the pill exchange. Once
she received the pills, the Defendant would then go to the player's club window,

adjust the points on that patron's rewards card, prepare a voucher redeeming
the points for cash, and finally bring them to the cashier's window to redeem the
voucher.
The Defendant acknowledges that she did not have authorization to adjust

player points for pills, and knew she was converting casino monies to her own
use and/or for her own benefit. The Defendant further acknowledges that the

Grand River Casino is a duly authorized gaming establishment on Indian land,
of which she was an officer or employee during all relevant times.

J

 Case Document 33 Fxled 08/07/19 Page 4 of4 PageID 82

RONALD A. PARSONS, JR.
United States Auomcy


7 7&102 l/Zt' 

Troy .Morl: 
Assistant nited States Auorncv

   
  

z) ~7 1/ 7 @1242 

 

Date Candace Crow GhosL
Defendant
r, I 

Dam Randall Turner

Anomey for Defendant