Case 5:19-cr-50071-JLV Document 1 Filed 05/21/19 Page 1 of 21 PageID #: 1 UNITED STATES DISTRICT COURT Filed DISTRICT OF SOUTH DAKOTA WESTERN DIVISION MAY 7 1 o ' '2019 CR 6:\q-CK.-5cc5T\ UNITED STATES OF AMERICA, REDACTED INDICTMENT Plaintiff, WIRE FRAUD vs. 18 U.S.C. § 1343 ROBERT RODNEY BLAND, THEFT OF GOVERNMENT PROPERTY Defendant 18 U.S.C. § 641 FORFEITURE The Grand Jury charges: WIRE FRAUD (18 U.S.C. § 1343) Overview of the GSA Fleet Program 1. The General Services Administration (GSA) is responsible for maintaining a fleet of approximately 210,000 vehicles. This includes leasing vehicles to federal agencies as well as providing a mechanism for agencies to fuel and provide necessaiy maintenance and repairs for these vehicles. With the exception of a very limited number of customer agencies who provide their own fuel and maintenance, a majority of GSA customers are under a "rate structure" lease. This means that fuel and maintenance is built into the cost of the lease. 2. GSA contracts with a company named WEX, Inc. (WEX), which provides vehicle leasees and drivers with a credit card that they use to purchase 1 Case 5:19-cr-50071-JLV Document 1 Filed 05/21/19 Page 2 of 21 PageID #: 2 Case 5:19-cr-50071-JLV Document 1 Filed 05/21/19 Page 3 of 21 PageID #: 3 Case 5:19-cr-50071-JLV Document 1 Filed 05/21/19 Page 4 of 21 PageID #: 4 Case 5:19-cr-50071-JLV Document 1 Filed 05/21/19 Page 5 of 21 PageID #: 5 Case 5:19-cr-50071-JLV Document 1 Filed 05/21/19 Page 6 of 21 PageID #: 6 Case Document 1 Filed 05/21/19 Page 7 of 21 PageID 7 17, Between November 29, 2017, and August 7, 2018, a random sampling of 18 vehicles was examined to determine Whether the total number of claimed rock chip repairs was accurate. The total amount that Bland billed for rock chip repairs on these 18 vehicles [after any windshield replacement was done) was approximately $10,400.00, which would have been 416 rock chips at $25 per repair. An inspection of each of these vehicles suggested that out of all of these billings that Bland claimed to have performed repairs on, only approximately 22 repairs had actually been performed. Additionally, on one vehicle (2013 Dodge Grand Caravan, VIN: -- Count 17 below) Bland billed for five repairs that were done after the vehicle's inspection. Bland, therefore, fraudulently billed GSA and was compensated for approximately 389 repairs he had never performed As a result, Bland fraudulently obtained more than $9,500.00 in funds be was not entitled to receive, WIRE FRAUD (18 U.S.C. 1343] 18. All of the allegations set forth in paragraphs 1--17 inclusive are hereby realleged and incorporated by reference as though fully set forth herein, COUNT 1 On or about between March 25, 2011, and December 12, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, - devised the aboveedescx'lbed scheme and artifice to defraud and for obtaining 7 Case Document 1 Filed 05/21/19 Page 8 of 21 PageID 8 money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempu'ng to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire Communications in interstate commerce Writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 24 rock chip repairs he never performed on a 2009 Jeep Grand Cherokee Laredo, Vehicle Identification Number (VIN): -- leased to the Department of Interior [Office of the Special 'l'rustee for American Indians] totaling approximately $600.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds belonged to GSA, all in violation of 18 U.S.C, 1343. COUNT 2 On or about between August 30, 2013, and August 30, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 12 rock chip repairs he never performed 8 Case Document 1 Filed 05/21/19 Page 9 of 21 PageID 9 on a 2013 Ford Focus SE, VIN: --, leased to the Department of Health and Human Services, totaling approidmately $300.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C, 1343' COUNT 3 On or about between May 4, 2014, and September 21, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be u-ansmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 22 rock chip repairs he never performed on a 2013 Ford Focus SE, VIN: -- leased to the Department of Health and Human Services, totaling approximately $550.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds fighn'ully belonged to GSA, all in violation of 18 U.S.C. 1343. Case Document 1 Filed 05/21/19 Page 10 of 21 PageID 10 COUNT 4 On or about between July 17, 2015, and March 6, 2018, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 13 rock chip repairs he never performed on a 2016 Ford Focus SE, VIN: leased to the Department of the Army, totaling approximately $325.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 1343. COUNT 5 On or about between April 4, 2017, and March 16, 2018, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above--described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be 10 Case Document 1 Filed 05/21/19 Page 11 of 21 PageID 11 transmitted by means of Wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 14 rock chip repairs he never performed on a 2016 Dodge Grand Caravan, VIN: -- leased to the Department of the Army, totaling approximately $350.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C. 1343. COUNT 6 On or about between September 16, 2014, and December 28, 2017, in the District of South Dakom and elsewhere, the defendant, Robert Rodney Bland, devised the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempfing to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 69 rock chip repairs he never performed on a 2015 Chevrolet Equinox LT, VIN-- leased to the Department of the Air Force, totaling approximately $1,725.00 and had the payment for those fraudulent repairs deposited into a bank account that he 11 Case Document 1 Flled 05/21/19 Page 12 of 21 PageID 12 controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C. 1343. COUNT 7 On or about between December 27, 2015, and April 6, 2018, in'the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above>>described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of Wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 13 rock chip repairs he never performed on a 2013 Dodge Grand Caravan, VIN: -- leased to the Department of Health and Human Services, totaling approximately $325.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in Violation of 18 1343. COUNT 8 On or about between April 26, 2016, and December 28, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above>>described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations 12 Case Document 1 Filed 05/21/19 Page 13 of 21 PageID 13 and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire Communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 17 rock chip repairs he never performed on a 2013 Chevrolet Equinox LT, VIN-- leased to the Department of the Air Force, totaling approximately $425.00 and had the payment for those fraudulent repairs deposited into a bank account that be controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 use. 1343. COUNT 9 On or about between July 16, 2014, and March 27, 2018, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above--described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 13 rock chip repairs he never performed on a 2014 Dodge Grand Caravan, VIN: leased to the Department of the Army, totaling approximately $325.00 and had the payment 1 3 Case Document 1 Filed 05/21/19 Page 14 of 21 PageID 14 for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C. 1343, COUNT 10 On or about between December 14, 2015, and March 27, 2018, in the District of South Dakom and elsewhere, the defendant, Robert Rodney Bland, devised the aboveedescribed scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for die purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce Writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 12 rock chip repairs he never performed on a 2016 Chevrolet Colorado, VIN: leased to the Department of the Army, totaling approximately $300.00 and had the payment for those fraudulent repairs deposited into a bank account that he connolled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 1343, COUNT 1 1 On or about between January 26, 2016, and December 12, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the aboveedescribed scheme and artifice to defraud and for obtaining 14 Case Document 1 Filed 05/21/19 Page 15 of 21 PagelDJi. 15 money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be nansmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 11 rock chip repairs he never performed on a 201510 School Bus, VIN: -- leased to the Department of Interior [Bureau of Indian Affairs), totaling approzdmately $275.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C. 1343. COUNT 12 On or about between April 9, 2013, and June 9, 2015, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above--described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 17 rock chip repairs he never performed on a 2013 1c School Bus, VIN: leased to the Department of 15 Case Document 1 Flled 05/21/19 Page 16 of 21 PageID 16 Interior [Bureau of Indian Affairs), totaling approximately $42500 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C. 1343. COUNT 13 On or about between May 19, 2015, and March 6, 2018, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 1 1 rock chip repairs he never performed on a 2015 IC School Bus, VIN: -- leased to the Department of Interior (Bureau of Indian Affairs], totaling approximately $275.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C. 1343, COUNT 14 On or about between June 28, 2014, and December 12, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, 16 Case Document 1 Filed 05/21/19 Page 17 of 21 PageID 17 devised the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, represenmtions and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 19 rock chip repairs he never performed on a 2014 IC School Bus, VIN: -- leased to the Department of Interior [Bureau of Indian Affairs], totaling approximately $475.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 USC. 1343. COUNT 15 On or about between November 7, 2013, and March 6, 2018, in the Disn'ict of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above--described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in intersmte commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 31 rock chip repairs he never performed on a 17 Case Document 1 Filed 05/21/19 Page 18 of 21 PageID 18 2013 1C School Bus, VIN: --, leased to the Department of Interior (Bureau of Indian Affairs), totaling approximately $775.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 1343. COUNT 16 On or about between April 16, 2013, and September 21, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the aboveidescribed scheme and artifice to defraud and for obmining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 12 rock chip repairs he never performed on a 2013 10 School Bus, VIN: leased to the Department of Interior [Bureau of Indian Affairs), totaling approximately $300.00 and had the payment for those fraudulent repairs deposited into a bank account that be controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C. 1343' 18 Case Document 1 Filed 05/21/19 Page 19 of 21 PageID 19 COUNT 17 On or about between November 25, 2013, and November 22, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland. devised the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to wit, the defendant, Robert Rodney Bland, did fraudulently bill for approximately 35 rock chip repairs he never performed on a 2013 Dodge Grand Caravan, leased to the Department of Health and Human Services, totaling approximately $875.00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in violation of 18 U.S.C, 1343. COUNT 18 On or about between July 21, 2015, and November 27, 2017, in the District of South Dakota and elsewhere, the defendant, Robert Rodney Bland, devised the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations and promises, and for the purposes of executing such scheme and artifice to defraud and attempting to do so, unlawfully, willfully, and knowingly did cause 19 Case 5.19ecre50071eJLV Document 1 Filed 05/21/19 Page 20 of 21 PageID 20 to be transmitted by means of wire communications in interstate commerce writings, signs, signals and sounds, to Wit, the defendant, Robert Rodney Bland, did fraudulently bill {or approximately 44 rock chip repairs he never performed on a 2015 Chevrolet Equinox, VIN: leased the Army Corp. of Engineers, totaling approximately $1,100i00 and had the payment for those fraudulent repairs deposited into a bank account that he controlled at Black Hills Federal Credit Union, which funds rightfully belonged to GSA, all in Violation of 18 1343. 60mm 19 On or about between March 25, 2011, and April 6, 2018, in the District of South Dakota, the defendant, Robert Rodney Bland, willfully and knowingly did embezzle, steal, purloin, and knowingly convert to his own use money of the General Services Administration, a department and agency of the United States, namely payments made for windshield rock chip repairs which he knew he was not entitled, having a value in excess of $1,000, all in violation of 18 U.S.C. 641. FORFEITURE ALLEGATION AS TO COUNTS 1 THROUGH 18 1. The allegations contained in Counts 1 through 18 of this Indictment/Information are hereby realleged and incorporated by reference for the purpose of alleging forfeitures pursuant to Title 18, United States Code, Section 981(a)(1)(C] and Title 28, United States Code, Section 2461(0). 2. Upon conviction of the offense[s] in violation of Title 18, United 20 Case 5:19-cr-50071-JLV Document 1 Filed 05/21/19 Page 21 of 21 PageID #: 21