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Case 1:07-cr-00274-RJL Document 3 Filed 10/16/2007 Page 1 of 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Holding a Criminal Term

Sworn in on May 11, 2006

UNITED STATES OF AMERICA

Crim. No. 07 -____________

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:
: MAGISTRATE NO. 07-0382M-01 (CR)
:
:
:
:
:
____________________________________:

VIOLATION:
18 U.S.C. § 666(a)(1)(A)
(Obtaining funds by embezzlement from
an organization receiving federal funds)

RENITA FRANKLIN-THROWER,


v.

Defendant.

INDICTMENT

COUNT ONE

The Grand Jury charges that:

A.

Introduction

1.

At all times relevant to this Indictment, the National American Red Cross (Red Cross)

was a corporation with its principal place of business and national headquarters in the District of

Columbia. The principal purposes of the Red Cross were to provide volunteer aid in the time of war

to the sick and wounded of the Armed Forces, and to carry out a system of national and international

relief in the time of peace in order to mitigate the suffering caused by pestilence, famine, fire, floods

and other great national calamities.

2.

At all times relevant to this Indictment, in order to carry out its mission, the Red

Cross ran various programs and provided various services throughout the world and the United

States. Also in order to carry out its mission, including making payments to its employees, staff,

suppliers of goods and services, and contractors, the Red Cross maintained accounts at various banks

and maintained an endowment. In addition to having received donations and grants, the Red Cross

received annually hundreds of thousands of dollars from the Federal Government in the form of

Case 1:07-cr-00274-RJL Document 3 Filed 10/16/2007 Page 2 of 3

grants, programs, contracts, loans and subsidies. At all times relevant to this Indictment, the Red

Cross received in excess of $10,000.00 from the Federal Government in the form of grants.

3.

At all times relevant to this Indictment, the Red Cross maintained a bank account at

JP Morgan Chase Bank (the Payroll Account) that it used to fund its employee wages.



4.

On or about August 4, 2005, defendant RENITA FRANKLIN-THROWER was hired

by the Red Cross to work in the District of Columbia as a Payroll Administrator. As a Payroll

Administrator, defendant RENITA FRANKLIN-THROWER’s responsibilities included: making and

processing payments to various tax authorities for payroll taxes; communicating with a third-party

payroll company called “ADP,” and, when the need arose, processing “manual” checks paid out

directly from the Payroll Account to be issued to employees of the Red Cross.

5.

At all times relevant to this Indictment, all Red Cross employees received their wages

directly from ADP in the form of a paper check or by way of direct deposit. The Red Cross normally

did not pay its employees with checks that were generated within its own payroll office. Manual

payroll checks drawn from the Payroll Account were prepared and issued from the payroll office

only in the event that an employee had not received his payroll check from ADP, had misplaced a

check, or had otherwise not been paid but was due a payroll check.

6.

At all times relevant to this Indictment and in the District of Columbia, the manual

payroll checks maintained by the Red Cross were kept secured and were only accessible by the small

payroll staff and supervisors. One person with such access during all relevant times was defendant

RENITA FRANKLIN-THROWER. These manual payroll checks were prepared and produced in

the payroll office by having a payroll employee “key-in” the relevant information, including the

name of the employee, the date of the check, and the amount of pay the employee was due. Once

this information was keyed-in the check was printed with the authorized signature printed on the face

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Case 1:07-cr-00274-RJL Document 3 Filed 10/16/2007 Page 3 of 3

of the check. As a payroll employee defendant RENITA FRANKLIN-THROWER had the ability

and access to key-in information into the payroll computer to print a payroll check.

B.

Embezzlement Scheme

7.

Beginning on or about August 28, 2006, until on or about January 11, 2007, within

the District of Columbia and elsewhere, defendant RENITA FRANKLIN-THROWER devised a

scheme to embezzle, steal, or obtain by fraud, the money of the Red Cross by using her position in

the payroll department to access and produce manual payroll checks made out to herself to which

she was not entitled. Upon completion of making manual payroll checks to herself, defendant

RENITA FRANKLIN-THROWER would either deposit the money into accounts she owned or

controlled or otherwise would convert the money to her use with neither the knowledge, nor

authority of the Red Cross.

8.

From on or about August 28, 2006, until on or about January 11, 2007, within the

District of Columbia and elsewhere, defendant RENITA FRANKLIN-THROWER executed this

scheme on approximately seven occasions and wrote seven manual payroll checks from the Red

Cross payroll account to herself totaling $28,617.50 to which she was not entitled.

(Obtaining Funds by Embezzlement from an Organization Receiving Federal Funds

in violation of Title 18, United States Code, Sections 666(a)(1)(A)).

Attorney of the United States in
and for the District of Columbia

A TRUE BILL

FOREPERSON

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