FILED

UNITED STATES
c. Ul PM 3 39
DISTRICT OF
. TRlcr COURT
N-12-3 NEW HAVEN, CT.
UNITED STATES OF AMERICA Criminal No. 3:13CR I Y0C.f:JJq
v.
THERESA SUTHERLAND,
GINA MARIE WILSON and
TUW ANDA MCCOLLUM
The Grand Jury charges:
VIOLATIONS:
18 U.S.C. Section 1343 (Wire Fraud)
18 U.S.C. Section 1349 (Conspiracy)
18 U.S.c. Section 1 028A(a))(1) (Aggravated
Identity Theft)
18 U.S.C. Section 2 (Aiding and Abetting)
INDICTMENT
COUNTS ONE through SIX
(18 U.S.c. 1343 - Wire Fraud)
1. At all times relevant to this Indictment, the defendants THERESA SUTHERLAND
("SUTHERLAND") and GINA MARIE WILSON ("WILSON") were employed by Mass Mutual
Financial Group ("Mass Mutual") as claims examiners. At all times relevant to this Indictment,
TUW ANDA MCCOLLUM ("MCCOLLUM") was employed by Mass Mutual as a customer service
representative.
2. As employees of Mass Mutual, SUTHERLAND, WILSON and MCCOLLUM were
entitled to $8,500 in college tuition reimbursement yearly and up to $5,000 reimbursement per child
for the expenses associated with the adoption of a child if they incurred qualifying expenses.
The Scheme and Artifice to Defraud
3. On or about the dates set forth below in the District of COlU1ecticut and elsewhere,
SUTHERLAND, WILSON and MCCOLLUM did knowingly and willfully devise and intend to
Case 3:13-cr-00140-AVC Document 1 Filed 07/24/13 Page 1 of 5
devise, and participate in, a scheme and artifice to defraud and to obtain money and property by
means of materially false and fraudulent pretenses, representations and promises.
Purpose of the Scheme
4. The purpose of the scheme and artifice to defraud was for SUTHERLAND, WILSON
and MCCOLLUM to enrich themselves by converting and stealing money from Mass Mutual by
,lor
electronically submitting fraudulent claims for tuition reimbursement an, adoption expenses that
never occurred and for which they were not entitled.
Manner and Means of the Scheme
The manner and means by which SUTHERLAND, WILSON and MCCOLLUM exploited
their status as employees of Mass Mutual and accomplished the scheme included the following:
5. It was part of the scheme and artifice to defraud that SUTHERLAND, WILSON and
MCCOLLUM submitted fraudulent claims and fraudulent documents for tuition reimbursement to
Mass Mutual for college courses allegedly taken when in fact they had never taken such courses.
6. It was further part of the scheme and artifice to defraud that SUTHERLAND and
WILSON submitted fraudulent claims and fraudulent documents for adoption-related expenses to
Mass Mutual when in fact neither SUTHERLAND nor WILSON had any such adoption-related
expenses.
7. On or about the dates listed below, in the District of Connecticut and elsewhere,
SUTHERLAND, WILSON and MCCOLLUM, for the purpose of executing the aforesaid scheme
and artifice to defraud and to obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, did knowingly transmit and cause to be transmitted, by
means of wire communications in interstate and foreign commerce the writings, signs, signals,
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Case 3:13-cr-00140-AVC Document 1 Filed 07/24/13 Page 2 of 5
pictures, sounds and communications described below for each count, each transmission constituting
a separate count:
I
Count
I
Date
I
Use ofInterstate Wires
1 12116/08

SUTHERLAND's ..eJ,6. submission for adoption
reimbursement expenses allegedly incurred by SUTHERLAND
and sent from Mass Mutual in Connecticut to Springfield,
Massachusetts
2 1/2/09 SUTHERLAND's
Wl't:.e b' .
--.::>"ICl "" su mISSIon for education
reimbursement allegedly incurred by SUTHERLAND and sent
from Mass Mutual III Connecticut to Springfield,
Massachusetts
..
-
3 3/23/09 MCCOLLUM's
b ..
...eUl:a't su mISSIOn for education
reimbursement allegedly incurred by MCCOLLUM and sent
from Mass Mutual III Connecticut to Springfield,
Massachusetts
4 4/3/09 for education reimbursement
allegedly incurred by WILSON and sent from Mass Mutual in
Connecticut to Springfield, Massachusetts
5 12/7/09 WILSON' s submission for adoption reimbursement
expenses allegedly incurred by WILSON and sent from Mass
Mutual in Connecticut to Springfield, Massachusetts
6 1119110 SUTHERLAND's
b' .
em(\! su mISSIOn for adoption
reimbursement expenses allegedly incurred by SUTHERLAND
and sent from Mass Mutual in Connecticut to Springfield,
Massachusetts
All in violation of Title 18, United States Code, Sections 1343 and 2.
COUNT SEVEN
( Conspiracy)
I
8. The allegations contained in paragraphs 1 through 7 are realleged and incorporated
by reference as though fully set forth herein.
9. From approximately 2008 to approximately 2010, the exact dates being unknown to
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Case 3:13-cr-00140-AVC Document 1 Filed 07/24/13 Page 3 of 5
the Grand Jury, in the District of Connecticut and elsewhere, SUTHERLAND, WILSON and
MCCOLLUM did unlawfully, knowingly, and intentionally conspire, combine, confederate, and
agree with each other and others known and unknown to the Grand Jury, to commit an offense
against the United States, namely, to devise and intend to devise a scheme and artifice to defraud,
and to obtain money and property from their employer by means of materially false and fraudulent
pretenses, representations, and promises, and, for the purpose of executing and attempting to execute
the scheme and artifice did knowingly transmit and cause to be transmitted, by means of wire
communications in interstate and foreign commerce, writings, signs, signals, pictures, and sounds,
in violation of Title 18, United States Code, Section 1343.
All in violation of Title 18, United States Code, Section 1349.
TW6,L,...Ve
COUNTS E1 GRT iliJ:Ounb r.o,J J lUlM!:j>./
(18 U.S.C. 1 028A(a)(1) - Aggravated Identity Theft)
10. The allegations contained in paragraphs 1-7 are realleged and incorporated by
reference as though fully set forth herein.
11. On or about the dates listed below, in the District of Connecticut and elsewhere,
SUTHERLAND and WILSON did knowingly transfer, possess and use, without lawful authority,
a means of identification of another person during and in relation to a violation of Title 18, United
States Code, Section 1343, namely, SUTHERLAND and WILSON transferred, possessed, and used,
oor
without lawful authority, the names, social security number birth dates, among other things, of
'"
the following individuals, whose identities are known to the Grand Jury, when submitting fraudulent
adoption reimbursement requests to Mass Mutual, during and in relation to a scheme to commit wire
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Case 3:13-cr-00140-AVC Document 1 Filed 07/24/13 Page 4 of 5
fraud, as set forth above in paragraphs 1-7:
I
Count
I
Date
I Victim
8 12116/08 A.J.T.
9 12116108 T.I.T.
10 1217/09 J.C.M.
11 1217/09 S.D.O.
12 119/10 L.M.K.
All in violation of Title 18, United States Code, Sections 1 048A(a)(1) /tild 1:-e
~
UNITED STATES OF AMERICA
A D : ~ A ( M ATTORNEY
~ P. MORABITO
ASSISTANT UNITED STATES ATTORNEY
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