STATE OF MARYLAND, Prince Georges County, to wit:

THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY, IN PRINCE
GEORGES COUNTY, MARYLAND, DID, BETWEEN THE DATES OF AUGUST 10, 2010 AND
JUNE 30, 2015, PURSUANT TO ONE SCHEME AND CONTINUING COURSE OF CONDUCT,
STEAL UNITED STATES CURRENCY AND FOOD ITEMS PROPERTY OF PRINCE GEORGE'S
COUNTY BOARD OF EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS
HAVING A VALUE OF AT LEAST $1,000 BUT LESS THAN $10,000, IN VIOLATION OF
CR-07-104 OF THE CRIMINAL LAW ARTICLE AGAINST THE PEACE, GOVERNMENT AND
DIGNITY OF THE STATE. (THEFT-SCHEME: $1000 TO UNDER $10,000)
COUNT 2
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
10th DAY OF AUGUST, 2010, IN PRINCE GEORGES COUNTY, MARYLAND, DID, IN A SIGNED
APPLICATION, MAKE A FRAUDULENT STATEMENT, WITH THE INTENT TO OBTAIN
MONEY, PROPERTY, AND ASSISTANCE UNDER A PROGRAM BASED ON NEED, FINANCED
IN WHOLE OR IN PART BY THE STATE OF MARYLAND AND ADMINISTERED BY THE
PRINCE GEORGE'S COUNTY BOARD OF EDUCATION D/B/A PRINCE GEORGE'S COUNTY
PUBLIC SCHOOLS, IN VIOLATION OF CR-08-504 OF THE CRIMINAL LAW ARTICLE AGAINST
THE PEACE, GOVERNMENT AND DIGNITY OF THE STATE. (PUBLIC ASSISTANCE - FALSE
APPLICATION)
COUNT 3
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
10th DAY OF AUGUST,

2010, IN PRINCE GEORGES COUNTY, MARYLAND, DID

FRAUDULENTLY OBTAIN A BENEFIT TO WHICH THE PERSON AIDED WAS NOT ENTITLED,
TO WIT: SCHOOL LUNCHES, FROM PRINCE GEORGE'S PUBLIC SCHOOLS SCHOOL LUNCH
PROGRAM A NUTRITIONAL PROGRAM FINANCED IN WHOLE AND IN PART BY THE STATE
OF MARYLAND AND ADMINISTERED BY PRINCE GEORGE'S COUNTY BOARD OF
EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, AND DID SO BY
WILLFULLY MAKING A FALSE STATEMENT TO PRINCE GEORGE'S COUNTY BOARD OF
EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, IN VIOLATION OF
CR-08-503B OF THE CRIMINAL LAW ARTICLE AGAINST THE PEACE, GOVERNMENT AND
DIGNITY OF THE STATE. (FRAUD-WELFARE)

COUNT 4
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
18th DAY OF AUGUST, 2011, IN PRINCE GEORGES COUNTY, MARYLAND, DID, IN A SIGNED
APPLICATION, MAKE A FRAUDULENT STATEMENT, WITH THE INTENT TO OBTAIN
MONEY, PROPERTY AND ASSISTANCE UNDER A PROGRAM BASED ON NEED, FINANCED
IN WHOLE OR IN PART BY THE STATE OF MARYLAND AND ADMINISTERED BY THE
PRINCE GEORGE'S COUNTY BOARD OF EDUCATION D/B/A PRINCE GEORGE'S COUNTY
PUBLIC SCHOOLS, IN VIOLATION OF CR-08-504 OF THE CRIMINAL LAW ARTICLE AGAINST
THE PEACE, GOVERNMENT AND DIGNITY OF THE STATE. (PUBLIC ASSISTANCE - FALSE
APPLICATION)
COUNT 5
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
18th DAY OF AUGUST,

2011, IN PRINCE GEORGES COUNTY, MARYLAND, DID

FRAUDULENTLY OBTAIN A BENEFIT TO WHICH THE PERSON AIDED WAS NOT ENTITLED,
TO WIT: SCHOOL LUNCHES, FROM PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS SCHOOL
LUNCH PROGRAM, A NUTRITIONAL PROGRAM FINANCED IN WHOLE AND IN PART BY
THE STATE OF MARYLAND AND ADMINISTERED BY PRINCE GEORGE'S COUNTY BOARD
OF EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, AND DID SO BY
WILLFULLY MAKING A FALSE STATEMENT TO PRINCE GEORGE'S COUNTY BOARD OF
EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, IN VIOLATION OF
CR-08-503B OF THE CRIMINAL LAW ARTICLE AGAINST THE PEACE, GOVERNMENT AND
DIGNITY OF THE STATE. (FRAUD-WELFARE)

COUNT 6
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
16th DAY OF AUGUST, 2012, IN PRINCE GEORGES COUNTY, MARYLAND, DID, IN A SIGNED
APPLICATION, MAKE A FRAUDULENT STATEMENT, WITH THE INTENT TO OBTAIN
MONEY, PROPERTY, AND ASSISTANCE UNDER A PROGRAM BASED ON NEED, FINANCED
IN WHOLE OR IN PART BY THE STATE OF MARYLAND AND ADMINISTERED BY THE
PRINCE GEORGE'S COUNTY BOARD OF EDUCATION D/B/A PRINCE GEORGE'S COUNTY
PUBLIC SCHOOLS, IN VIOLATION OF CR-08-504 OF THE CRIMINAL LAW ARTICLE AGAINST
THE PEACE, GOVERNMENT AND DIGNITY OF THE STATE. (PUBLIC ASSISTANCE - FALSE
APPLICATION)
COUNT 7
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
16th DAY OF AUGUST,

2012, IN PRINCE GEORGES COUNTY, MARYLAND, DID

FRAUDULENTLY OBTAIN A BENEFIT TO WHICH THE PERSON AIDED WAS NOT ENTITLED,
TO WIT: SCHOOL LUNCHES, FROM PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS SCHOOL
LUNCH PROGRAM, A NUTRITIONAL PROGRAM FINANCED IN WHOLE AND IN PART BY
THE STATE OF MARYLAND AND ADMINISTERED BY PRINCE GEORGE'S COUNTY BOARD
OF EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, AND DID SO BY
WILLFULLY MAKING A FALSE STATEMENT TO PRINCE GEORGE'S COUNTY BOARD OF
EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, IN VIOLATION OF
CR-08-503B OF THE CRIMINAL LAW ARTICLE AGAINST THE PEACE, GOVERNMENT AND
DIGNITY OF THE STATE. (FRAUD-WELFARE)

COUNT 8
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
7th DAY OF OCTOBER, 2013, IN PRINCE GEORGES COUNTY, MARYLAND, DID, IN A
SIGNED APPLICATION, MAKE A FRAUDULENT STATEMENT, WITH THE INTENT TO
OBTAIN MONEY, PROPERTY, AND ASSISTANCE UNDER A PROGRAM BASED ON NEED,
FINANCED IN WHOLE OR IN PART BY THE STATE OF MARYLAND AND ADMINISTERED BY
THE PRINCE GEORGE'S COUNTY BOARD OF EDUCATION D/B/A PRINCE GEORGE'S
COUNTY PUBLIC SCHOOLS, IN VIOLATION OF CR-08-504 OF THE CRIMINAL LAW ARTICLE
AGAINST THE PEACE, GOVERNMENT AND DIGNITY OF THE STATE.

(PUBLIC

ASSISTANCE - FALSE APPLICATION)

COUNT 9
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
7th DAY OF OCTOBER,

2013, IN PRINCE GEORGES COUNTY, MARYLAND, DID

FRAUDULENTLY OBTAIN A BENEFIT TO WHICH THE PERSON AIDED WAS NOT ENTITLED,
TO WIT: SCHOOL LUNCHES, FROM PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS SCHOOL
LUNCH PROGRAM A NUTRITIONAL PROGRAM FINANCED IN WHOLE AND IN PART BY
THE STATE OF MARYLAND AND ADMINISTERED BY PRINCE GEORGE'S COUNTY BOARD
OF EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, AND DID SO BY
WILLFULLY MAKING A FALSE STATEMENT TO PRINCE GEORGE'S COUNTY BOARD OF
EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, IN VIOLATION OF
CR-08-503B OF THE CRIMINAL LAW ARTICLE AGAINST THE PEACE, GOVERNMENT AND
DIGNITY OF THE STATE. (FRAUD-WELFARE)

COUNT 10
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
2nd DAY OF SEPTEMBER, 2014, IN PRINCE GEORGES COUNTY, MARYLAND, DID, IN A
SIGNED APPLICATION, MAKE A FRAUDULENT STATEMENT, WITH THE INTENT TO
OBTAIN MONEY, PROPERTY, AND ASSISTANCE UNDER A PROGRAM BASED ON NEED,
FINANCED IN WHOLE OR IN PART BY THE STATE OF MARYLAND AND ADMINISTERED BY
THE PRINCE GEORGE'S COUNTY BOARD OF EDUCATION D/B/A PRINCE GEORGE'S
COUNTY PUBLIC SCHOOLS, IN VIOLATION OF CR-08-504 OF THE CRIMINAL LAW ARTICLE
AGAINST THE PEACE, GOVERNMENT AND DIGNITY OF THE STATE.

(PUBLIC

ASSISTANCE - FALSE APPLICATION)

COUNT 11
THE GRAND JURORS OF THE STATE OF MARYLAND FOR THE BODY OF PRINCE GEORGES
COUNTY ON THEIR OATH DO PRESENT THAT LYNETTE J. MUNDEY ON OR ABOUT THE
2nd DAY OF SEPTEMBER, 2014, IN PRINCE GEORGES COUNTY, MARYLAND, DID
FRAUDULENTLY OBTAIN A BENEFIT TO WHICH THE PERSON AIDED WAS NOT ENTITLED,
TO WIT: SCHOOL LUNCHES, FROM PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS SCHOOL
LUNCH PROGRAM, A NUTRITIONAL PROGRAM FINANCED IN WHOLE AND IN PART BY
THE STATE OF MARYLAND AND ADMINISTERED BY PRINCE GEORGE'S COUNTY BOARD
OF EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, AND DID SO BY
WILLFULLY MAKING A FALSE STATEMENT TO PRINCE GEORGE'S COUNTY BOARD OF
EDUCATION D/B/A PRINCE GEORGE'S COUNTY PUBLIC SCHOOLS, IN VIOLATION OF
CR-08-503B OF THE CRIMINAL LAW ARTICLE AGAINST THE PEACE, GOVERNMENT AND
DIGNITY OF THE STATE. (FRAUD-WELFARE)

____________________________________
ASSISTANT STATES ATTORNEY FOR
PRINCE GEORGES COUNTY, MARYLAND