Case 7:19-cr-00472-LSC-JHE Document 1 Filed 09/05/19 Page 1 of 7 FILED

2019 Sep-05 PM 03:32

U.S. DISTRICT COURT
N.D. OF ALABAMA
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
WESTERN DIVISION
UNITED STATES OF AMERICA )
)
v. ) Case No.:
)
LATANYA HATTER, )
)
Defendant. )

INFORMATION

The United States Attorney charges that:

INTRODUCTION

1. The Social Security Administration (“SSA”), an agency of the United

States Government, administered monetary aid to the public through various

federally funded programs. One program was the Title II Federal Old-Age,

Survivors, and Disability Insurance Benefits Program (“Retirement Benefits”),

which authorized monthly monetary payments to individuals who have reached the

age of 62 and filed an application for benefits (“program beneficiaries”). At times,

Retirement Benefits underpayments occurred when program beneficiaries failed to

receive money owed. SSA policy also required that written notice be sent to the

identified program beneficiary notifying that individual of the reason for the

underpayment. Underpayments could be paid by Automated One-Time Payments

(“AOTPs”) that were entered manually by SSA employees and wired directly to the

United States Department of Treasury for processing.

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2. The Defendant, Latanya Hatter, was employed as a Legal

Administrative Specialist, or “Benefit Authorizer,” at the SSA’s Birmingham,

Alabama, Field Office. As a Benefit Authorizer, Defendant Hatter had access to

program beneficiary accounts and personal identifying information (“PII”).

3. Defendant Hatter’s job duties included making final determinations of

entitlement to benefits and the payments thereof. Defendant Hatter also made

payments to program beneficiaries through the Single Payment System (“SPS”).

4. Defendant Hatter had access to and control over a bank account held in

her name located at AlabamaONE Credit Union, with an account number ending in

912.

COUNT ONE
Wire Fraud
[18 U.S.C. § 1343]

8. The U.S. Attorney adopts and incorporates paragraphs one through four

of the Introduction as if set forth fully herein.

NATURE AND PURPOSE OF THE SCHEME TO DEFRAUD

9. On or about December 5, 2017, in the Northern District of Alabama,

Western Division, and elsewhere, the Defendant,

LATANYA HATTER,

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did knowingly and with intent to defraud, devise, and intend to devise, and attempt

to devise, a scheme and artifice to defraud, and for obtaining money and property by

means of false and fraudulent pretenses, representations, and promises.

THE SCHEME AND ARTIFICE

10. It was part of the scheme to defraud that, beginning in or about

December 2017 and continuing until in or about January 2018, the Defendant,

Latanya Hatter, caused approximately $148,428.00 in Title II Retirement Benefits

to be electronically deposited into Hatter’s account at AlabamaONE Credit Union

and bank accounts belonging to friends and family members.

11. It was further part of the scheme to defraud that Defendant Hatter used

her personalized SSA PIN number to query records of approximately 18 program

beneficiaries and used their PII to create fraudulent AOTPs for unauthorized

underpayments.

12. It was further part of the scheme to defraud that these AOTPs were

electronically transferred from Defendant Hatter’s location in the Northern District

of Alabama to the United States Department of Treasury in Kansas City, Missouri,

for electronic deposit into the bank accounts that Defendant Hatter designated,

including her account at AlabamaONE Credit Union ending in 912 and bank

accounts belonging to friends and family members.

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THE WIRE COMMUNICATION

13. On or about December 5, 2017, having devised and intended to devise

the above-described scheme to defraud, for the purpose of executing and attempting

to execute said scheme to defraud, the Defendant,

LATANYA HATTER,

did transmit and cause to be transmitted by means of wire communications in

interstate commerce, certain signs, signals, and communications, that is, an AOTP

wire transfer in the amount of $5,559 made payable to program beneficiary R. R.,

on behalf of deceased program beneficiary N. R., sent from the Northern District of

Alabama to the state of Missouri, said AOTP to be deposited into Defendant Hatter’s

bank account at AlabamaONE Credit Union ending in 912.

All in violation of Title 18, United States Code, Section 1343 and 2.

COUNT TWO
Conversion of Public Money
[18 U.S.C. § 641]

The allegations of paragraphs one through four are re-alleged as if set forth

fully herein. Beginning on or about December 5, 2017, and continuing until January

31, 2018, in Tuscaloosa County, in the Northern District of Alabama, Western

Division, the Defendant,

LATANYA HATTER,

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did willfully and knowingly receive, retain, embezzle, steal, purloin, convert to her

own use and the use of another, on a recurring basis, money belonging to the United

States and a department and agency thereof, in a total amount greater than $1,000,

namely, Title II SSA Retirement Benefits having a value of approximately $148,428.

All in violation of Title 18, United States Code, Section 641.

COUNT THREE
Identity Theft
[18 U.S.C. § 1028(a)(7)]

The allegations of paragraphs one through seven are re-alleged as if set forth

fully herein. From on or about December 5, 2017, to January 31, 2018, in the

Northern District of Alabama, Western Division, and elsewhere, the Defendant,

LATANYA HATTER,

did knowingly use, transfer, and possess, in or affecting interstate commerce,

without lawful authority, a means of identification of another person, including

names, dates of birth, and social security numbers for 18 SSA program beneficiaries,

with the intent to commit, or in connection with, any unlawful activity that

constitutes a violation of Federal law, to wit, conversion of public money in violation

of Title 18, United States Code, Section 641, as alleged in Count Two of this

Information, and, as a result of this offense, Defendant Hatter obtained money or

property in excess of $1,000 during a one year period, to wit, approximately

$148,428 in AOTPs for unauthorized underpayments.

All in violation of Title 18, United States Code, Section 1028(a)(7).

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NOTICE OF FORFEITURE

1. The allegations of Counts One and Three of this Information are re-

alleged and incorporated by reference as though set forth fully herein for the purpose

of alleging forfeiture to the United States pursuant to the provisions of Title 18,

United States Code, Section 982(a)(2).

2. Pursuant to Rule 32.2(a) of the Federal Rules of Criminal Procedure,

the Defendant,

LATANYA HATTER,

is hereby notified that, upon conviction of the offenses alleged in Counts One and

Three of this Indictment, the Defendant shall forfeit to the United States, under Title

18, United States Code, Section 982(a)(2):

a. any conveyance, including any vessel, vehicle, or aircraft used in

the commission of the offense; and
b. any property, real or personal:
(i) that constitutes, is derived from, or is traceable to the
proceeds obtained directly or indirectly from the
commission of the offense, or
(ii) that was used to facilitate, or was intended to be used to
facilitate, the commission of the offense.

3. If any of the property described above as being forfeitable under Title

18, United States Code, Section 982(a)(2), as a result of any act or omission of the

Defendant:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the Court;

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d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be
divided without difficulty;

it is the intention of the United States, under Title 18, United States Code, Section

982(b), incorporating Title 21, United States Code, Section 853(p), to seek forfeiture

of any other property of the Defendant up to the value of the property described

above.

All pursuant to Title 18, United States Code, Section 982(a)(2).

JAY E. TOWN
United States Attorney

/s/ electronic signature

CATHERINE C. LONG
Assistant United States Attorney