Case 4:18-mj-70709-MAG Document 6 Filed 05/23/18 Page 1 of 2

1 ALEX G. TSE (CABN 152348)

Acting United States Attorney
2
BARBARA J. VALLIERE (DCBN 439353)
3 Chief, Criminal Division

4 JOSE APOLINAR OLIVERA (CABN 279741)

Assistant United States Attorney
5 1301 Clay Street, Suite 340S
Oakland, California 94612
6 Telephone: (510) 637-3680
FAX: (510) 637-3724
7 E-mail: Jose.olivera@usdoj.gov

8 Attorneys for the United States of America

9 UNITED STATES DISTRICT COURT

10 NORTHERN DISTRICT OF CALIFORNIA

11 OAKLAND DIVISION

12 UNITED STATES OF AMERICA, ) CR 4:18-mj-70709-MAG

)
13 Plaintiff, ) NOTICE OF UNITED STATES’ APPEAL TO THE
) U.S. DISTRICT COURT FOR THE E.D. OF
14 v. ) MICHIGAN OF MAGISTRATE JUDGE RYU’S
) ORDER DENYING DETENTION HEARING AND
15 SONJA EMERY, ) DETENTION OF DEFENDANT, AND RELEASE
a/k/a “SONJA LEE ROBINSON” ) OF DEFENDANT ON BOND WITH CONDITIONS
16 a/k/a “SONJALEE EMERY-ROBINSON” )
a/k/a “SONJALEE EMERY” )
17 )
)
18 Defendant. )
)
19

20 The United States gives notice that it has appealed to the U.S. District Court for the Eastern
21 District of Michigan Magistrate Judge Donna Ryu’s March 22, 2018 Order: (1) denying the United

22 States’ a detention hearing in the above-captioned matter, (2) denying the United States’ motion to

23 detain Defendant, and (3) releasing Defendant on bond with conditions. The U.S. Attorney’s Office for

24 the Eastern District of Michigan and the U.S. Department of Justice, Tax Division, have filed the United

25 States’ appeal with the U.S. District Court for the Eastern District of Michigan as permitted by 18

26 U.S.C. § 3145(a)(1).

27 //

28 //

NOTICE OF APPEAL
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1 Attached is a copy of the United States’ appeal filed with the U.S. District Court for the Eastern

2 District of Michigan.

3 DATED: May 22, 2018

4
/s Jose A. Olivera
5 JOSE A. OLIVERA
Assistant United States Attorneys
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NOTICE OF APPEAL
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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

United States of America,

Plaintiff,
Criminal No. 18-cr-20240
v.
Honorable Laurie J. Michelson

Sonja Emery
a/k/a “Sonja Lee Robinson”
a/k/a “Sonjalee Emery-Robinson”
a/k/a “Sonjalee Emery”,

Defendant.

MOTION AND MEMORANDUM IN SUPPORT OF

DETENTION HEARING AND PRETRIAL DETENTION

The United States of America by and through its attorneys, Matthew Schneider,

United States Attorney, Jeffrey McLellan and Jack Morgan, Trial Attorneys, United States

Department of Justice - Tax Division, hereby submits this Motion and Memorandum in

Support of a Detention Hearing and Pretrial Detention. The defendant, Sonja Emery, poses

a serious risk of flight and danger to the community. As there is no condition or

combination of conditions that will reasonably assure her appearance or the safety of the

community, she should be detained. In the event that the Court is not inclined to hold a

detention hearing, the government requests that additional conditions of release (such as

secured bond, surrender of passport, electronic monitoring, geographic limitations on

travel) be imposed in this case.

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I. HEARING BEFORE MAGISTRATE ON MAY 22, 2018

Emery was arrested today, May 22, 2018, in the Northern District of California.

Upon initially appearing before the magistrate judge in case number 4:18-mj-70709-MAG,

Emery was released on $50,000 unsecured bond. Over the government’s objections, and

despite the fact that the government was prepared for an evidentiary hearing on detention,

Emery was released without a detention hearing even being held. The magistrate judge

found that Emery’s case did not warrant a detention hearing because Emery did not pose a

serious risk of flight.

Because the magistrate judge did not hold a hearing, that court did not hear key

evidence relating to Emery’s risk of flight. Consequently, the government was not able to

rebut a proffer by Emery’s attorney that two outstanding warrants for her arrest were for

some other person. As shown by Special Agent McWhirr’s Affidavit referenced below,

those arrest warrants do, in fact, apply to Emery. Emery’s attorney also proffered that she

is currently receiving cancer treatment in New York. As described below, according to the

government’s investigation, Emery has made similar representations to other courts that

were apparently inaccurate. Accordingly, the government respectfully requests that this

Court review de novo the evidence pertaining to detention.

This court has authority to review the release order at issue. See 18 U.S.C. §

3145(a)(1). Essentially, if the defendant is ordered released “. . . by a person other than a

judge of a court having original jurisdiction over the offense. . .” the attorney for the

government may file a motion for revocation of the release order or amendment of release

conditions with the court of original jurisdiction. See id.

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II. APPLICABLE LEGAL STANDARD

The Bail Reform Act, 18 U.S.C. § 3141 et seq., sets forth the procedures for a district

court to determine whether a defendant should be released or detained pending trial,

sentence, or appeal. Under 18 U.S.C. § 3142(f)(2)(A) the judicial officer shall hold a

detention hearing upon the government’s motion in a case that involves “a serious risk that

such person will flee.” Here, the magistrate judge in the Northern District of California

found that Emery’s case did not warrant a detention hearing under that standard. However,

this Court should overrule that finding and hold a detention hearing in this case because

Emery poses a serious risk of flight.

This Court should hold a detention hearing and find that Emery should be detained.

The “hallmark” of the Bail Reform Act is that an arrestee may be released on bail only

under conditions which will “reasonably assure both the appearance of the person as

required and the safety of any other person and the community.” 18 U.S.C. § 3142(b), (c)).

If a judicial officer finds, pursuant to a pretrial detention hearing, that “no condition or

combination of conditions” will ensure both the defendant’s appearance and the public’s

safety, then the officer “shall” order detention pending trial. See 18 U.S.C. § 3142(e)(1).

In this case, the United States moves for a detention hearing under 18 U.S.C. §

3142(f)(2)(A) on the basis that Emery poses a serious flight risk, and also requests pretrial

detention on the basis of a “serious risk that [the defendant] will flee” because Emery

presents a danger to the community. See id. Detention on the basis of risk of flight requires

the United States to prove by a preponderance of the evidence that no conditions of release

would reasonably assure the defendant’s appearance at trial. See United States v.

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Motamedi, 767 F.2d 1403, 1407 (9th Cir. 1985). By contrast, detention on the basis of

danger to the community must be established by “clear and convincing evidence.” Id. at

1406. The evidence presented should speak to the factors enumerated in 18 U.S.C. §

3142(g), specifically the nature and circumstances of the offenses charged, the weight of

the evidence, the history and characteristics of the defendant, and the nature and seriousness

of the danger to any person or the community posed by the defendant’s release. In

presenting such evidence, the parties are not bound by the formal rules of admissibility, see

18 U.S.C. 3142(f), and evidence may be presented by way of proffer, see United States v.

Salerno, 481 U.S. 739, 743 (1987).

III. BACKGROUND

On April 10, 2018, a grand jury returned a true bill for an indictment against Emery,

charging her with four counts of wire fraud, in violation of 18 U.S.C. § 1341; two counts

of mail fraud, in violation of 18 U.S.C. § 1343; one count of corruptly endeavoring to

obstruct the Internal Revenue Service; and four counts of tax evasion, in violation 26

U.S.C. § 7201. Doc.# 1. The indictment alleges that from 2011 through 2014, Emery

engaged in a scheme to defraud three different employers in three different states by falsely

representing her professional status, educational background, and work experience. Each

of these positions that Emery obtained by her false representations were in the health-care

field and highly remunerated, paying base salaries of over $200,000. The details of

Emery’s alleged fraudulent conduct, as well as the substantial evidence relating to her

outstanding arrest warrants and other relevant conduct are outlined in Special Agent

McWhirr’s affidavit (“the McWhirr Affidavit”)(Exhibit 1 hereto).

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IV. DISCUSSION

A. Risk of Flight

Emery poses a substantial risk of flight that warrants her detention. While the

indictment focuses on Emery’s most recent conduct, as the McWhirr Affidavit establishes,

Emery has a long-established pattern dating back to at least 2006 of obtaining health-care

related employment using false names and work history. This past behavior reveals

Emery’s remarkable ability to obtain employment under false pretenses and her willingness

to use false identities. The government’s investigation has tied Emery to eight different

social security numbers and three different names. McWhirr Aff. at pg. 3. Emery provided

these identities to law enforcement agencies and employers throughout the country,

including in California, Connecticut, Georgia, Louisiana, Michigan, New York, and

Wisconsin. The repeated use of false identities supports detention. United States v. Gentry,

455 F. Supp. 2d 1018, 1033 (D. Az. 2006) (citing the defendant’s proven ability to create

and use false identities and identification documents as part of its basis for pre-trial

detention); United States v. Anderson, 382 F. Supp. 2d (D.C. 2005) (finding “strong

circumstantial evidence of [the defendant’s] clear interest in fleeing the jurisdiction and his

intent to do so” by virtue of his use of aliases and false identities and possession of literature

on how to disguise identity and hide assets).

This is not a case where Emery simply used other people’s names and personal

identifying information in the commission of her frauds. In the execution of her fraud,

Emery repeatedly generated false documents including fake resumes, credit reports, and

background reports to paper her falsities. Id. at pg. 4-5. On these records, she falsely

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claimed to be a registered nurse, to have a Masters in Public Health, and a PhD, among

other accomplishments. Emery provided employers with fake emails purportedly from

references at nationally known businesses, id. at 7, and she sent one of her employers a fax

purportedly from the “IRS” to have a wage levy fraudulently lifted, id. at 7-8. By all

accounts, these false records are convincing. Since 2006, Emery has successfully obtained

employment, including serving as a “Clinical Director” and “Director, Medical Services,”

among other titles, with at least eight different companies and hospitals. The defendant’s

repeated use of and “‘apparent access to false documents’ supports a finding that a

defendant poses a risk of flight.” United States v. Baig, 536 F. App’x 91, 93 (2d Cir. 2013)

(quoting United States v. El–Hage, 213 F.3d 74, 80 (2d Cir. 2000)).

Emery’s creation and use of false records was not confined solely to her employers.

On at least two occasions, Emery was charged with fraud-based offenses and

representations were made to the local district attorneys that Emery suffered from “brain

tumor surgery” and cancer. Id. at 13 and 14. In each instance, the district attorney was told

Emery had suffered a debilitating illness that rendered her unable to stand trial, including

that her surgery had “left her blind, without memory, and physically unable to care for

herself,” and in another instance that her “cognitive state is disoriented and confused. She

is unable to care for herself.” Id. at 113-14. Relying on the representations as to her

disability, one of the district attorneys moved that a nolle prosequi be entered because the

“defendant has recently suffered a brain tumor, surgery for which has left her blind, without

memory, and physically unable to care for herself in any fashion.” Id. at 13. The

government attempted to corroborate the claims of Emery’s illness, and instead found no

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evidence that Emery was diagnosed or received treatment of any kind at the hospitals

referenced in the letters. Id. at 14-15. The documents supplied to the local prosecutors in

these cases were apparent forgeries.1

Ultimately, the theft of others identities and the creation of false identities and

documents are at the heart of Emery’s fraud. She has relied on the same tools to

fraudulently obtain employment and conceal the nearly $2 million in income that she

earned from 2012 to 2017 from the government—income upon which she has paid no

taxes. Emery’s willingness and capability to execute such a fraud over a protracted period

of time combined with the substantial unaccounted-for income that she received from these

employers is precisely why the government has serious concerns about her risk of flight.

Moreover, Emery has continued this pattern in recent years. In 2014, Emery

fraudulently represented her work experience and education credentials to a specialty

recruiter in Massachusetts, which then submitted her as a candidate to Contra Costa

County, California. McWhirr Aff. at pg. 9-10. Emery worked for the county through the

Massachusetts employer until late 2015 when she hired by the county directly as an

independent contractor. The contract, which was signed in December 2015, was to

“provide consultation and technical assistance to the Contra Costa Health Plan” and not to

exceed $384,000. On the contract with the County, Emery was falsely described as a

“registered nurse.”

1
In a similar vein, at today’s hearing before the magistrate judge, Emery’s attorney proffered
that she is currently receiving cancer treatment in New York.

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To the contrary, Emery has perpetuated her fraudulent conduct across the United

States and evidenced a willingness to move to escape justice. This is not merely conjecture.

At present, the government has found four outstanding bench warrants for Emery’s arrest.

The warrants related to offenses that occurred in Georgia and New York, where Emery

failed to appear after being charged with various frauds. What is past is prologue. Emery’s

prior conduct strongly suggest that she poses a substantial flight risk. This is especially true

given that in the present case Emery has been charged with multiple felonies that have 20

year maximum sentences and that she is facing a guideline range of at least 46 to 57

months.2

B. Danger to the Community

Over the past decade, Emery has repeatedly falsified credentials and lied to obtain

lucrative employment with at least eight employers. Emery has executed these frauds,

despite being fired from some employers after her fraud came to light and despite knowing

about an administrative investigation by the IRS. The scope and geographic and temporal

duration of Emery’s fraud speak volumes of her resiliency and ingenuity. It also speaks to

the danger that she poses to the community if she is released. See United States v. Parodi,

No. CR-08-0083 PJH, 2008 WL 683421, at *3 (N.D. Cal. Mar. 7, 2008) (“Propensity to

commit crime generally may constitute a sufficient risk of danger to come within the act.”)

The case law makes clear that economic harm is a viable basis for a claim of danger

to the community. As the Ninth Circuit held in United States v. Reynolds, “danger may, at

2
Includes a fraud loss of over $550,000, which is conservative by the government’s estimate, and
a 2 point sophisticated means enhancement. See U.S.S.G. 2B1.1.

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least in some cases, encompass pecuniary or economic harm.” 956 F.2d 192, 192 (9th Cir.

1992). The Ninth Circuit reiterated this point in United States v. Lindsey, 680 F. App’x 563

(9th Cir. 2017), holding that the district court did not act improperly when it determined

that a defendant, who was found guilty in a trial of wire fraud and aggravated identity theft

in a $2.3 million fraud, posed an economic danger to the community. While the present

case involves a pre-trial posture, and thus the burden is the government’s, the total fraud

losses are analogous, as is the protracted nature of the defendant’s fraudulent conduct,

which the Ninth Circuit found to be sufficient to justify a claim of pecuniary harm.

Moreover, the present case is not one where the defendant would be deterred by the public

nature of the indictment or the charges. See United States v. Menaged, 2017 WL 2556828

(D. Az. 2017) (finding that because the defendant’s scheme had been exposed to the public

that any economic danger was “significantly diminished.”) Emery has not been deterred

by the outstanding warrants for her arrest for fraud. To the contrary, she has continued and

expanded the frauds that she has perpetrated.

The jobs that Emery has repeatedly sought also raise substantial concerns about

Emery’s ongoing danger to the community. As detailed in the McWhirr Affidavit, Emery

has sought and obtained positions as the “Director, Medical Services,” “Per Diem

Administrative Supervisor,” “Clinical Director,” “Senior Vice President” consulting on

revamping Emergency Rooms, and “Interim Chief Clinical Operations Improvement

Officer,” among other jobs. These jobs were with doctor’s offices, hospitals, or consulting

groups that advised hospitals. The government does not presently have evidence that

anyone was physically harmed as a byproduct of Emery taking these positions.

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Nonetheless, if Emery were to flee, consistent with her prior pattern of criminal activity,

she likely would attempt to obtain another health-care related position, which could

endanger patient welfare and pose a danger to the community. See, e.g., United States v.

Redman, 2018 WL 1801894 (7th Cir. 2018) (finding that defendant who claimed fake

medical license and treated patients put patients at risk “both in what he did to treat patients

and what he might have missed because of his lack of training.)”

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V. CONCLUSION

Given the statutory factors described above, and the defendant’s prior behavior,

including her access to and use of other false identities, her fabrication of false records

related to these identities, her apparent willingness to mislead courts and their officers, her

repeated failure to appear for prior fraud offenses, her perpetuation of these health-care

related frauds in multiple states, and her receipt of substantial income from her fraud

conduct, the government believes that Emery poses a serious risk of flight and a danger to

the community.

At this point, the defendant has been released on $50,000 unsecured bond over the

government’s objections in the Northern District of California. Typically the government

would recommend some combination of conditions—whether a bail package or third-party

signatory—to reasonably assure the defendant’s appearance and the safety of the

community. See 18 U.S.C. § 3142(e). In the present case, the government does not believe

that any combination of conditions exists.

The defendant moves frequently. She moved to California as part of her fraudulent

scheme, just as she had previously taken jobs in Michigan, Wisconsin, and Massachusetts.

The serial quality of the defendant’s offenses—her willingness to move to continue

executing the scheme—combined with her ability to find new employment defrauding

medical institutions highlights not only that she is a substantial flight risk but that she

continues to pose a danger to the community. The clearest evidence of this is the

defendant’s prior conduct. The defendant has fled in prior instances when confronted with

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lesser criminal charges and there are presently multiple outstanding warrants for her arrest.

The defendant committed the instant offenses notwithstanding the prior warrants.

In light of Emery’s prior flight, her extensive history of using false identities, and

her substantial fraudulent conduct, the United States respectfully requests that the Court

hold a detention hearing and submits that no condition or combination of conditions can

reasonably assure her presence at trial, and that this Court should therefore order pretrial

detention. In the event that the Court is not inclined to hold a detention hearing, the

government requests that additional conditions of release (such as secured bond, surrender

of passport, electronic monitoring, and geographic limitations on travel) be imposed in this

case.

Respectfully submitted,

Matthew Schneider
United States Attorney

/s/ Jeffrey A. McLellan

Jeffrey A. McLellan
DOJ Trial Attorney
601 D Street NW
Washington, DC 20004
Jeffrey.A.McLellan@usdoj.gov
(202) 514-5150

Dated: May 22, 2018

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CERTIFICATE OF SERVICE

I certify that on May 22, 2018, I electronically filed the foregoing document with

the Clerk of Court using the CM/ECF System, which will send notice of such filing to

registered CM/ECF users on the docket of this case. Attorney Joyce Leavitt will be served

by email at Joyce_Leavitt@fd.org.

By: /s Jeffrey A. McLellan

Jeffrey A. McLellan
Trial Attorney
U.S. Department of Justice, Tax Division
Northern Criminal Enforcement Section
601 D. St., N.W
Washington, DC 20530
(202) 514-5181
Jeffrey.a.mclellan@usdoj.gov

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EXHIBIT1
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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA )

)
v. ) Criminal Case No.
)
SONJA EMERY, ) VIOLATIONS:
a/k/a “SONJA LEE ROBINSON” ) 18 U.S.C. § 1341 – Mail Fraud
a/k/a “SONJALEE EMERY-ROBINSON” ) 18 U.S.C. § 1343 – Wire Fraud
a/k/a “SONJA ROBINSON” ) 26 U.S.C. § 7201 – Tax Evasion
Defendant. ) 26 U.S.C. § 7212 – Corrupt Endeavor
) to Obstruct the IRS
)

DECLARATION IN SUPPORT OF REQUEST FOR DETENTION

I, Matthew S. McWhirr, make the following unsworn declaration pursuant to 28 U.S.C. § 1746:

INTRODUCTION

1. I am a Special Agent with the Treasury Inspector General for Tax Administration

(“TIGTA”), and have been so employed since June 1999. The information in this declaration is

based on my personal knowledge and observations during the course of this investigation,

information conveyed to me by other law enforcement and Government officials, and evidence

obtained during the investigation. The declaration does not contain each and every fact known to

the Government, but rather, it outlines the facts that your affiant believes supports a decision to

detain SONJA EMERY (“EMERY”).

1) BACKGROUND

2. Based on the Government’s investigation, I have learned that EMERY was born on

, 1965, and has the following Social Security Number (“SSN”): XXX-XX-9309.

3. My investigation has revealed that EMERY studied for two semesters (Spring and

Fall of 1984) and earned two credits in Speed Reading at Westchester Community College, but

did not obtain a college degree. To date, my investigation has not discovered any college degrees

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obtained by EMERY. Further, New York University and Emory University have both

affirmatively stated that EMERY did not receive any degrees from their institutions.

4. EMERY claimed to have graduated from the Westchester School of Nursing in

New York; however, a review of that institution’s records disclosed no record of EMERY.

5. My investigation has also not discovered any nursing qualifications obtained by

EMERY. Further Connecticut, Georgia, and New York, have all affirmatively stated that EMERY

is not a registered nurse in their respective states.

2) RISK OF FLIGHT

A. EMERY’s Misrepresentations, Use of Various Identities, and Fabrication of Documents

and Records to Fraudulently Obtain Employment

6. Since as early as 2005, if not earlier, EMERY has fraudulently misrepresented her

identity, academic qualifications, and work experience to induce employment with various

employers in at least seven states. From 2006 to 2017, EMERY fraudulently received

approximately $2,481,724.00 in compensation from these employers. Much of this compensation

was never reported to the Internal Revenue Service (“IRS”), and taxes were never paid.

7. As part of her frauds and as described in greater detail below, EMERY has

fabricated a wide variety of records and documents. These include, as described in greater detail

below, fraudulent resumes, fake credit reports, and fake background reports, among other items.

8. Finally, as part of her fraudulent scheme, EMERY has used multiple identities.

Over the course of the Government’s investigation, the affiant has linked the following aliases,

SSNs, and/or DOBs with EMERY:

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A. EMERY, SONJA LEE

SSN: XXX-XX-9309
SSN: XXX-XX-3742
SSN: XXX-XX-9093
DOB: , 1965
DOB: , 1965
DOB: , 1968
DOB: 1962

B. ROBINSON, SONJA
SSN: XXX-XX-1067

C. ROBINSON, SONJA
SSN: XXX-XX-2901

D. ROBINSON, SONJA
SSN: XXX-XX-9091

E. ROBINSON, SONJA
SSN: XXX-XX-2597

F. TRUPUR, MICHELL
DOB: , 1964

G. ROBINSON, SONJA
SSN: XXX-XX-2904

H. FERNANDEZ-ROBINSON, SONJA
SSN: XXX-XX-1061

9. As summarized above, EMERY first began to provide false information to her

employers as early as 2005. On or about November 1, 2005, EMERY was hired under the name

“Sonja Robinson” as the “Director, Medical Services” for Employer 1, which is headquartered in

White Plains, New York. The position paid approximately $125,000.00. On her employment

application, she listed her SSN as XXX-XX-1067; however, she subsequently provided Employer

1 with a United States Social Security Administration (SSA) card that listed her correct SSN,

XXX-XX-9309.

10. Shortly thereafter, on or about January 16, 2006, EMERY was hired as a “Per Diem

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Administrative Supervisor” with Employer 2, which is headquartered in Stamford, Connecticut.

On her employment application, EMERY listed her name as “Sonja Robinson” and falsely listed

her SSN as XXX-XX-2901. EMERY further falsely claimed on her resume to Employer 2, that in

the State of New York, she was registered as a nurse (“Nurse 1”) with the New York Nursing

License Number: XX4985. EMERY also falsely claimed to Employer 2 that she was a registered

nurse (“Nurse 2”) with the Connecticut Nursing License Number: XX1415 and Connecticut Nurse

Midwife License Number: XX0044.

11. Nurse 1, whose name and New York Nursing License Number were used on the

employment application submitted to Employer 2, was interviewed by TIGTA Special Agents and

she confirmed that she was never employed by, nor did she ever apply for employment with,

Employer 2.

12. Similarly, Nurse 2, whose name and Connecticut Nursing License Number were

also used on the employment application submitted to Employer 2, was interviewed by the affiant

and confirmed that she was never employed by, nor did she ever apply for employment with,

Employer 2.

13. On or about approximately November 21, 2006, EMERY was hired under the name

“Sonja Robinson-Emery” by Employer 3, which is headquartered in Decatur, Georgia. EMERY

provided Employer 3 with two different SSNs on forms she submitted as part of her application.

Employer 3 terminated EMERY’s employment after approximately nine days, due to concerns

over the different SSNs that she had provided.

14. On or about August 10, 2009, Emery was hired under the name “Sonja Robinson-

Emery” by Employer 4, which was located in New York, New York, to serve as their Clinical

Director, a position that paid approximately $135,000.00 annually. In her application for

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employment with Employer 4, EMERY provided a fictitious Equifax Credit Report, which falsely

claimed employment with Emory University as a Nursing Director. EMERY also provided a

fictitious Healthcare Solutions Background Report that falsely claimed degrees from Emory

University and nursing licenses for New York and Georgia, and also falsely claimed that she had

no criminal record. EMERY left the position in approximately December 2010.

15. In approximately April 2011, EMERY applied to be a Senior Vice President with

Employer 5, which, at the time, was headquartered in Ann Arbor, Michigan, consulting for

hospitals revamping their Emergency Rooms.

16. As part of her application package for employment with Employer 5, on or about

April 12, 2011, EMERY submitted or caused to be submitted a resume to Employer 5, wherein

she falsely claimed to be a registered nurse in New York (License Number: XX4985) and a

registered nurse in Georgia (License XXXX6076); she also falsely claimed to possess a Bachelor

of Science in Nursing (“BSN”) degree, a Master in Health Administration (“MHA”) degree and a

Master in Business Administration (“MBA”) degree from New York University (“NYU”).

EMERY later claimed in an electronic mail message (e-mail) that she forwarded to an employee

of Employer 5, that she had earned her BSN, MBA, Master of Health Science (“MHS”), and

Doctor of Philosophy (“Ph.D.”) degrees from Emory University, not NYU. Government

investigators have reviewed the state licensure information for the actual nurses with License

Numbers: XX4985 and XXXX6076. Neither license was granted to EMERY. Furthermore,

government investigators subpoenaed Emory University and NYU; neither Emory University nor

NYU had any record of EMERY ever graduating from, or even attending, their respective

institutions.1

1
As explained above, to the best of the affiant’s knowledge, EMERY never graduated from any
college with any degree.

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17. On the same resume submitted to Employer 5, EMERY also falsely claimed to have

worked from 1984 to 2001, as the “Director of Case Management” and “Director of Emergency

Services” at a major hospital (“Hospital 1”) in Atlanta, Georgia. EMERY further falsely claimed

to have worked from 2001 to 2004, as the “Managing Director – Healthcare” for a major national

accounting firm (“Accounting Firm 1”) in Atlanta, Georgia, and to have worked from 2004 to

2011, as the Vice President of Consulting Services-Healthcare for another major national

accounting firm (“Accounting Firm 2”) in New York, New York.

18. Government investigators subpoenaed Hospital 1, Accounting Firm 1, and

Accounting Firm 2; no record of EMERY ever having been employed at any of these firms was

located.

19. Further, the Government has received records from the State of Georgia and New

York State, which reveal that during the same period that EMERY claimed she was working for

Hospital 1, Accounting Firm 1, and Accounting Firm 2, she was, in fact, claiming to be

unemployed and receiving unemployment benefits.

20. To substantiate her education record and employment record, on or about April 12,

2011, EMERY submitted or caused to be submitted to Employer 5, a false document labeled,

“Healthcare Solution National Background Report.” This report falsely verified that EMERY had

received BSN, MHA, MBA, and Ph.D. degrees from the School of Public Health at Emory

University; that she was a registered nurse in the State of New York (License X4985); that she had

worked for Accounting Firm 1 and Accounting Firm 2. On or about April 12, 2011, EMERY also

submitted, or caused to be submitted, a fictitious document labeled “Equifax Plus Credit Report,”

which falsely confirmed that EMERY had worked for Hospital 1, Accounting Firm 1, and

Accounting Firm 2.

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21. In addition, on or about May 17, 2011, an employee from Employer 5 received an

e-mail purportedly from [Accounting Firm 2].human.resources@inbox.com, entitled “Contractor

Verification.” The body of the e-mail confirmed that “Sonjalee Robinson has been a contractor

with [Accounting Firm 2]-US from 2004-5/2011. Position held was Director-Healthcare Group.”

Accounting Firm 2 verified that this is not a valid e-mail address used by any employee at their

company, and again, that there are no records that EMERY ever worked for Accounting Firm 2.

22. Employer 5 hired EMERY based, in part, on her fraudulent representations

regarding her education and work experience. Employer 5 paid EMERY at least $158,444.00 in

2011, at least $283,891.00 in 2012, at least $261,529.00 in 2013, and at least $38,392.00 in 2014.

23. For the 2011 and 2012 tax years, EMERY claimed on her Employee’s Withholding

Allowance Certificate, commonly known as an IRS Form W-4, which she provided to Employer

5, that she was “Exempt” from tax withholdings. She listed her name as SONJALEE EMERY-

ROBINSON, and her SSN as XXX-XX-9309. Thus, notwithstanding her income, EMERY paid

no taxes in 2011, 2012, 2013, or 2014.

24. On or about July 17, 2013, the IRS provided a notice to Employer 5 regarding its

intent to levy the wages of EMERY for approximately $18,869.58 in unpaid taxes, relating to the

2005 and 2007 tax years. Employer 5 apprised EMERY of the levy, and following this, on or

about, August 14, 2013, Employer 5 received a fictitious document, purporting to be a facsimile

(fax) from the IRS with the subject, “Levy Release and Settlement.” The fabricated fax further

included a Notice of Levy on Wages, Salary, and Other Income, again purportedly from the IRS,

claiming that the levy amount had been reduced to $558.68. The IRS has no record of sending the

fax, nor any record indicating that the levy was released, reduced, or paid in full.

25. The fraudulent fax received by Employer 5 was sent from the number (609) XXX-

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7045. This is not a number associated with the IRS. My investigation has revealed that (609) XXX-

7045 is a fax number provided by j2 Global, Incorporated (“j2”), which is a company that provides

efaxes, enabling customers to send “faxes” from online accounts. The account associated with

(609) XXX-7045 was created on or about August 14, 2013, which is the same day the fax was sent

to Employer 4. The “Bill To” address provided to j2 was “Internal Revenue Service,” XXX Bronx

River Road, Apartment LM, Yonkers, New York 10704. There is no IRS office at this address,

and our investigation had previously associated this address with EMERY. Additionally, the j2

account was paid using a MasterCard credit card in the name of PATRICK ROBINSON, the last

four digits of which were 7889; PATRICK ROBINSON is the name of both EMERY’s son and

her ex-husband.

26. The affiant has interviewed EMERY’s son and ex-husband, and both advised that

they never authorized EMERY to use a credit or debit card in their names to open an account with

j2; they also both affirmed that they were not familiar with the MasterCard used to open the j2

account.

27. On or about August 14, 2013, Employer 5 forwarded an e-mail to EMERY stating

that Employer 5 had a received a fax, purportedly from the IRS, which identified a new levy

amount of $558.68. Employer 5 stated that the entire amount could be satisfied with EMERY’s

next paycheck. EMERY falsely replied that she had already paid $558.68 by check and provided

an image of a check from Bank 1 for $558.68 to the IRS. Believing that the levy had been satisfied,

Employer 5 replied, “OK Thanks. They get no more.” The affiant subsequently investigated this

claim and determined that no payment in the amount of $558.68 was ever received by the IRS.

The affiant has also reviewed records for EMERY’s account with Bank 1. A cashier’s check in the

amount of $558.68, made payable to the IRS was issued on August 22, 2013. This same check was

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redeposited into EMERY’s bank account on September 5, 2013.

28. On or about March 2014, EMERY was hired under the name “Sonjalee Robinson”

by Employer 6, which is a major hospital in Wisconsin, to serve as the Interim Chief Clinical

Operations Improvement Officer. EMERY was employed in this capacity for only several months,

during which she earned approximately $267,000.00. In her resume provided to Employer 6,

EMERY again falsely claimed to have a Nursing degree from New York, and BSN, MHA, MBA,

and Ph.D. degrees from Emory University. She also falsely claimed to have “more than 25 years

of experience in a variety of healthcare positions,” including serving as a “vice president of

emergency services, director of emergency services, director of case management, CNO [Chief

Nursing Officer], COO [Chief Operating Officer], and nursing director-at a large healthcare

system.” Employer 6 terminated EMERY when her criminal history, true work experience, and

educational background were revealed. Notwithstanding the $267,000.00 that she received from

Employer 6, EMERY neither reported to the IRS nor paid taxes on this income.

29. In or about November 2014, EMERY was hired under the name “Sonja Robinson”

by Employer 7, which is a specialist medical placement company located in Massachusetts.

Employer 8, which is a county in California, hired EMERY through Employer 7 to serve as a

hospital consultant. Employer 7 paid EMERY approximately $16,800.00 for her limited work in

2014, and approximately $209,850.00 for her work in 2015. In her resume provided to Employer

7, EMERY again falsely claimed to have a Nursing degree from New York, and BSN, MHA,

MBA, and Ph.D. degrees from Emory University. She also falsely claimed to have worked in

various positions, including senior-level positions, from 1983 through 2014, for Hospital 1 and

Hospital 2, which was purportedly health and hospital corporation located in New York. Again,

Hospital 1 and Hospital 2 have no record of EMERY ever working for their institutions.

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30. On or about November 17, 2014, on her IRS Forms W-9, Request for Taxpayer

Identification Number and Certification (“Form W-9”), provided to Employer 7, EMERY listed

her name as “Sonja Robinson,” and provided the following SSN: XXX-XX-1061. After being

informed by the IRS that this name and SSN did not match, Employer 7 informed EMERY of the

discrepancy. On or about October 28, 2015, EMERY submitted a revised, but still false, Form W-

9; this time claiming that her name was “Sonja Fernandez-Robinson,” with the same SSN. Shortly

thereafter, EMERY left Employer 7 and began to work directly for Employer 8 in California.

31. EMERY is currently employed by Employer 8 under false pretenses and

credentials. She earns approximately $384,000.00 per year, and has not paid taxes on this income.

B. Emery’s Prior Criminal History, Misrepresentations to Law Enforcement, and

Outstanding Arrest Warrants

32. EMERY (under the name SONJA ROBINSON) has three active Failure to Appear

Bench Warrants in Fulton County, Georgia. One of the warrants pertains to a Theft By Taking

charge, and the other two pertain to a Theft By Deception charge. The investigation associated

with one of the warrants pertains to a Theft By Taking charge (Clerk Number: 03SC09876), and

is described in Paragraph 36. The investigation associated with the other two active warrants

pertains to a Theft By Deception charge (Clerk Number: 04SC12291), and are described in

Paragraphs 38 and 39.

33. EMERY (under the name SONJA ROBINSON) currently has an active Arrest

Warrant in New Rochelle, New York. The investigation associated with the warrant (Court Docket

Number: 08-2297) pertains to a Petit Larceny charge, and is described in Paragraph 50.

34. On at least two prior occasions, as described in paragraphs 42 to 44 and 45 to 496,

EMERY was charged with fraud offenses and the local district attorneys’ office subsequently

received information claiming that EMERY suffered from serious health conditions. As described

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below, some of the documentation alleging EMERY’s health conditions appear to be false.

i. Biloxi, Mississippi

35. On January 26 1998, the Biloxi, Mississippi Police Department (“BPD”) arrested

EMERY for False Pretense / Bad Check. She was identified as a Nurse at the “Dekab [sic] Medical

ceNter [sic]” in Atlanta, Georgia. The following SSNs were listed on the BPD “OFFENSE FORM

II” as being associated with EMERY: XXX-XX-9309; XXX-XX-3742; and XXX-XX-9093. A

review of the BPD Custody Form and Fingerprint Card, however, disclosed that EMERY’s SSN

was listed as XXX-XX-9091. EMERY’s correct Social Security Number is SSN: XXX-XX-9309.

A review of the IRS tax database disclosed that SSN: XXX-XX-9091 is assigned to an individual

who resides in Albany, New York, whose DOB was identified as , 1976. Neither SSN:

XXX-XX-3742, nor SSN: XXX-XX-9093, are assigned to anyone.

ii. Fulton County, Georgia

36. On October 24, 2003, “SONJA ROBINSON” was indicted by a Grand Jury in

Fulton County, Georgia, for a Theft By Taking charge. A review of the Fulton County, Georgia

Police Department (“FCPD”) Incident Report disclosed that between January 31, 2003, and

August 20, 2003, ROBINSON allegedly converted $20,000.00 that her business partner provided

to her.

37. On January 30, 2018, Sharon N. White, “Court Support Supervisor I”, Fulton

County, Georgia Clerk of Superior Court, advised that the Failure to Appear Bench Warrant in the

name of SONJA ROBINSON, dated October 12, 2006, which pertained to the investigation

described in Paragraph 36, was active. A review of the associated case file, which was provided

by Assistant District Attorney Arthur Walton, Fulton County District Attorney’s Office, disclosed

multiple booking photographs of an individual identified as SONJA ROBINSON, DOB:

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, 1965. The individual depicted in these photographs was identified by the affiant as

EMERY.

38. On November 8, 2003, an individual (“Victim 1”) alleged to the Roswell, Georgia

Police Department (“RPD”) that he had met with SONJA LEE EMERY about renting his

townhouse and subsequently been defrauded of approximately $1,000. Victim 1 advised that when

he met with EMERY, “she was wearing a nurse/doctor outfit and a stethoscope around her neck

and said she was an OBGYN [Obstetrician/Gynecologist]. She went on to say her husband and she

were here in town due to his working at IBM and that the rent would come straight from IBM and

had [Victim 1] sign some paperwork to that effect.”

39. On November 25, 2003, RPD obtained an Arrest Warrant for “SONJA

ROBINSON” for Theft By Deception. Later that date, EMERY was arrested as she was about to

pick up her son, PATRICK T. ROBINSON, from school. EMERY instructed PATRICK T.

ROBINSON to retrieve his backpack from the vehicle, which was about to be towed. As he was

about to do so, the RPD detective stopped PATRICK T. ROBINSON, as the detective had not

observed him with a backpack when he exited the school. The RPD Detective determined that the

bag belonged to EMERY, not her son. A search of the aforementioned backpack in EMERY’s

presence revealed “Two driver’s licenses, with different dated of births [sic] and different license

numbers.”

40. On January 30, 2018, Sharon N. White, “Court Support Supervisor I”, Fulton

County, Georgia Clerk of Superior Court, advised that the two Failure to Appear Bench Warrants,

both of which are in the name of SONJA ROBINSON and pertain to the investigation described

in Paragraphs 38 and 39, were active. The first warrant was dated September 1, 2004, and the

second warrant was dated October 12, 2006.

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41. Lead Fingerprint Specialist (LFS) Mack Brazelle from the TIGTA Forensic and

Digital Science Laboratory compared one of the fingerprint cards associated with the investigation

described in Paragraph 36 (and the related active Failure to Appear Bench Warrant in the name of

SONJA ROBINSON), with the fingerprint card associated with the investigation described in

Paragraphs 38 and 39 (and the two related active Failure to Appear Bench Warrants, also in the

name of SONJA ROBINSON). LFS BRAZELLE confirmed that the same source provided both

sets of fingerprints. As stated in Paragraph 37, the individual depicted in the photographs

associated with the investigation described in Paragraph 36 was identified by the affiant as

EMERY.

iii. Gwinnett County, Georgia

42. On January 5, 2004, an Arrest Warrant was issued by the Gwinnett County, Georgia

Magistrate Court for “ROBINSON, SONJA LEE;” the charge was identified as Theft By Taking,

relating to an investment fraud scheme in which EMERY allegedly defrauded a victim of

approximately $6,800.00. The Arrest Warrant listed “SONJA EMERY” and SONJA LEE

EMERY” as aliases for “ROBINSON.” On January 15, 2004, EMERY was arrested by the

Suwanee, Georgia Police Department (“SPD”); her SSN was listed on the SPD Offense / Incident

Report as XXX-XX-9091. The individual depicted in the photograph associated with the Arrest

Report is EMERY. As stated in Paragraph 35, a review of the IRS tax database disclosed that SSN:

XXX-XX-9091, is assigned to an individual who resides in Albany, New York, whose DOB was

identified as , 1976.

43. On November 8, 2004, a Bench Warrant was issued for EMERY (identified therein

as “Sonja Lee Robinson”) for failing to appear for her Arraignment on that date (November 8,

2004). Following this, on May 4, 2005, the Gwinnett County, Georgia Sheriff’s Department

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forwarded, via fax, a letter to Assistant District Attorney Don Geary, Gwinnett County. The fax

included a handwritten letter, dated May 4, 2005, from Prison Health Services, Incorporated,

which was addressed to Hogan. The letter, which was purportedly signed and provided by a doctor

whose signature was illegible, stated, in part: “This letter is regarding inmate Sonja Robinson

#99177640. This Lady had a Brain tumor surgery done a few months ago in New York (most

likely cause of violation of probation – she was in the Hospital for an extended period of time).

Surgery has Left her with no vision, dysbalance [sic] and memory Loss. She is unable to care for

herself and needs twenty four hour care and supervision.”

44. On the basis of the letter, the Assistant District Attorney moved that a nolle

prosequi be entered because the “defendant has recently suffered a brain tumor, surgery for which

has left her blind, without memory, and physically unable to care for herself in any fashion.” On

May 4, 2005, the local judge ordered that a nolle prosequi be entered.

iv. Cherokee County, Georgia

45. On September 20, 2005, EMERY was charged with Deposit Account Fraud in

Canton, Georgia, relating to a false check. In a letter addressed to the Cherokee County, Georgia

“Solicitor Offices,” supposedly from the “New York Cancer Center,” dated July 18, 2005, “Laura

Wartburg, M.D. [Doctor of Medicine],” wrote:

Mrs. Sonja Robinson is under my care for reoccurring Pineal Parenchyma Cancer.
As of May 2005, she stop [sic] responding to treatment and has taken a turn for the
worse. All treatment at St. Joseph’s Hospital in Atlanta was discontinued and Mrs.
Robinson was referred to MSKCC [Memorial Sloan Kettering Cancer Center] for
advance External-Bean Radiation Therapy and Chemotherapy . . . Her current
prognosis is very poor. Her cognitive state is disorientated and confused. She is
unable to care for herself and is currently receiving custodial care by her family.
We are requesting that Mrs. Robinson [sic] court date be postpone [sic] until she
has completed treatment or when her cognitive state improves.

The case was closed on October 18, 2005, when EMERY’s cash bond was applied to her fine and

restitution to her victim following her non-appearance after the case was called in open court.

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46. Attempts made to identify anyone by the name of LAURA WARTBURG via

Internet research, Consolidated Lead Evaluation and Reporting (CLEAR) Database research, and

IRS Integrated Data Retrieval System (IDRS) research, were unsuccessful.

47. In response to a Grand Jury Subpoena, Saint Joseph’s Hospital in Atlanta, Georgia,

advised that it had “conducted a diligent search of Emory Saint Joseph’s Hospital patient record

database and have not found any records” for SONJA EMERY, SONJA ROBINSON, or

SONJALEE EMERY ROBINSON or for the following SSNs: XXX-XX-9309, XXX-XX-2901;

XXX-XX-2904, XXX-XX-2597, XXX-XX-1067, XXX-X5-9091, XXX-X8-9091.

48. In response to a Grand Jury Subpoena, Memorial Sloan-Kettering Cancer Center

advised that SONJA EMERY, also known as SONJA ROBINSON, and SONJA EMERY

ROBINSON, SSNs: XXX-XX-9309; XXX-XX-2901; XXX-XX-2904; XXX-XX-2597; XXX-

XX-1067; XXX-X5-9091; and XXX-X8-9091; “was never a registered patient at Memorial Sloan

Kettering Cancer Center.”

49. In response to a Grand Jury Subpoena, New York University (“NYU”) Langone

Laura and Isaac Perlmutter Cancer Center advised “that a thorough search of the records

maintained by the Perlmutter Cancer Center’s Health Information Management Department,

carried out under my direction and control, revealed no records” pertaining to SONJA EMERY,

also known as SONJA ROBINSON and SONJALEE EMERY ROBINSON, SSNs: XXX-XX-

9309; XXX-XX-2901; XXX-XX-2904; XXX-XX-2597; XXX-XX-1067; XXX-X5-9091; and

XXX-X8-9091.

v. New Rochelle, New York

50. On September 4, 2008, Police Officer MARION, New Rochelle, New York Police

Department (“NRPD”) met with an individual (“Victim 2”), who reported that he had an ongoing

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dispute with his tenant, identified as SONJALEE EMERY and SONJA ROBINSON, regarding

the payment of rent. Victim 2 reportedly received a rent check from EMERY in the amount of

$1,600.00, which could not be negotiated due to insufficient funds. After unsuccessfully

attempting to telephonically contact her, Victim 2 contacted her alleged employer, IBM, but was

told that there was no record of an employee by the name of EMERY.

51. On or about January 17, 2018, the affiant received a copy of the Arrest Warrant in

the name of SONJA ROBINSON, DOB: 1965, Address: Bronx River Road,

Yonkers, New York, from the NRPD. The affiant confirmed that the warrant, which pertains to

the investigation described in Paragraph 50 and is dated December 19, 2008, was active.

52. On June 19, 2013, in Tunica County, Mississippi, EMERY (identified as

ROBINSON) pled guilty and paid fines in two separate cases involving bad checks.

CONCLUSION

I declare under the penalty of perjury the foregoing is true and correct to the best of my knowledge.

Executed on the 17th day of May, 2018.

Respectfully submitted,

________________________
Matthew S. McWhirr
Special Agent
Treasury Inspector General for Tax Administration

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