Including goods and services, from life insurers operating ...

Case 4:17-cr-00048-RGD-LRL Document 47 Filed 10/31/17 Page 1 of 16 PageID# 180

TOT

IMOPgN COURT

CUT >I 2017

IN THE UNITED STATES DISTRICT COURT FOR 1

EASTERN DISTRICT OF VIRGINIA

Ctrak. U.S. biSTFtlCT COURT

NORFOLK. VA

Newport News Division

UNITED STATES OF AMERICA

No. 4:17-CR-48

V.

ALEXANDRA HATCHER,

Defendant.

STATEMENT OF FACTS

By signing below, the parties stipulate that the allegations inthe indictment and the

criminal information and the following facts are true and correct, and that had the matter gone to

trial the United States would have proven them beyond a reasonable doubt, bycompetent and

admissible evidence.

Conspiracy to Commit Mail Fraud

1.

Between at least February 2015 andApril 2017, in the Eastern District of

Virginia, the defendant, ALEXANDRA HATCHER (Defendant), along with and aided and

abetted by others, including but not limited ALBERT HATCHER (HATCHER), created and

carried out a scheme to fraudulently obtain U.S. currency, its equivalents, and other items,

including goods and services, from life insurers operating in the Eastern District ofVirginia by

seeking and obtaining policies insuring Defendant's life and then submitting false claims for

death benefits imder those policies.

2.

Through this scheme. Defendant and HATCHER attempted to defraud, among

others. Navy Mutual Aid Association (Navy Mutual) and New York Life, both life insurance

companies operating inthe Eastern District ofVirginia and elsewhere.

Case 4:17-cr-00048-RGD-LRL Document 47 Filed 10/31/17 Page 2 of 16 PageID# 181

3.

OnJuly 14,2014,HATCHER, an existing Navy Mutual customer, submitted an

application for a ten-year term, $250,000 policy to insure the life ofDefendant, whose legal

name was then "Sandra Marie Hatcher." Navy Mutualapprovedand issued the policy as

requested on or about February 4,2015. The total quarterly premium for this policy was $65.25.

HATCHER was named as the policy's sole beneficiary.

4.

On February 19,2015, HATCHER submitted anapplication to Navy Mutual for a

level term, $500,000 policy to replace the policy he had previously obtained to insure

Defendant's life. Navy Mutual approved and issued thepolicy as requested effective May 27,

2015 (last four digits 6618). The total quarterly premium for this policy was $425.48. The policy

insuredthe Defendant as "Sandra Marie Hatcher." HATCHER was named as the policy's sole

beneficiary.

5.

OnMay 8,2015, Defendant submitted a Member Enrollment Form to AARP

requesting $100,000 in coverage through an AARP Level Benefit Term Life policy administered

through New York Life. On this form, Defendant designated HATCHER as the sole beneficiary

ofthe requested policy. New York Life approved and issued the policy as requested effective

June 1,2015 (last four digits 4748).

6.

On August 11,2015, in the Cascade Division of the Snohomish County Courts

located inArlington, Washington, Defendant obtained a court order changing her legal name

from "Sandra Marie Hatcher" to "Alexandra Vaughan Mitchell."

7.

On August 19,2015, Defendant applied for and obtained a Washington State

Driver's License in the name of "Sandra Marie Hatcher."

Case 4:17-cr-00048-RGD-LRL Document 47 Filed 10/31/17 Page 3 of 16 PageID# 182

8.

Sometime before August 29,2015, Defendant forged and falsified certificates of

death, which falsely certified that "Sandra Marie Hatcher" had died in Portsmouth, Virginia on

August 26,2015 ofa traumatic brain injury resulting from a fall.

9.

Onor before August 29, 2015, Defendant and HATCHER falsely notified Navy

Mutual that Defendant had died. As a result of this notification. Navy Mutual sent HATCHER

an election form on which he could designate how he wished to receive benefits under the policy

ending in 6618. Defendant completed this form, indicating that HATCHER wished to receive a

lump sum benefits payment, which payment Defendant directed Navy Mutual to deposit into a

Langley Federal Credit Union savings account (last four digits 8073), which account Defendant

and HATCHER had jointly opened on December 5,2013. HATCHER signed the election form.

He andDefendant thenreturned the form to Navy Mutual along with at least oneof the forged

and falsified certificates of Defendant'sdeath. Navy Mutual received the election form and

forged certificate on September 4,2015.

10.

On August 31,2015, Defendant, using the name "Alexandra Mitchell" and posing

as her own sister-in-law, called New York Life and reported that Defendant had died of

accidental causes. As a resuhof this call, New York Life opened a death claim under the policy

ending in 4748.

11.

After submitting these false death benefit claims, Defendant and HATCHER

stopped paying the premiums associated with the Navy Mutual policy ending in 6618 and the

New York Life policy ending in 4748.

12.

Defendant and HATCHER's submission of these false claimscausedinsurers,

including Navy Mutual and New York Life, to transmit correspondence, including requests for

Case 4:17-cr-00048-RGD-LRL Document 47 Filed 10/31/17 Page 4 of 16 PageID# 183

verification of Defendant's death, via U.S. mail and private and commercial interstate carriers to

the residence Defendant and HATCHER shared in Portsmouth, Virginia.

13.

To substantiate the false death benefit claims described herein, Defendant and

HATCHER created and submitted for publication a death notice that falsely stated that"Sandra

M. Hatcher," had died on August 26,2015. At their direction, the Daily Press published this

false notice on September 2,2015.

14.

Defendant and HATCHER continued to contact insurers regarding such false

claims. On September 3, 2015, Defendant and HATCHER emailed Navy Mutual another forged

and falsified certificate of Defendant's death. On or about September 4,2015, HATCHER

called Navy Mutual to inquire as to the status ofthe death benefits claim pending under the

policy ending in 6618. Navy Mutual representatives advised HATCHER that acertified death

certificate was required for Navy Mutual to process the claim. Approximately two hours later,

Defendant, posing as her sister-in-law, called Navy Mutual and advised that the funeral home

would issue a certified death certificate the following week.

15.

Seeing the notice ofDefendant's death published on September 2,2015, members

ofDefendant's family contacted the Portsmouth Police Department. On September 3,2015,

officers responded to the residence that Defendant and HATCHER shared in Portsmouth,

Virginia. HATCHER answered the door and, when officers asked to speak to Defendant,

responded, "Is this ajoke?" HATCHER then stated that Defendant had passed away. When

officers asked for a copy ofDefendant's death certificate, HATCHER briefly showed officers

one ofthe forged and falsified certificates ofdeath indicating that Defendant had died on August

26,2015 ofa traumatic brain injury resulting from a fall. While doing so, HATCHER advised

officers thatDefendant haddied of cancer. Officers thenresponded to the funeral home listed on

jp

Case 4:17-cr-00048-RGD-LRL Document 47 Filed 10/31/17 Page 5 of 16 PageID# 184

the forged and falsified death certificate. The funeral home did not have a record ofthe

Defendant's death.

16.

On September 9,2015, a member of Defendant's family filed a missing person's

report with the Portsmouth Police Department. Officers continued to investigate Defendant's

disappearance for several months, during which time they received reports ofDefendant and

hatcher's involvement with various vehicle purchases, as described herein.'

17.

On September 22,2015, HATCHER and Defendant, using the name "Alexandra

Vaughan Mitchell," remarried in Las Vegas, Nevada.

18.

On September 25,2015, Defendant submitted a Change ofName ofRecord form

to the Washington State Department ofLicensing (WA DOL) declaring that her name had

changed from "Sandra Marie Hatcher" to "Alexandra Vaughan Hatcher." As a result, WA DOL

issued Defendant a new driver's license bearing the name "Alexandra Vaughan Hatcher" on

October 9,2015.

19.

On or aboutOctober 1,2015, Defendant and HATCHER shipped to Navy Mutual

via FedEx an item containing atleast one forged and falsified certificate of Defendant's death.

FedEx is a private and commercial interstate carrier that sends and delivers deposited items

according to the direction thereon. That same day. Navy Mutual mailed a letter to HATCHER at

the residence heand Defendant shared in Portsmouth, Virginia indicating that Navy Mutual was

unable to process the death benefits claim under the policy ending in 6618, because the

certificates ofdeath they had received via email on September 3,2015 and by FedEx delivery on

October 1,2015 did not meet their standards.

' On orabout March 30,2016, officers spoke with Defendant, who stated she did not want to have contact with her

family.

5

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