F1 ED

U.S. DISTRICT COURT

MIDDLE DISTRICT OF TENN.
UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE JAN 18 2022
NASHVILLE DIVISION

UNITED STATES OF AMERICA )

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No. 3.~W -Dd4~'7'// Y CLERK
V. )

MELISSA ANN GOODWIN ) 18 U.S.C. § 1343

INFORMATION
CC)T TNT ONF

THE UNITED STATES ATTORNEY CHARGES:

At all times material to this Information:

1. The T.J. Martell Foundation for Cancer Research ("the Foundation"), based in

Nashville, Tennessee, was the music industry's leading foundation that funds innovative medical

research focused on finding treatments and cures for cancer. The Foundation raises money for

cancer research by soliciting in-kind donations from celebrities and then auctioning off those

donations for a profit.

2. MELISSA ANN GOODWIN was an employee of the Foundation from 2005 until

July 2020. GOODWIN was employed in various capacities. Beginning in approximately June

2011, GOODWIN managed and oversaw the financial operations of the entire Foundation and

reported directly to the CEO. From 2018 until July 2020, she was the Executive Vice President

and General Manager. GOODWIN's duties included: working with staff to organize and execute

Foundation events; maintaining the Foundation's national budget; procuring various insurance

policies for the Foundation; being the point-person with the Foundation's accounting firm;

handling payroll; and establishing and procuring contracts for the Foundation.

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 3. In its fundraising efforts, the Foundation primarily relied on donated items, but

occasionally auctioned items on a consignment basis. When the Foundation auctioned items on

consignment, the Foundation borrowed the consignment items from a consignment vendor and put

those items up at auction. At the conclusion of the auction, the Foundation would pay the vendor

the consignment price for any items that sold at auction and would return any items that did not

sell.

4. Individual One, an individual known to the Acting United States Attorney, was the

founder and owner of a charity auction business based in New York City ("Business A"). Business

A, a business known to the Acting United States Attorney, conducted auctions for clients and

offered consignment items, such as event tickets or sports memorabilia, to clients for use in their

auctions. On occasion, the Foundation used the services of Business A to provide consignment

items at auction.

5. The Foundation hired Accounting Firm One, an accounting firm known to the

Acting United States Attorney, to issue checks for the Foundation, to record Foundation credit

card expenses in QuickBooks (an accounting software program), and to create periodic financial

reports for the Foundation. GOODWIN was the primary point of contact between Accounting

Firm One and the Foundation, and it was her job to provide Accounting Firm One with the

Foundation's credit card statements and expense reports so that Accounting Firm One could

prepare the financial reports. Further, it was GOODWIN's responsibility to provide the financial

reports prepared by Accounting Firm One to the Foundation's CEO.

6. Beginning in or about July 2018, and continuing until in or about June 2020, in the

Middle District of Tennessee and elsewhere, GOODWIN devised and intended to devise a scheme

and artifice to defraud the Foundation, and others, known and unknown to the Acting United States

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Attorney, and to obtain money and property by means of materially false pretenses,

representations, and promises, and by acts of concealment of the scheme, and in furtherance

thereof, used interstate wires, which scheme is further described in the following paragraphs.

7. While GOODWIN was employed at the Foundation, it had an active JPMorgan

Chase corporate credit card account ending in account number x0241. Sometime before July 2018,

GOODWIN obtained a Foundation credit card in her own name, credit card account ending in

x1527, which was a sub-account of the Foundation credit card account ending in x0241.

8. Beginning in at least approximately July 2018, GOODWIN began using the

Foundation credit card ending in x1527 to make large ticket purchases through online ticket and

event vendors such as Ticketmaster, Stubhub, Primesport, and On-Location. Some of the tickets

GOODWIN purchased were for musical concerts, such as Lady Gaga and Celine Dion, and some

were to sporting events, such as Super Bowl LIV, which was a major sporting event that was

scheduled to take place in Miami, Florida, on February 2, 2020. The tickets that GOODWIN

purchased were not for a legitimate Foundation purpose.

9. It was part of the scheme that GOODWIN also used the Foundation's credit card

to purchase other items that were not for legitimate Foundation purposes, such as expensive and

rare alcohols, plane tickets, and hotel stays.

10. It was part of the scheme that after GOODWIN purchased the tickets at market

resale value through online ticket and event vendors such as Ticketmaster, Stubhub, Primesport,

and On-Location, she provided those tickets and some of the other items purchased with the

Foundation's credit card to Individual One.

11. It was part of the scheme that GOODWIN led Individual One to believe she had

acquired those tickets for free or at a discounted rate.

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 12. Between July 2018 and April 2020, GOODWIN purchased approximately $3.96

million in tickets from Ticketmaster, Stubhub, Primesport, and On-Location using the

Foundation's credit card. Goodwin then used the Foundation bank, accounts to make payments on

the credit card.

13. It was part of the scheme that, in order to conceal the purchases and checks she

wrote, GOODWIN provided falsified credit card statements and false expense reports to

Accounting Firm One. Before providing them to Accounting Firm One, GOODWIN altered the

credit card statements to conceal purchases she made from Ticketmaster, Stubhub, Primesport, and

On-Location, as well as other expenses. She often replaced those expenses with other vendors so

that the charges appeared to be legitimate Foundation expenses. In total, GOODWIN concealed

over $3 million in fraudulent credit card expenses.

14. Accounting Firm One prepared the Foundation's periodic financial statements

based on these falsified credit card statements and expense reports. Accounting Firm One then

emailed those financial statements to GOODWIN, whose job it was to provide them to the

Foundation's CEO.

15. It was further a part of the scheme that after receiving the financial statements from

Accounting Firm One, GOODWIN falsified those financial statements before providing them to

the Foundation's CEO. GOODWIN falsified the financial statements by inflating the

Foundation's assets and lowering its liabilities to make the Foundation appear to be more liquid

than it actually was at the time. For example, on the August 31, 2019, periodic financial statement,

GOODWIN inflated the cash balance by $500,000, and on the 2019 Year-End Financials,

GOODWIN inflated the cash balance by $1,020,000. These falsifications prevented the

Foundation from detecting GOODWIN's fraudulent transactions.

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 16. It was further a part of the scheme that GOODWIN caused payments to be made

to the Foundation's credit card from Business A's bank account related to the tickets she purchased

as part of the scheme.

17. It was further a part of the scheme that GOODWIN forged the signature of the

Foundation's CEO on various Foundation checks. GOODWIN did not have authority to sign

Foundation checks. The Foundation had a policy that any check over $5,000 must be signed by at

least two signatories—the Foundation's CEO and the Foundation's in-house counsel. Despite this,

GOODWIN signed the CEO's name on several checks that were not approved by the Foundation.

GOODWIN forged the CEO's name on the following checks without authorization or approval:

Check Date Payable to Check Amount

05/23/2019 Business A $12,500.00
02/06/2020 Business A $122,211.00
02/13/2020 Business A $600,950.00
02/21/2020 Business A $34,530.00
03/11/2020 Business A $119,652.28
03/23/2020 Business A $76,432.50

18. On or about the April 11, 2020, in the Middle District of Tennessee and elsewhere,

GOODWIN, for the purpose of executing and attempting to execute the scheme to defraud, caused

to be transmitted by means of wire communications in interstate commerce the following signals

and sounds: an email dated April 11, 2020, to S.S., an employee at Accounting Firm One, which

contained falsified credit card statements that omitted payments to the credit card from Business

A's bank account and falsified and concealed other fraudulent expenses GOODWIN had incurred

on the Foundation's credit card, in violation of Title 18, United States Code, Section 1343.

FORFEITURE ALLEGATION

19. Paragraphs One (1) through Eighteen (18) are reincorporated and realleged as if

fully set forth herein in support of this forfeiture.

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 20. Upon conviction of Count One of this Information, MELISSA ANN GOODWIN

shall forfeit to the United States of America, pursuant to Title 18, United States Code, Section

981(a)(1)(C) by Title 28, United States Code, Section 2461, any property constituting, or derived

from, proceeds traceable to the violation of Title 18, United States Code, Section 1343 as charged

in Count One, including but not limited to a money judgment in the amount of at least

$3,765,606.77 United States currency, representing the proceeds of the scheme and artifice to

defraud as set forth in the Count One.

21. If any of the property described above, as a result of any act or omission of

GOODWIN:

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;

d. has been substantially diminished in value; or

e. has been commingled with other property that cannot be divided without difficulty,

the United States shall be entitled to forfeiture of substitute property, and it is the intent of the

United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any

other property of GOODWIN, up to the value of said property listed above as subject

to forfeiture up to the amount of $3,765,606.77 United States currency.

MARK H. WILDASIN
UNTIED STATES ATTORNEY

KATHR W. BOOTH
ASSISTANT UNITED STATES ATTORNEY

E.
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