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USA v. Goodwin, Information
USA v. Goodwin, Information
INFORMATION
CC)T TNT ONF
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
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.
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
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.
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.
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
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
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
11. It was part of the scheme that GOODWIN led Individual One to believe she had
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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
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
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
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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
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:
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
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
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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
21. If any of the property described above, as a result of any act or omission of
GOODWIN:
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
MARK H. WILDASIN
UNTIED STATES ATTORNEY
KATHR W. BOOTH
ASSISTANT UNITED STATES ATTORNEY
E.
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