1 Indictment 1 WM

Case: 25CI1:22-cr-00002-EFP Document #: 1 Filed: 01/13/2022 Page 1 of 35
INDICTMENT Defendant Nancy New CIRCUIT COURT NO. ~-l

Conspiracy ~97-1-1- 3 Counts
Conspiracy 97-7-11 - 2 Counts
Conspiracy ICO §97-45-5(4)
Embezzlement §97-23-19(d)- 7 Counts
Bribery of Public Official §97-11-53 - 6 Counts
Defraud The State OfMississippi §97-7-10- 10 Counts
Mail Fraud §97-19-83- 10 Counts
Forgery §97-21-3- 2 Counts
Violations of Racketeer Influenced and Corrupt Organization Act.§97-43-5- 3 Counts
Violations of Racketeer Influenced and Corrupt Organization Act.§97-43-3.1 - 2 Counts
Defendant Zachary New

Conspiracy ~97-1-1- 3 Counts
Conspiracy 97-7-11 -2 Counts
Conspiracy ICO §97-45-5(4)
Embezzlement §91-23-19(d) -7 Counts
Bribery ofPubhc Official §97-11-53- 6 Counts
Defraud The State Of Mississippi §97-7-10- 10 Counts
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Mail Fraud §97-19-83 -- 10 Counts
Forgery §97-21-3- 2 Counts
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Violations of Racketeer Influenced and Corrupt Organization Act.§97-43-5- 3 Counts
Violations of Racketeer Influenced and Corrupt Organization Act.§97-43-3.1 - 2 Counts
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THE STATE OF MISSISSIPPI Circuit Court
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FIRST DISTRICT, HINDS COUNTY January Term, A.D., 2022
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First Judicial District
of Hinds County
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The Grand Jurors of the State of Mississippi, taken from the body of good and lawful
persons of the First Judicial District of Hinds County, in the State of Mississippi, elected,
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impanelled, sworn and charged to inquire in and for said District, County and State aforesaid, in
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the name and by the authority of the State of Mississippi, upon their oath present: That
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Nancy New and Zachary New, Co-Defendants

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In said District, County and State
COUNT I
on, about and between the 18th day of January, 2019 and the 7th day of October 2019, in
the county aforesaid and within the jurisdiction of this Court, said Nancy New being a
female human being above the age of eighteen (18) years, and Zachary New being a male
human being above the age of eighteen (18) years, whose date of birth is, did willfully,
unlawfully, and feloniously enter into a conspiracy with each other, and others known and
unknown to the grand jury, to commit the crime of embezzlement in violation of Miss.
Code §97-23-19, To-wit: Nancy New and Zachery New, conspired with each other and
others known and unknown to the grand jury, to convert funds received by the Mississippi
Community Education Center, a private non-profit entity responsible
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for distributing public grant funds received from the State of Mississippi by transferring funds
owned by the Mississippi Community Education Center, from its bank account, a Regions Bank
Account, through a series of multiple transactions, into bank accounts owned by Prevacus,
Suntrust Bank, and PresolMD, Suntrust Bank, Florida based biomedical companies, which
transferred funds were used to purchase investment interests in Prevacus and PresolMD which
investment interests were owned by Nancy New and Zachary New, all occurring within the
jurisdiction of this court and in violation of Section 97-1-1 and Section 97-23-19, Mississippi
Code Annotated (1972, as amended); and,
COUNT II
based upon a series of acts connected together and constituting parts of a common
scheme and plan, said Nancy New being a female human being above the age of eighteen (18)
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years, and Zachary New being a male human being above the age of eighteen (18) years, did,
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on or about the 18th of January, 2019, willfully, unlawfully, and feloniously embezzle,
fraudulently secrete, conceal, or convert to their own use, or make way with, or secrete with
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intent to embezzle or convert to their own use, United States Funds, money, in a value in
excess of $25,000.00, which United States Funds came into their possession and/or had been
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entrusted to Nancy New and Zachary New by virtue of their offices, positions, places, or
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employment, either in mass or otherwise, To-wit: Nancy New and Zachary New, while
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serving as the Executive Director and Assistant Executive Director, respectively, of the
Mississippi Community Education Center, a private non-profit entity responsible for
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distributing public grant funds received from the State of Mississippi, embezzled,
converted to their own use and transferred seven hundred and fifty thousand dollars,
$750,000.00, the property of the Mississippi Community Education Center, from its bank
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account, Regions Bank Account Number ******7729, to an account controlled by Nancy New
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and Zachary New in the name of New Learning Resources, Inc., which in tum mailed a
check for $750,000.00 from Account 0122811079 to Prevacus, Inc., which deposited said
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$750,000.00 check in Prevacus, Inc., Suntrust Bank Account Number ********7709, a

Florida based biomedical company, which transferred funds were used to purchase an investment
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interest in Prevacus Inc., which investment interest was owned by NancyWhitten New and
Zachery Whitten New, all occurring within the jurisdiction of this court and in violation of
Section 97 -23-19(d), Mississippi Code Annotated (1972, as amended); and,
COUNT III
on or about the 8th day of April, 2019, willfully, unlawfully, and feloniously embezzle,
fraudulently secrete, conceal, or convert to their own use, or make way with, or secrete with
intent to embezzle or convert to their own use, United States Funds, money, in a value in
excess of $25,000.00, which United
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States Funds came into their possession and/or had been entrusted to them by virtue of their
offices, positions, places, or employment, either in mass or otherwise, To-wit: Nancy New was
serving as the Executive Director of the Mississippi Community Education Center, and Zachary
New was serving as the Assistant Executive Director of the Mississippi Community Education
Center, a private non-profit entity responsible for distributing public grant funds received from
the State of Mississippi, embezzled, converted to their own use and transferred $500,000.00, via
wire, the property of the Mississippi Community Education Center, from its bank account, a
Regions Bank Account, to a bank account owned by Prevacus, Suntrust Bank, a Florida based
biomedical company, which transferred funds were used to purchase an investment interest in
Prevacus which investment interest was owned by Nancy New and Zachary New, all occurring
within the jurisdiction of this court and in violation of Section 97 -23-19( d), Mississippi Code
Annotated (1972, as amended); and,
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COUNT IV
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years and Zachary New being a male human being above the age of eighteen (18) years did, on
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or about the 101h day of May, 2019, willfully, unlawfully, and feloniously embezzle, fraudulently
secrete, conceal, or convert to their own use, or make way with, or secrete with intent to
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embezzle or convert to each of their own use, United States Funds, money, in a value in
excess of $25,000.00, which United States Funds came into their possession and/or had been
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entrusted to them by virtue of their offices, positions, places, or employment, either in mass or
otherwise, To-wit: Nancy New was serving as the Executive Director of the Mississippi
Community Education Center, and Zachary New was serving as the Assistant Executive
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Director of the Mississippi Community Education Center, a private non-profit entity

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responsible for distributing public grant funds received from the State of Mississippi,
embezzled, converted to their own use and transferred two hundred and fifty thousand
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dollars, $250,000.00, via wire, the property of the Mississippi Community Education Center,
from its bank account, a Regions Bank Account, to a bank account owned by Prevacus,
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Suntrust Bank, a Florida based biomedical company, which transferred funds were used
to purchase an investment interest in Prevacus which investment interest was owned by
Nancy New and Zachary New, all occurring within the jurisdiction of this court and in violation
of Section 97 -23-19( d), Mississippi Code Annotated ( 1972, as amended); and,
COUNTY
years and Zachary New being a male human being above the age of eighteen (18) years, did, on
or about the 16th day of July, 2019, willfully, unlawfully, and feloniously embezzle, fraudulently
secrete, conceal,
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or convert to their own use, or make way with, or secrete with intent to embezzle or convert to
their own use, United States Funds, money, in a value in excess of $25,000.00, which United
States Funds came into their possession and/or had been entrusted to them by virtue of their
offices, positions, places, or employment, either in mass or otherwise, To-wit: Nancy New was
serving as the Executive Director of the Mississippi Community Education Center, and Zachary
New was serving as the Assistant Executive Director of the Mississippi Community Education
Center, a private non-profit entity responsible for distributing public grant funds received from
the State of Mississippi, embezzled, converted to their own use and transferred four hundred
thousand dollars, $400,000.00, via wire, the property of the Mississippi Community Education
Center, from its bank account, a Regions Bank Account to a bank account owned by Prevacus,
Suntrust Bank, a Florida based biomedical company, which transferred funds were used to
purchase an investment interest in Prevacus which investment interest was owned by Nancy New
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and Zachary New, all occurring within the jurisdiction of this court and in violation of Section
97-23-19(d), Mississippi Code Annotated (1972, as amended); and,
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COUNT VI
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or about the 24th day of September, 2019, willfully, unlawfully, and feloniously embezzle,
fraudulently secrete, conceal, or. convert to their own use, or make way with, or secrete with
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intent to embezzle or convert to their own use, United States Funds, money, in a value in excess
of $25,000.00, which United States Funds came into their possession and/or had been
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entrusted to them by virtue oftheir offices, positions, places, or employment, either in mass or
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embezzled, converted to their own use and transferred one hundred thousand dollars,
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$100,000.00, via wire, the property of the Mississippi Community Education Center, from its
bank account, a Regions Bank Account to a bank account owned by PresolMD, Suntrust Bank,
a Florida based biomedical company, which transferred funds were used to purchase an
investment interest in PresolMD which investment interest was owned by Nancy New and
Zachery New, all occurring within the jurisdiction of this court and in violation of Section
97-23-19(d), Mississippi Code Annotated (1972, as amended); and,
COUNT VII
years and Zachary New being a male human being above the age of eighteen (18) years, did,
on or about the 7th
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day of October, 2019, willfully, unlawfully, and feloniously embezzle, fraudulently secrete,
conceal, or convert to their own use, or make way with, or secrete with intent to embezzle or
convert to their own use, United States Funds, money, in a value in excess of $25,000.00, which
United States Funds came into their possession and/or had been entrusted to them by virtue of
their offices, positions, places, or employment, either in mass or otherwise, To-wit: Nancy New
was serving as the Executive Director of the Mississippi Community Education Center, and
Zachary New was serving as the Assistant Executive Director of the Mississippi Community
Education Center, a private non-profit entity responsible for distributing public grant funds
received from the State of Mississippi, embezzled, converted to their own use and transferred
one hundred fifty thousand dollars, $150,000.00, via wire, the property of the Mississippi
Community Education Center, from its bank account, a Regions Bank Account to a bank
account owned by PresolMD, Suntrust Bank, a Florida based biomedical company, which
transferred funds were used to purchase an investment interest in PresolMD which investment
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interest was owned by Nancy New and Zachary New, all occurring within the jurisdiction of this
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court and in violation of Section 97 -23-19( d), Mississippi Code Annotated ( 1972, as amended);
and,
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COUNT VIII
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years and Zachary New being a male human being above the age of eighteen (18) years,
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did, on or about and between 181hday of January, 2019 and the 7th day of October 2019,
willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi or
any department, agency, office, board, comm1sswn, county, municipality or other
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subdivision of the state or local government, knowingly and willfully falsified, concealed
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or covered up by trick, scheme or device, a material fact, or made a false, fictitious and
fraudulent statements or representations, or made or used any false writing or document
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knowing that the same contained false, fictitious an fraudulent statements or entries,
To-wit: Nancy New and Zachary New while acting in concert and/or aiding, and
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assisting others known and unknown to the grand jury, falsified documents, invoices, books,
reports, ledgers, and accountings of the Mississippi Community Education Center, a
private non-profit entity responsible for distributing public grant funds received from the State
of Mississippi, at a time when they were in the positions of Executive Director and
Assistant Executive Director, respectively, of the Mississippi Community Education
Center, to conceal that they had embezzled or otherwise unlawfully misdirected
$2,150,000.00, from the Mississippi Community Education Center which embezzled
funds were used to purchase investment interests in Prevacus and PresolMD, Florida
based biomedical companies, which investment interests were owned by Nancy New and
Zachery New, all occurring within the jurisdiction of this court and in violation of Section
97-7-10, Mississippi Code Annotated (1972, as amended); and,
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COUNT IX
On, about and between the 20th day of September 2018 and the 20th day of October
2019, in the county aforesaid and within the jurisdiction of this Court, Nancy New, being a
female human being above the age of eighteen (18) years and Zachary New being a male
human being above the age of eighteen (18) years, did willfully, unlawfully, and feloniously
entered into a conspiracy with each other, Anne McGrew, John Davis and others known and
unknown to the grandjury, to commit the crime of embezzlement in violation of §97-23-19, To-
wit: Nancy New and Zachery New conspired with each other, Anne McGrew, John Davis and
others known and unknown to the grand jury, to embezzle and convert to each of their
own use funds received by the Mississippi Community Education Center, a private non-profit
entity responsible for distributing public grant funds received from the State of Mississippi by
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transferring funds owned by the Mississippi Community Education Center, from a bank
account owned by the Mississippi Community Education Center, through a series of
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multiple transaction, into bank accounts owned by New Learning Resources, Inc., a private for
profit company owned and controlled by Nancy Whitten New and Zachery Whitten New, and
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thus converting such monies to each of their own use, all occurring within the jurisdiction of this
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court and in violation of Section 97-1-1 and Section 97-23-19, Mississippi Code Annotated
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(1972, as amended); and,
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COUNT X
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based -upon a oseries of acts connected together and constituting parts of a common
scheme and plan, said Nancy Whitten New, being a female human being above the age of
eighteen (18) years and Zachary New being a male human being above the age of eighteen (18)
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years, did, on or about and between the 20th day of September 2018 and the 20th day of October
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2019, willfully, unlawfully, and feloniously embezzle, fraudulently secrete, conceal, or convert
to each of their own use, or make way with, or secrete with intent to embezzle or convert to
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each of their own use, United States Funds, money, in a value in excess of $25,000.00, which
United States Funds came into their possession and/or had been entrusted to Nancy New and
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Zachery New by virtue of their offices, positions, places, or employment, either in mass or
embezzled, converted to each of their own use and transferred funds, in excess of two
million dollars, $2,000,000.00, the property of the Mississippi Community Education Center,
from a bank account owned by the Mississippi Community Education Center, through a
series of multiple transaction, into bank accounts owned by New Learning, Resources Inc, a
private for-profit company owned and controlled by Nancy Whitten New and Zachery Whitten
New and thus converting such monies to each of their own use, all occurring within the
jurisdiction of this court and in violation of Section 97-23-19 (d), Mississippi Code
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COUNT XI
scheme and plan, said Nancy New, being a female human being above the age of eighteen (18)
or about February 11, 2019, willfully, unlawfully, feloniously, and directly or indirectly
offer, promise, give or agree to give to a public official as defined by Miss. Code §97-11-53,
money, property, or other tangible or intangible thing of value as a bribe or inducement or
incentive for the awarding or refusal to award a contract by an entity referred to Miss. Code
§97-11-53(2-b)(i) through (v) or as an inducement or incentive for the accomplishment of any
official act or purpose involving public funds or public trust. To-wit: Nancy New, at a time
when she was in the position of Executive Director of the Mississippi Community Education
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Center, and Zachary New, at a time when he was in the position of Assistant Executive
Director of the Mississippi Community Education Center, while acting in concert and/or
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aiding, and assisting each other, John Davis and others known and unknown to the grand jury,
and during and after the time when the Mississippi Department of Human Services had
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entrusted limited purpose public TANF grant funds to Mississippi Community Education
Center, did directly or indirectly offer, promise, give or agree to give to John Davis, a public
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official holding the office of Executive Director of the Mississippi Department of Human
Services money, property, or other tangible or intangible thing of value, namely a payment of
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$40,000.00, on or about February 11, 2019, of limited purpose public TANF grant funds
toward the extinguishment of the personal debt of John Davis to Rise In Malibu made as
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an inducement or incentive of awarding a contract modification by the Mississippi

Department of Human Services on or about June 13, 2019, which increased the limited
purpose grant funds under the control of Nancy New and Zachary New by $3,600,000.00 and as
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an inducement or incentive for the accomplishment of any official act or purpose

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involving public funds or public trust, namely the subsequent transfers, on and after February 11,
2019, of limited purpose public grant TANF funds to Mississippi Community Education Center,
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under the control of Nancy New and Zachary New, from the Mississippi Department of Human
Services, including but not limited to those limited purpose public TANF grant funds
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fraudulently obtained and transferred by Nancy New and Zachary New to New Learning
Resources Inc., and to Prevacus Inc., and to PresolMD, all occurring within the jurisdiction of
this court and in violation of Section 97-11-53, Mississippi Code Annotated (1972, as amended);
and,
COUNT XII
or about March 7, 2019, willfully, unlawfully, feloniously, and directly or indirectly offer,
promise, give or agree to give to a public official as defined by Miss. Code §97-11-53, money,
property, or other tangible
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or intangible thing of value as a bribe or inducement or incentive for the awarding or refusal to
award a contract by an entity referred to Miss. Code §97-11-53(2-b)(i) through (v) or as an
inducement or incentive for the accomplishment of any official act or purpose involving public
funds or public trust. To-wit: Nancy New, at a time when she was in the position of Executive
Director of the Mississippi Community Education Center, and Zachary New, at a time when he
was in the position of Assistant Executive Director of the Mississippi Community Education
Center, while acting in concert and/or aiding, and assisting each other, John Davis and others
known and unknown to the grand jury, and during and after the time when the Mississippi
Department of Human Services had entrusted limited purpose public TANF grant funds to
Mississippi Community Education Center, did directly or indirectly offer, promise, give or agree
to give to John Davis, a public official holding the office of Executive Director of the Mississippi
Department of Human Services money, property, or other tangible or intangible thing of value,
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namely a payment of $40,000.00, on or about March 7, 2019, toward the extinguishment of the
personal debt of John Davis to Rise In Malibu made as an inducement or incentive of awarding a
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contract modification by the Mississippi Department of Human Services on or about June 13,
2019, which increased the limited purpose grant funds under the control of Nancy New and
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Zachary New by $7,600,000.00 and as an inducement or incentive for the accomplishment of
any official act or purpose involving public funds or public trust, namely the subsequent
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transfers, on and after March 7, 2019, of limited purpose public grant TANF funds to Mississippi
Community Education Center, under the control of Nancy New and Zachary New, from the
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Mississippi Department of Human Services, including but not limited to those limited purpose
public TANF grant funds fraudulently obtained and transferred by Nancy New and Zachary New
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to New Learning Resources Inc., and to Prevacus Inc., and to PresolMD, all occurring within the
jurisdiction of this court and in violation of Section 97-11-53, Mississippi Code Annotated (1972,
as amended); and,
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so
COUNT XIII
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or about April 8, 2019, willfully, unlawfully, feloniously, and directly or indirectly offer,
promise, give or agree to give to a public official as defined by Miss. Code §97-11-53, money,
property, or other tangible or intangible thing of value as an inducement or incentive for the
awarding or refusal to award a contract by an entity referred to Miss. Code §97-11-53(2-b)(i)
through (v) or as an inducement or incentive for the accomplishment of any official act or
purpose involving public funds or public trust. To-wit: on or about April 8, 2019 -the very
same date Nancy New and Zachary New fraudulently caused $500,000.00, in limited purpose
public TANF grant funds, to be transferred to Prevacus Inc., for the personal enrichment of
Nancy New and Zachary New, to wit: Nancy New, at a time when she was in the position of
Executive Director of the Mississippi Community Education Center, and Zachary New, at a time
when he was in the position of Assistant Executive Director of the Mississippi Community
Education Center, while acting in concert and/or aiding,
Page 8 of 35
and assisting each other, John Davis and others known and unknown to the grand jury, and
during and after the time when the Mississippi Department of Human Services had entrusted
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limited purpose public TANF grant funds to Mississippi Community Education Center, did f
directly or indirectly offer, promise, give or agree to give to John Davis, a public official holding
the office of Executive Director of the Mississippi Department of Human Services money, I
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property, or other tangible or intangible thing of value, namely a payment of $40,000.00, on or
about April 8, 2019, toward the extinguishment of the personal debt of John Davis to Rise In
Malibu made as an inducement or incentive of awarding a contract modification by the i
Mississippi Department of Human Services on or about June 13, 2019, which increased the
limited purpose grant funds under the control of Nancy New and Zachary New by $7,600,000.00
and as an inducement or incentive for the accomplishment of any official act or purpose
involving public funds or public trust, namely the subsequent transfers, on and after April 8,
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2019, of limited purpose public grant TANF funds to Mississippi Community Education Center,
under the control of Nancy New and Zachary New, from the Mississippi Department of Human
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Services, including but not limited to those limited purpose public TANF grant funds
fraudulently obtained and transferred by Nancy New and Zachary New to New Learning
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Resources Inc., and to Prevacus Inc., and to PresolMD, all occurring within the jurisdiction of
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and,
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COUNT XIV
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based upon a series of acts connected together and constituting- parts of a common
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or about June 13, 2019, the very day that John Davis signed a contract modification by the
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Mississippi Department of Human Services which increased the limited purpose grant funds
under the control of Nancy New and Zachary New by $7,600,000.00, did willfully, unlawfully,
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feloniously, and directly or indirectly offer, promise, give or agree to give to a public official
as defined by Miss. Code §97-11-53, money, property, or other tangible or intangible thing
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of value as a bribe or an inducement or incentive for the awarding or refusal to award a

contract by an entity referred to Miss. Code §97-11-53(2-b)(i) through (v) or as an
inducement or incentive for the accomplishment of any official act or purpose involving
public funds or public trust. To-wit: Nancy New, at a time when she was in the position of
Executive Director of the Mississippi Community Education Center, Zachary New, at a time
when he was in the position of Assistant Executive Director of the Mississippi Community
Education Center, and while acting in concert and/or aiding, and assisting each other, John Davis
and others known and unknown to the grand jury, and during and after the time when the
Mississippi Department of Human Services had entrusted limited purpose public TANF grant
funds to Mississippi Community Education Center, did directly or indirectly offer, promise,
give or agree to give to John Davis, a public official holding the office of Executive
Director of the Mississippi Department of Human Services money, property, or other tangible
or intangible thing of value, namely a payment of$40,000.00
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on or about June 13,2019, toward the extinguishment of the personal debt of John Davis to Rise
In Malibu made as an inducement or incentive for awarding a contract modification by the
Mississippi Department of Human Services on June 13, 2019, the very same day as the
payment of the bribe, which increased the limited purpose grant funds under the control of
Nancy New and Zachary New by $7,600,000.00 and as an inducement or incentive for the
accomplishment of any official act or purpose involving public funds or public trust, namely the
subsequent transfers, on and after June 13, 2019, oflimited purpose public grant TANF funds to
Mississippi Community Education Center, under the control of Nancy New and Zachary New,
from the Mississippi Department of Human Services, including but not limited to those limited
purpose public TANF grant funds fraudulently obtained and transferred by Nancy New and
Zachary New to New Learning Resources Inc., and to Prevacus Inc., and to PresolMD, all
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occurring within the jurisdiction of this court and in violation of Section 97-11-53, Mississippi f
Code Annotated (1972, as amended); and,
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COUNT XV
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or about February 23, 2019 willfully, unlawfully, feloniously, and directly or indirectly offer,
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promise, give or agree to give to a public official as defined by Miss. Code §97-11-53,
money, property, or other tangible or intangible thing of value as a bribe - or an inducement or
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official act or purpose involving public funds or public trust. To-wit: on or about February 23,
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2019, Nancy New, at a time when she was in the position of Executive Director of the
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Mississippi Community Education Center, and Zachary New, at a time when he was in the
position of Assistant Executive Director of the Mississippi Community Education Center,
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and while acting in concert and/or aiding, and assisting each other, John Davis and others
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Mississippi Community Education Center, did directly or indirectly offer, promise, give or
agree to give to John Davis, a public official holding the office of Executive Director of the
Mississippi Department of Human Services money, property, or other tangible or intangible
thing of value, namely payment in Hinds County, Mississippi at least $790.00 for a luxury hotel
suite at the Four Seasons Hotel in California used by John Davis for his personal use and which
payment was made as an inducement or incentive for the awarding a contract modification by
the Mississippi Department of Human Services on or about June 13, 2019, which increased
the limited purpose grant funds under the control of Nancy New and Zachary New by
$7,600,000.00 and as an inducement or incentive for the accomplishment of any official act
or purpose involving public funds or public trust, namely the subsequent transfers, on
and after February 23, 2019, of limited purpose public grant TANF funds to Mississippi
Community Education Center, under the control of Nancy New and Zachary New,
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from the Mississippi Department of Human Services, including but not limited to those limited
purpose public TANF grant funds fraudulently obtained and transferred by Nancy New and
Zachary New to New Learning Resources Inc., and to Prevacus Inc., and to PresolMD, all
1 occurring within the jurisdiction of this court and in violation of Section 97-11-53, Mississippi
Code Annotated ( 1972, as amended); and,
COUNT XVI
or about February 20, 2019 willfully, unlawfully, feloniously, and directly or indirectly offer,
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promise, give or agree to give to a public official as defined by Miss. Code §97-11-53,
money, property, or other tangible or intangible thing of value as a bribe or an inducement or
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official act or purpose involving public funds or public trust. To-wit: on or about February 20,
2019, Nancy New, at a time when she was in the position of Executive Director of the
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and while acting in concert and/or aiding, and assisting each other, John Davis and others
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Mississippi Community Education Center, did directly or indirectly offer, promise, give or
agree to give to John Davis, a public official holding the office of Executive Director of the
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Mississippi Department of Human Services money, property, or other tangible or intangible

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thing of value, namely payment in Hinds County, Mississippi at least $1,107.75 for a First Class
Ticket for a flight to and from California and $238.31 to a California limousine company for a
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chauffeured sedan for personal use of John Davis and which payment was made as an
inducement or incentive for the awarding a contract modification by the Mississippi
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Department of Human Services on or about June 13, 2019, which increased the limited
purpose grant funds under the control of Nancy New and Zachary New by $7,600,000.00 and as
an inducement or incentive for the accomplishment of any official act or purpose
involving public funds or public trust, namely the subsequent transfers, on and after February 20,
2019, of limited purpose public grant funds to Mississippi Community Education Center from
the Mississippi Department of Human Services, including but not limited to those limited
purpose public grant funds fraudulently obtained and transferred by Nancy New and Zachary
New to New Learning Resources Inc., and to Prevacus Inc., and to PresolMD, all occurring
within the jurisdiction of this court and in violation of Section 97-11-53, Mississippi Code
Page 11 of 35
COUNT XVII
years, and Zachary New being a male human being above the age of eighteen (18) years, did
on, about and between February 11, 2019 and June 13, 2019, in the county aforesaid and within
the jurisdiction of this Court, willfully, unlawfully, and feloniously entered into a conspiracy
with each other, John Davis and others known and unknown to the grand jury, to commit the
crime ofbribery in violation of Miss. Code §97-11-53, To-wit: between February 11, 2019
and June 13, 2019, Nancy New and Zachary New conspired with each other and with John
Davis, a public official being the Executive Director of the Mississippi Department of
Human Services and others known and unknown to the grand jury, to directly or indirectly
m
offer, promise, give or agree to give to John Davis, a public official holding the office of
Executive Director of the Mississippi Department of Human Services money, property, or
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other tangible or intangible thing of value, namely payment of the personal debts and
personal travel expenses of John Davis as an inducement or incentive of awarding a
a.
contract modification by the Mississippi Department ofHuman Services on or about June 13,
2019 which increased the limited purpose grant funds under the control of Nancy New and
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la
Zachary New by $7,600,000.00 and/or as an inducement or incentive for the accomplishment of
any official act or purpose involving public funds or public trust, namely the subsequent
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transfers of public funds to Mississippi Community Education Center, under the control of
Nancy New and Zachary New, from the Mississippi Department of Human Services on and
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after February 20, 2019, all occurring within the jurisdiction of this court and in violation of
Section 97-1-1 and Section 97-11-53, Mississippi Code Annotated (1972, as amended); and,
nj
COUNT XVIII
so
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Ja
or about October 1, 2018 and continuing until December 31, 2019, willfully, unlawfully, and
feloniously with the intent to defraud the State of Mississippi enter into an agreement,
combination or conspiracy to defraud the State of Mississippi, or any department or political
subdivision thereof, by obtaining or aiding to obtain the payment or allowance from the
public funds of the state, or of any department or political subdivision thereof, of any false or
fraudulent claim, To-wit: Nancy New, at a time when she was in the position of Executive
was in the position of Assistant Executive Director of the Mississippi Community
Education Center, while acting in agreement, combination and conspiracy with each
other, and in combination, conspiracy, concert and/or aiding, and assisting John Davis and
others known and unknown to the grand jury, did with the intent to defraud the Mississippi
Department of Human Services knowingly and willfully submit
Page 12 of 35
false and fraudulent claims to the Mississippi Department of Human Services which documents
intentionally, knowingly and falsely sought and obtained payments of at least $1,656,000.00 of
limited purpose public grant funds which were criminally diverted, or which were obtained to
replace funds which were criminally diverted, to New Learning Resources, Inc., a company
which Nancy New and Zachary New owned and controlled, and which was known by Nancy
New and Zachary New to be ineligible to receive such grant funds and for purposes known by
Nancy New and Zachary New and Zachary New to not be allowed by law and the terms of the
grant under which the funds where obtained from the Mississippi Department of Human
Services, all occurring within the jurisdiction of this court and in violation of Section 97-7-11,
Mississippi Code Annotated ( 1972, as amended).
COUNT XIX
m
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a.
on or about October 1, 2018 and continuing until December 31, 2019, willfully, unlawfully, and
feloniously with the intent to defraud the State of Mississippi enter into an agreement,
y
combination or conspiracy to defraud the State of Mississippi, or any department or political
la
subdivision thereof, by obtaining or aiding to obtain the payment or allowance from the
ba
public funds of the state, or of any department or political subdivision thereof, of any false or
fraudulent claim, To-wit: Nancy New, at a time when she was in the position of Executive
am
was in the position of Assistant Executive Director of the Mississippi Community
Education Center, while acting in agreement, combination and conspiracy with each
nj
other, and in combination, conspiracy, concert and/or aiding, and assisting John Davis and
so
others known and unknown to the grand jury, did with the intent to defraud the Mississippi
Department of Human Services knowingly and willfully submit false and fraudulent claims to
ck
the Mississippi Department of Human Services which documents intentionally, knowingly and
falsely sought and obtained payments of at least $2,150,000.00 of limited purpose public grant
Ja
funds which were criminally diverted, or used to replace limited purpose public grant funds
previously criminally diverted, to Prevacus Inc., and/or PresolMD, companies known by
Nancy New and Zachary New to be ineligible to receive such grant funds and for purposes of
the acquisition of an ownership interest is said companies by Nancy New and Zachary New
which was a purpose known by Nancy New and Zachary New to not be allowed by law and
the terms of the grant under which the funds where obtained from the Mississippi Department
of Human Services, all occurring within the jurisdiction of this court and in violation of Section
97-7-11, Mississippi Code Annotated ( 1972, as amended).
COUNT XX
Page 13 of 35
or about the week ofNovember 18, 2019, willfully, unlawfully, and feloniously with the intent to
defraud the State of Mississippi or any department, agency, office, or other subdivision of
the state or local government, knowingly and willfully made false, fictitious and
fraudulent statements or representations, or made or used any false writing or document
knowing that the same contained false, fictitious an fraudulent statements or entries, To-wit:
Nancy New, at a time when she was in the position of Executive Director of the
and while acting in concert and/or aiding, and assisting each other, John Davis, and others
m
Mississippi Community Education Center, did with the intent to defraud the Mississippi
Department of Human Services knowingly and willfully create, submit and deliver a document
co
entitled "Memorandum of Understanding Between Mississippi Community Education Center
and New Learning Resources, Inc.," bearing the forged signature of William R. Sutton, to the
a.
Mississippi Office Of State Auditor and intentionally, knowingly and falsely represented that
there existed a valid written agreement between Mississippi Community Education Center and
y
la
New Learning Resources, Inc., in relation to an illegal transfer of at least $700,000.00, limited
purpose public TANF grant funds to New Learning Resources, Inc., a company owned
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and/or controlled by Nancy New and Zachary New, when Nancy New and Zachary New
knew that the document was forged and false, that no such agreement existed, the described
am
- . -
program did not exist and that the forged document had been created after the fact to
fraudulently conceal the wrongful enrichment by unlawful criminal use of limited purpose public
TANF grant funds and to attempt to avoid each their personal accountability to the State of
nj
Mississippi for the funds criminally obtained and/or to continue to conceal their individual and
so
joint violations of the federal and state laws concerning TANF grants and/or the breach of
contractual grant obligations, all occurring within the jurisdiction of this court and in violation of
ck
Section 97-7-10, Mississippi Code Annotated (1972, as amended); and,

Ja
COUNT XXI
or about June 12, 2019, willfully, unlawfully, and feloniously with the intent to defraud the State
of Mississippi or any department, agency, office, board, commission, county, municipality or
other subdivision of the state or local government, knowingly and willfully made false,
fictitious and fraudulent statements or representations, or made or used any false writing or
document knowing that the same contained false, fictitious an fraudulent statements or entries,
To-wit: Nancy New, at a time when she was in the position of Executive Director of the
position of Assistant Executive Director
Page 14 of 35
of the Mississippi Community Education Center, and while acting in concert and/or aiding, and
assisting each other, Anne McGrew, John Davis and others known and unknown to the grand
jury, and during and after the time when the Mississippi Department of Human Services had
entrusted limited purpose public grant funds to Mississippi Community Education Center, did
with the intent to defraud the Mississippi Department of Human Services out of an additional
$7,600,000.00, knowingly and willfully submit documents entitled "Subgrant Modification
Signature Sheet," "Modification Budget Summary," "Modification Cost Summary Support
Sheets," "Budget Changes/Modification #3," "Modification of Subgrant" and ledgers and other
documents to the Mississippi Department of Human Services which documents intentionally,
knowingly and falsely represented that previously obtain funds had been lawfully expended to
appropriate ends in accordance with the terms and conditions of the subject grants when Nancy
New and Zachary New knew that such funds had not been lawfully expended to appropriate ends
in accordance with the terms and conditions of the subject grants and instead Nancy New and
m
Zachary New had wrongfully profited and wrongly enriched themselves, by the criminal
co
wrongful diversion of the entrusted limited purpose public grant funds to the payments of bribes
to John Davis, and to New Learning Resources, Inc., a company which they owned and/or
a.
controlled, and which was known Nancy New and Zachary New to be ineligible to receive such
grant funds and for purposes not allowed by the terms of the grant under which the funds were
y
entrusted and instead Nancy New and Zachary New had wrongfully profited and wrongly
la
enriched themselves, by the criminal wrongful diversion of the entrusted limited purpose public
ba
grant funds to Prevacus, Inc., and PresolMD, which companies were known by Nancy New and
Zachary New to be ineligible to receive such grant funds and for purposes not allowed by the
am
terms of the grants under which the funds were entrusted, all occurring within the jurisdiction of
and,
nj
so
COUNT XXII
ck
scheme and plan, said Nancy New, being a female human being above the age of eighteen
Ja
(18) years and Zachary New being a male human being above the age of eighteen (18) years,
did, on or about September 26, 2019, willfully, unlawfully, and feloniously with the intent to
defraud the State of Mississippi or any department, agency, office, board, commission, county,
municipality or other subdivision of the state or local government, knowingly and willfully
made false, fictitious and fraudulent statements or representations, or made or used any false
writing or document knowing that the same contained false, fictitious an fraudulent statements
or entries, To-wit: Nancy New, at a time when she was in the position of Executive Director
of the Mississippi Community Education Center, and Zachary New, at a time when he was in
the position of Assistant Executive Director of the Mississippi Community Education Center,
and while acting in concert and/or aiding, and assisting each other, Anne McGrew, John
Davis and others known and unknown to the grand jury, and during and after the time
when the Mississippi Department of Human Services had entrusted limited purpose public
grant funds to Mississippi Community Education
Page 15 of 35
Center, did with the intent to defraud the Mississippi Department of Human Services out of an
additional $4,822,992.01, knowingly and willfully submit documents entitled "Subgrant
Modification Signature Sheet," "Modification Budget Summary," "Modification Cost Summary
Support Sheets," "Budget Changes/Modification #4," "Modification of Subgrant" and ledgers to
the Mississippi Department of Human Services which intentionally, knowingly and falsely
represented that previously obtain funds had been lawfully expended to appropriate ends in
accordance with the terms and conditions of the subject grants when Nancy New and Zachary
New knew that such funds had not been lawfully expended to appropriate ends in accordance
with the terms and conditions of the subject grants and instead Nancy New and Zachary New had
wrongfully profited and wrongly enriched themselves, by the criminal wrongful diversion of the
entrusted limited purpose public grant funds to the payments of bribes to John Davis, and to New
Learning Resources, Inc., a company which they owned and/or controlled, and which was known
Nancy New and Zachary New to be ineligible to receive such grant funds and for purposes not
m
allowed by the terms of the grants under which the funds were entrusted and instead Nancy New
co
and Zachary New had wrongfully profited and wrongly enriched themselves, by the criminal
wrongful diversion of the entrusted limited purpose public grant funds to Prevacus, Inc., and
a.
PresolMD, which companies were known by Nancy New and Zachary New to be ineligible to
receive such grant funds and for purposes not allowed by the terms of the grants under which the
y
funds were entrusted, all occurring within the jurisdiction of this court and in violation of Section
la
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COUNT XXIII
am
nj
so
, or about October 31, 2019, willfully, unlawfully, and feloniously with the intent to defraud the
State of Mississippi or any department, agency, office, board, commission, county, municipality
ck
or other subdivision of the state or local government, knowingly and willfully made false,
fictitious and fraudulent statements or representations, or made or used any false writing or
Ja
document knowing that the same contained false, fictitious an fraudulent statements or entries,
To-wit: Nancy New, at a time when she was in the position of Executive Director of the
position of Assistant Executive Director of the Mississippi Community Education Center, and
while acting in concert and/or aiding, and assisting Anne McGrew, John Davis and others
Department of Human Services had entrusted limited purpose public grant funds to
Mississippi Community Education Center, did with the intent to defraud the Mississippi
Department of Human Services knowingly and willfully submit documents entitled "Subgrant
Expenditure Report For Period Ending September 30, 2019," and ledgers to the Mississippi
Department of Human Services which intentionally, knowingly and falsely represented that
previously obtain funds had been lawfully expended to appropriate ends in accordance with the
terms and conditions of the subject grants when Nancy New and Zachary
Page 16 of 35
New knew that such funds had not been lawfully expended to appropriate ends in accordance
with the terms and conditions of the subject grants and instead Nancy New and Zachary New had
wrongfully profited and wrongly enriched themselves, by the wrongful diversion of the entru~ted
limited purpose public grant funds to the payments of bribes to John Davis, and to New Learning
Resources, Inc., a company which they owned and/or controlled, and which was known Nancy
New and Zachary New to be ineligible to receive such grant funds and for purposes not allowed
by the terms of the grants under which the funds were entrusted and instead Nancy New and
wrongful diversion of the entrusted limited purpose public grant funds to Prevacus, Inc., and
PresolMD, which companies were known by Nancy New and Zachary New to be ineligible to
m
co
COUNT XXIV
a.
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la
did, on or about December 3, 2019, willfully, unlawfully, and feloniously with the intent to
ba
am
- -
nj
of the Mississippi Community Education Center, and Zachary New, at a time when he was in
so
the position of Assistant Executive Director of the Mississippi Community Education Center,
and while acting in concert and/or aiding, and assisting each other, Anne McGrew, John
ck
Davis and others known and unknown to the grand jury, and during and after the time
when the Mississippi Department of Human Services had entrusted limited purpose public
Ja
grant funds to Mississippi Community Education Center, did with the intent to defraud the
Mississippi Department of Human Services knowingly and willfully submit documents
entitled "Subgrant Expenditure Report For Period Ending November 30, 2019," and
ledgers to the Mississippi Department of Human Services which intentionally, knowingly
and falsely represented that previously obtain funds had been lawfully expended to appropriate
ends in accordance with the terms and conditions of the subject grants when Nancy New and
Zachary New knew that such funds had not been lawfully expended to appropriate ends in
accordance with the terms and conditions of the subject grants and instead Nancy New and
wrongful diversion of the entrusted limited purpose public grant funds to the payments of bribes
to John Davis, and to New Learning Resources, Inc., a company which they owned and/or
controlled, and which was known Nancy New and Zachary New to be ineligible to
Page 17 of 35
funds were entrusted and instead Nancy New and Zachary New had wrongfully profited and
wrongly enriched themselves, by the criminal wrongful diversion of the entrusted limited
purpose public grant funds to Prevacus, Inc., and PresolMD, which companies were known by
Nancy New and Zachary New to be ineligible to receive such grant funds and for purposes not
allowed by the terms of the grants under which the funds were entrusted, all occurring within the
jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated (1972,
as amended); and,
COUNT XXV
m
did, on or about December 20, 2019, willfully, unlawfully, and feloniously with the intent to
co
a.
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of the Mississippi Community Education Center, and while acting in concert and/or aiding,
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and assisting Zachary New, the Assistant Executive Director of the Mississippi Community
Education Center, and others known and unknown to the grand jury, -and during and after the
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time when the Mississippi Department of Human Services had entrusted limited purpose public
grant funds to Mississippi Community Education Center, did with the intent to defraud the
Mississippi Department of Human Services knowingly and willfully submit a document
nj
entitled "Certification of Subgrant Compliance" to the Mississippi Department of Human

so
Services which intentionally, knowingly and falsely represented that "all terms and
condition of said subgrant have been met" and other related documents close out documents
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submitted at the same time when Nancy New and Zachary New knew that the terms and
conditions of 2019 TANF Sub grants had not been met and the documents were false and
Ja
instead Nancy New and Zachary New had wrongfully profited and wrongly enriched
themselves, by the criminal wrongful diversion of the limited purpose public grant funds to
bribe John Davis, and to New Learning Resources, Inc., which company which they owned
and controlled, and which was known by Nancy New and Zachary New to be ineligible to
receive such grant funds and for purposes not allowed by the terms and conditions of the
grants under which the funds were entrusted and to Prevacus, Inc., and PresolMD, which
companies were know by Nancy New and Zachary New to be ineligible to receive such grant
funds and for purposes not allowed by the terms and conditions of the grants under which the
Page 18 of 35
COUNT XXVI
years, did, on or about and between February 20, 2019, and the February 4, 2020,
willfully, unlawfully, and feloniously with the intent to defraud the State of Mississippi or any
department, agency, office, board, commission, county, municipality or other subdivision of
the state or local government, knowingly and willfully falsified, concealed or covered up by
trick, scheme or device, material facts, To- wit: Nancy New and Zachery New, and others
known and unknown to the grand jury, did with the intent to defraud the Mississippi Department
of Human Services by knowingly and willfully conceal or cover up by trick, scheme or device
m
the material facts that they had bribed John Davis or otherwise fraudulent and unlawfully paid
Rise In Malibu using $160,000.00 in limited purpose public TANF Grant funds entrusted to
co
Mississippi Community Education Center by the Mississippi Department of Human Services,
all occurring within the jurisdiction of this court and in violation of Section 97-7-10,
a.
Mississippi Code Annotated (1972, as amended); and,
y
COUNT XXVII
la
ba
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years, did, on or about and between January 22, 2019, and October 7, 2019, willfully,
unlawfully, and feloniously with the intent to defraud the State of Mississippi or any
nj
department, agency, office, board, commission, county, municipality or other subdivision

so
of the state or local government, knowingly and willfully falsified, concealed or covered up
by trick, scheme or device, material facts, To- wit: Nancy New and Zachery New, and others
ck
known and unknown to the grand jury, did with the intent to defraud the Mississippi
Department of Human Services by having knowingly and willfully concealed or covered up
Ja
by trick, scheme or device the material facts that they had fraudulently and unlawfully
obtained and transferred $2,150,000.00 in limited purpose public TANF Grant funds entrusted
1 to Mississippi Community Education Center by the Mississippi Department of Human Services
to Prevacus, Inc., and PresolMD, which companies were known by Nancy New and Zachary
New to be ineligible to receive such grant funds and for purposes not allowed by the terms and
conditions of the grants under which the funds were entrusted, all occurring within the
jurisdiction of this court and in violation of Section 97-7-10, Mississippi Code Annotated
( 1972, as amended), all occurring within the jurisdiction of this court and in violation of
Section 97-7-10, Mississippi Code Annotated (1972, as amended); and,
COUNT XXVIII
Page 19 of 35
I
eighteen (18) years, and Zachary New being a male human being above the age of eighteen
(18) years, did, on or about and between January 22, 2019, and October 7, 2019, willfully,
unlawfully, and feloniously with the intent to defraud the State of Mississippi or any
department, agency, office, board, commission, county, municipality or other subdivision
of the state or local government, knowingly and willfully falsified, concealed or covered up
by trick, scheme or device, material facts, To- wit: Nancy New and Zachery New, and others
known and unknown to the grand jury, did with the intent to defraud the Mississippi
Department of Human Services by having knowingly and willfully concealed or covered up
by trick, scheme or device the material facts that they had fraudulently and unlawfully
obtained and transferred $1,656,000.00 in limited purpose public TANF Grant funds entrusted
to Mississippi Community Education Center by the Mississippi Department of Human Services
to New Learning Resource, Inc., a company known by Nancy New and Zachary New to be
m
ineligible to receive such grant funds and for purposes not allowed by the terms and
co
conditions of the grants under which the funds were entrusted, all occurring within the
a.
(1972, as amended), all occurring within the jurisdiction of this court and in violation of
Section 97-7-10, Mississippi Code Annotated ( 1972, as amended); and,
y
la
COUNT XXIX
ba
, based upon a series of acts connected together and constituting parts of a common
am
j -scheme and plan, said Nancy New, being a female human being above the age of eighteen (18)
· years and Zachary New being a male human being above the age of eighteen (18) years, did, on
or about February 11, 2019, in the county aforesaid and within the jurisdiction of this Court,
nj
willfully, unlawfully, and feloniously, while acting in concert and/or aiding, and assisting each
so
other, John Davis and others known and unknown to the grand jury, having devised or intending
to devise any scheme or artifice to defraud the State of Mississippi, or for obtaining
ck
money from the State of Mississippi or for unlawfully securing personal advantage by
means of false or fraudulent pretenses, representations or promises, did for the purpose of
Ja
executing such scheme or artifice or attempting so to do, transmitted or caused to be

transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves,
microwaves, or other means of communication or by person, any writings, signs, signals,
pictures, sounds, data, or other matter across county or state jurisdictional lines, to wit: on or
about February 11, 2019, Nancy New and Zachary New did transmit or cause to be
transmitted $40,000.00 by mail, telephone, newspaper, radio, television, wtre,
electromagnetic waves, microwaves, or other means of communication or by person, any
writings, signs, signals, pictures, sounds, data, or other matter across state jurisdictional
lines, of limited purpose grant funds entrusted to Mississippi Community Education
Center by the Mississippi Department of Human Services from a bank account controlled
by Nancy New and Zachary New, being Regions Bank Account Number ******7729, into a
bank account owned by Rise In Malibu, Wells Fargo Bank NA, (San Francisco, California) Bank
Account Number *****0248, for the purpose of executing a scheme or artifice or
Page 20 of 35
attempting so to do, to defraud the State of Mississippi by false claims for limited purpose public
grant funds and the concealment of the unlawful and fraudulent diversion of limited purpose
public grant funds to Rise In Malibu, a company known to be ineligible to receive such grant
funds and the transfer was for the wrongful, criminally fraudulent and unlawful purposes of
using the said limited purpose grant funds for the personal advantage of Nancy New and Zachary
New gained by the bribery of a public official John Davis, Executive Director of the Mississippi
Department of Human Services, as part of a scheme to defraud and the defrauding of the
Mississippi Department of Human Services, all accomplished by means of false or fraudulent
pretenses, representations or promises, and for the purpose of executing such scheme or artifice
to defraud the Mississippi Department of Human Service and to bribe John Davis, or attempting
so to do, all occurring within the jurisdiction of this court and in violation of Section 97-19-83,
Mississippi Code Annotated ( 1972, as amended); and,
m
COUNT XXX
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a.
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la
did, on or about March 8, 2019, in the county aforesaid and within the jurisdiction of this Court,
ba
other, John Davis and others known and unknown to the grand jury, having devised or
intending to devise any scheme or artifice to defraud the State of Mississippi, or for obtaining
am
- --
means of false or fraudulent pretenses, representations or promises, did for the purpose
of executing such scheme or artifice or attempting so to do, transmitted or caused to be
nj

so

ck
about March 8, 2019, Nancy New and Zachary New did transmit or cause to be transmitted
$40,000.00 by mail, telephone, newspaper, radio, television, wire, electromagnetic waves,
Ja

pictures, sounds, data, or other matter across state jurisdictional lines, of limited purpose grant
funds entrusted to Mississippi Community Education Center by the Mississippi
Department of Human Services from a bank account controlled by Nancy New and Zachary
New, being Regions Bank Account Number ******7729, into a bank account owned by Rise In
Malibu, Wells Fargo Bank NA, (San Francisco, California) Bank Account Number
*****0248, for the purpose of executing a scheme or artifice or attempting so to do, to defraud
the State of Mississippi by false claims for limited purpose public grant funds and the
concealment of and the unlawful and fraudulent diversion of limited purpose public grant funds
to Rise In Malibu, a company known to be ineligible to receive such grant funds and the transfer
was for the wrongful, criminally fraudulent and unlawful purposes of using the said limited
purpose grant funds for the personal advantage of Nancy New and Zachary New gained by the
bribery of a public official John Davis, Executive Director of the Mississippi Department of
Page 21 of 35
Human Services, as part of a scheme to defraud and the defrauding of the Mississippi
Department of Human Services, all accomplished by means of false or fraudulent pretenses,
representations or promises, and for the purpose of executing such scheme or artifice to defraud
the Mississippi Department of Human Service and to bribe John Davis, or attempting so to do,
all occurring within the jurisdiction of this court and in violation of Section 97-19-83,
COUNT XXXI
m
did, on or about April 8, 2019, in the county aforesaid and within the jurisdiction of this Court,
co
a.
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la
ba
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about April 8, 2019, Nancy New and Zachary New did transmit or cause to be transmitted
nj
so

ck
New, being Regions Bank Account Number ******7729, into a bank account owned by Rise In
Malibu, Wells Fargo Bank NA, San Francisco, California Bank Account Number
Ja
*****0248, for the purpose of executing a scheme or artifice or attempting so to do, to defraud
concealment of the unlawful and fraudulent diversion of limited purpose public grant funds to
Rise In Malibu, a company known to be ineligible to receive such grant funds and the transfer
was for the wrongful, criminally fraudulent and unlawful purposes of using the said limited
purpose grant funds for personal advantage of Nancy New and Zachary New by the bribery of a
public official John Davis, Executive Director of the Mississippi Department of Human Services,
as part of a scheme to defraud and the defrauding of the Mississippi Department of Human
Services, all accomplished by means of false or fraudulent pretenses, representations or
promises, and for the purpose of executing such scheme or artifice to defraud the Mississippi
Department of Human Service and to bribe John Davis, or attempting so to do, all occurring
Page 22 of 35
COUNT XXXII
or about June 13, 2019, in the county aforesaid and within the jurisdiction of this Court, willfully,
unlawfully, and feloniously, while acting in concert and/or aiding, and assisting Zachary New,
John Davis and others known and unknown to the grand jury, having devised or intending to
devise any scheme or artifice to defraud the State of Mississippi, or for obtaining money
from the State of Mississippi or for unlawfully securing personal advantage by means of
false or fraudulent pretenses, representations or promises, did for the purpose of executing
such scheme or artifice or attempting so to do, transmitted or caused to be transmitted by
m
mail, telephone, newspaper, radio, television, wire, electromagnetic waves, microwaves, or other
means of communication or by person, any writings, signs, signals, pictures, sounds, data, or
co
other matter across county or state jurisdictional lines, to wit: on or about June 13, 2019, Nancy
New did transmit or cause to be transmitted $40,000.00 by mail, telephone, newspaper, radio,
a.
television, wire, electromagnetic waves, microwaves, or other means of communication or by
y
person, any writings, signs, signals, pictures, sounds, data, or other matter across state
la
jurisdictional lines, of limited purpose grant funds entrusted to Mississippi Community
Education Center by the Mississippi Department of Human Services from a bank account
ba
controlled by Nancy New and Zachary New, being Regions Bank Account Number
******7729, into a bank account owned by Rise In Malibu, Wells Fargo Bank NA, San
am
Francisco, California Bank Account Number *****0248, for the purpose of executing a
scheme or artifice or attempting so to do, to defraud the State of Mississippi by false
claims for limited purpose public grant funds and the concealment of the unlawful and
nj
fraudulent diversion of limited purpose public grant funds to Rise In Malibu, a company
so
known to be ineligible to receive such grant funds and the transfer was for the wrongful,
criminally fraudulent and unlawful purposes of using the said limited purpose grant funds for
ck
personal advantage of Nancy New and Zachary New by the bribery of a public official John
Davis, Executive Director of the Mississippi Department of Human Services, as part of a
Ja
scheme to defraud and the defrauding of the Mississippi Department of Human Services, all
accomplished by means of false or fraudulent pretenses, representations or promises, and for the
purpose of executing such scheme or artifice to defraud the Mississippi Department of Human
Service and to bribe John Davis, or attempting so to do, all occurring within the jurisdiction of
this court and in violation of Section 97-19-83, Mississippi Code Annotated ( 1972, as amended);
and,
COUNT XXXIII
on or about January
Page 23 of 35
22, 2019, in the county aforesaid and within the jurisdiction of this Court, willfully, unlawfully,
and feloniously, while acting in concert and/or aiding, and assisting each other, John Davis and
others known and unknown to the grand jury, having devised or intending to devise any scheme
or artifice to defraud the State of Mississippi, or for obtaining money from the State of
Mississippi or for unlawfully securing personal advantage by means of false or fraudulent
pretenses, representations or promises, did for the purpose of executing such scheme or artifice
or attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper,
radio, television, wire, electromagnetic waves, microwaves, or other means of communication or
by person, any writings, signs, signals, pictures, sounds, data, or other matter across county or
state jurisdictional lines, to wit: on or about January 22, 2019, Nancy New and Zachary New did
transmit or cause to be transmitted $750,000.00 by mail, telephone, newspaper, radio, television,
wire, electromagnetic waves, microwaves, or other means of communication or by person, any
m
writings, signs, signals, pictures, sounds, data, or other matter across state jurisdictional lines, of
limited purpose grant funds entrusted to Mississippi Community Education Center by the
co
Mississippi Department of Human Services, from Mississippi Community Education
Center bank account, Regions Bank Account Number ******7729, to an account controlled by
a.
Nancy New and Zachary New in the name of New Learning Resources, Inc.,
Regions Bank (Mississippi) Account Number ******1079 and in tum mailed a check for
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$750,000.00, check number 8307, payable from Account ******1079 to Prevacus, Inc., in
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Florida, which deposited said $750,000.00 check in Prevacus, Inc., Suntrust Bank
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(Florida) Account Number ******7709, for the purpose of executing a scheme or artifice
or attempting so to go, to defraud the State of Mississippi by false claims for limited purpose
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public grant funds and the concealment of the unlawful and fraudulent diversion of limited
purpose public grant funds to Prevacus, Inc., a company known to be ineligible to receive
such grant funds and the transfer was for the wrongful, criminal fraudulent and unlawful
nj
purposes of using the said limited purpose grant funds for personal advantage by the
so
acquisition by Nancy New and Zachery New and others of an ownership interest in Prevacus,
Inc., all accomplished by means of false or fraudulent pretenses, representations or promises,
ck
and for the purpose of executing such scheme or artifice to defraud the Mississippi Department
of Human Service, or attempting so to do, all occurring within the jurisdiction of this court
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and in violation of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and,
COUNT XXXIV
did, on or about April 8, 2019, in the county aforesaid and within the jurisdiction of this
Court, willfully, unlawfully, and feloniously, while acting in concert and/or aiding, and assisting
each other, John Davis and others known and unknown to the grand jury, having devised
or intending to devise any scheme or artifice to defraud the State of Mississippi, or for
obtaining money from the State of Mississippi or for unlawfully securing personal
advantage by means of false or fraudulent pretenses,
Page 24 of 35
representations or promises, did for the purpose of executing such scheme or artifice or
attempting so to do, transmitted or caused to be transmitted by mail, telephone, newspaper, radio,
television, wire, electromagnetic waves, microwaves, or other means of communication or by
person, any writings, signs, signals, pictures, sounds, data, or other matter across county or state
jurisdictional lines, to wit: on or about April 8, 2019, Nancy New and Zachary New did transmit
or cause to be transmitted $500,000.00 by mail, telephone, newspaper, radio, television, wire,
writings, signs, signals, pictures, sounds, data, or other matter across state jurisdictional lines, of
Mississippi Department of Human Services from a bank account controlled by Nancy New and
Zachary New, being Regions Bank (Mississippi) Account Number ******7729, into a bank
account owned by Prevacus, Inc., Suntrust Bank (Florida) Account Number ********7709, for
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the purpose of executing a scheme or artifice or attempting so to do, to defraud the State of
Mississippi by false claims for limited purpose public grant funds and the concealment of the
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unlawful and fraudulent diversion of limited purpose public grant funds to Prevacus, Inc., a
company known to be ineligible to receive such grant funds and the transfer was for the
a.
wrongful, fraudulent and unlawful purposes of using the said limited purpose grant funds for
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personal advantage by the acquisition by Nancy New and Zachery New and others of an
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ownership interest in Prevacus, Inc., all accomplished by means of false or fraudulent pretenses,
representations or promises, and for the purpose of executing such scheme or artifice to defraud
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the Mississippi Department of Human Service, or attempting so to do, all occurring within the
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(1972, as amended); and, ·
COUNT XXXV
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did, on or about May 10, 2019, in the county aforesaid and within the jurisdiction of this Court,
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about May 10, 2019, Nancy New and Zachary New did transmit or cause to be transmitted
pictures, sounds, data, or other matter across state jurisdictional lines, of
Page 25 of 35
Mississippi Department of Human Services from a bank account controlled by Nancy New and
Zachary New, being Regions Bank (Mississippi) Account Number ******7729, into a bank
account owned by Prevacus, Inc., Suntrust Bank (Florida) Account Number *********7709, for
the purpose of executing a scheme or artifice or attempting so to do, to defraud the State of
wrongful, criminally fraudulent and unlawful purposes of using the said limited purpose grant
funds for personal advantage by the acquisition by Nancy New and Zachery New and others of
an ownership interest in Prevacus, Inc., all accomplished by means of false or fraudulent
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to defraud the Mississippi Department of Human Service, or attempting so to do, all occurring
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a.
COUNT XXXVI
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did, on or about July 16,2019, in the county aforesaid and within the jurisdiction of this Court,
am
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' means of false or fraudulent pretenses, representations or promises, did for the purpose
ck

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about July 16, 2019, Nancy New and Zachary New did transmit or cause to be transmitted
New, being Regions Bank (Mississippi) Account Number ******7729, into a bank account
owned by Prevacus, Inc., Suntrust Bank (Florida) Account Number ********7709, for the
purpose of executing a scheme or artifice or attempting so to do, to defraud the State of
Page 26 of 35
wrongful, criminally fraudulent and unlawful purposes of using the said limited purpose grant
funds for personal advantage by the acquisition by Nancy New and Zachery New and others of
an ownership interest in Prevacus, Inc., all accomplished by means of false or fraudulent
to defraud the Mississippi Department of Human Service, or attempting so to do, all occurring
COUNT XXXVII
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did, on or about September 24, 2019, in the county aforesaid and within the jurisdiction of
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this Court, willfully, unlawfully, and feloniously, while acting in concert and/or aiding, and
assisting each other, John Davis and others known and unknown to the grand jury, having
a.
devised or intending to devise any scheme or artifice to defraud the State of Mississippi, or for
obtaining money from the State of Mississippi or for unlawfully securing personal advantage
y
by means of false or fraudulent pretenses, representations or promises, did for the purpose of
la
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about September 24, 2019, Nancy New and Zachary New did transmit or cause to be
transmitted $100,000.00 by mail, telephone, newspaper, radio, television, wire,
nj

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writings, signs, signals, pictures, sounds, data, or other matter across state jurisdictional
lines, of limited purpose grant funds entrusted to Mississippi Community Education
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Center by the Mississippi Department of Human Services from a bank account controlled
by Nancy New and Zachary New, being Regions Bank (Mississippi) Account Number
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******7729, into a bank account owned by PresolMD, Suntrust Bank (Florida) Account Number
*******9424, for the purpose of executing a scheme or artifice or attempting so to do, to defraud
concealment of the unlawful and fraudulent diversion of limited purpose public grant funds to
Prevacus, Inc. and/or PresolMD, companies known to be ineligible to receive such grant funds
and the transfer was for the wrongful, criminally fraudulent and unlawful purposes of using the
said limited purpose grant funds for personal advantage by the acquisition by Nancy New and
Zachery New and others of an ownership interest in Prevacus, Inc. and/or PresolMD, all
accomplished by means of false or fraudulent pretenses, representations or promises, and for the
purpose of executing such scheme or artifice to defraud the Mississippi Department of Human
Service, or attempting so to do, all occurring within the jurisdiction of this court and in violation
of Section 97-19-83, Mississippi Code Annotated (1972, as amended); and,
Page 27 of 35
COUNT XXXVIII
years and Zachary New being a male human being above the age of eighteen ( 18) years, did, on
or about October 7, 2019, in the county aforesaid and within the jurisdiction of this Court,
other, John Davis and others known and unknown to the grand jury, having devised or intending
to devise any scheme or artifice to defraud the State of Mississippi, or for obtaining
means of false or fraudulent pretenses, representations or promises, did for the purpose of
m
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about October 7, 20 19, Nancy New and Zachary New did transmit or cause to be transmitted
a.
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New, being Regions Bank (Mississippi) Account Number ******7729, into a bank account
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owned by PresolMD; Suntrust Bank (Florida) Account Number ********9424, for the purpose
of executing a scheme or artifice or attempting so to do, to defraud the State of
nj
unlawful and fraudulent diversion of limited purpose public grant funds to Prevacus, Inc. and/or
so
PresolMD, companies known to be ineligible to receive such grant funds and the transfer was for
the wrongful, criminally fraudulent and unlawful purposes of using the said limited purpose
ck
grant funds for personal advantage by the acquisition by Nancy New and Zachery New and
others of an ownership interest in Prevacus, Inc. and/or PresolMD, all accomplished by means of
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false or fraudulent pretenses, representations or promises, and for the purpose of executing such
scheme or artifice to defraud the Mississippi Department of Human Service, or attempting so to
do, all occurring within the jurisdiction of this court and in violation of Section 97-19-83,
COUNT XXXIX
between October 1, 2018 and June 12, 2019, with intent to defraud the State of Mississippi
made false entries, or falsely altered entries made in any book of accounts kept by a
corporation or its officers, which
Page 28 of 35
book of accounts was delivered or intended to be delivered to any person dealing with such
corporation, by which any pecuniary obligation, claim, or credit shall be or shall purport to be
discharged, diminished, increased, created, or in any manner affected, to wit: between October 1,
2018 and June 11, 2019, Nancy New, at a time when she was in the position of Executive
Director of the Mississippi Community Education Center, a non-profit corporation, and Zachary
New, at a time when he was in the position of Assistant Executive Director of the Mississippi
Community Education Center and while acting in concert and/or aiding, and assisting each other,
Anne McGrew, John Davis, and others known and unknown to the grand jury, and during and
after the time when the Mississippi Department of Human Services had entrusted limited
purpose public grant funds to Mississippi Community Education Center, did with the intent to
defraud the Mississippi Department of Human Services knowingly and willfully make false
entries or falsely altered entries made in the books of account, including budgets, Quickbook
m
records and Ledgers kept by Mississippi Community Education Center, a non-profit corporation,
or an officer thereof, namely budgets, Quickbook records and Ledgers periodically delivered on
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more than two (2) occasions, or intended to be delivered to the Mississippi Department of
Human Services and its employees being persons dealing with Mississippi Community
a.
Education Center by which the pecuniary obligation of Mississippi Community Education
y
Center and Nancy New, the claims of Mississippi Community Education Center, or credit of
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Mississippi Community Education Center, was or was purported to be discharged, diminished,
increased, created, or in any manner affected, namely that limited purpose public TANF Grant
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funds were needed and budgeted to be expended by Mississippi Community Education Center in
discharge of its obligations and the obligations ofNancy New under the terms of the 2019 TANF
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Grants obtained by Mississippi Community Education Center and that limited purpose public
TANF Grant funds had been expended by Mississippi Community Education Center in discharge
nj
of its obligations and the obligations of Nancy New under the terms of the 2019 TANF Grants
obtained by Mississippi Community Education Center when in truth and fact the sums sought
so
were intended by Nancy New and Zachary New to be, and were in fact, expended on bribes to a
public official and unlawful transfers to New Learning Resources, Inc., Prevacus Inc., and
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PresolMD, all occurring within the jurisdiction ofthis court and in violation of Section 97-21-3,
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COUNT XL
between June 12, 2019 and February 4, 2020, with intent to defraud the State of Mississippi
• made false entries, or falsely altered entries made in any book of accounts kept by a
• corporation or its officers, which book of accounts was delivered or intended to be delivered
to any person dealing with such corporation, by which any pecuniary obligation, claim, or
credit shall be or shall purport to be discharged, diminished, increased, created, or in any
manner affected, to wit: between June 12, 2019 and February 4, 2020, Nancy New, at a time
when she was in the position of Executive
Page 29 of 35
Director of the Mississippi Community Education Center, a non-profit corporation, and Zachary
New, at a time when he was in the position of Assistant Executive Director of the Mississippi
Community Education Center and while acting in concert and/or aiding, and assisting each other,
Anne McGrew, John Davis, and others known and unknown to the grand jury, and during and
after the time when the Mississippi Department of Human Services had entrusted limited
purpose public grant funds to Mississippi Community Education Center, did with the intent to
defraud the Mississippi Department of Human Services knowingly and willfully make false
entries or falsely altered entries made in the books of account, including budgets, Quickbook
records and Ledgers kept by Mississippi Community Education Center, a non-profit corporation,
or an officer thereof, namely the budgets, Quickbook records and General Ledgers periodically
delivered on more than two (2) occasions, or intended to be delivered to the Mississippi
Department of Human Services and Mississippi Office of State Auditor and those agencies
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employees being persons dealing with Mississippi Community Education Center and creation or
a false debit or credit in relation to the document entitled "Memorandum of Understanding
co
Between Mississippi Community Education Center and New Learning Resources, Inc.," bearing
the forged signature of William R. Sutton, presented to the Mississippi Office Of State Auditor
a.
by which the pecuniary obligation of Mississippi Community Education Center and Nancy New,
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the claims of Mississippi Community Education Center, or credit of Mississippi Community
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Education Center, was or was purported to be discharged, diminished, increased, created, or in
any manner affected, namely that limited purpose public TANF Grant funds were needed and
ba
budgeted to be expended by Mississippi Community Education Center in discharge of its
obligations and the obligations of Nancy New under the terms of the 2019 TANF Grants
am
obtained by Mississippi Community Education Center and that limited purpose public TANF
Grant funds had been expended by Mississippi Community Education Center in discharge of its
obligations and the obligations of Nancy New under the terms of the 2019 TANF Grants
nj
obtained by Mississippi Community Education Center when in truth and fact the sums sought
so
were intended by Nancy New and Zachary New to be, and were in fact, expended on bribes to a
public official and unlawful transfers to New Learning Resources, Inc., Prevacus Inc., and
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PresolMD, all occurring within the jurisdiction of this court and in violation of Section 97-21-3,
Mississippi Code Annotated ( 1972, as amended); and,
Ja
COUNT XLI
between September 1, 2018 and February 4, 2020, with criminal intent received proceeds
derived, directly or indirectly, from a pattern of racketeering activity to use or invest, whether
directly or indirectly, any part of such proceeds or the proceeds derived from the investment
i or use thereof, in the acquisition of any title to, or any right, interest, or equity in, the
establishment or operation of any enterprise, to wit: Nancy New and Zachary New engaged
in racketeering activities by at least two (2) incidents with the same or similar intents, results,
accomplices, victims, or methods
Page 30 of 35
of commission or otherwise are interrelated by distinguishing characteristics and are not isolated
! incidents, by each committing, attempting to commit, conspiring to commit any crime which is
chargeable under Miss. Code §97-21-3 (forgery and falsification of books of account of
Mississippi Community Education Center) or by each having solicited, coerced or intimidated
each other, and another person or persons, including Anne McGrew, to commit any crime which
is chargeable under Miss. Code §97-21-3 (forgery and falsification of books of account of
Mississippi Community Education Center), and Nancy New and Zachary New, each with
criminal intent, did receive proceeds derived, directly or indirectly, from the pattern of
racketeering activity and thereafter use or invest, directly or indirectly, any part of such proceeds
or the proceeds derived from the investment or use thereof, in the operation of several
enterprises, namely and the enterprise of the association or group of individuals made up of
Nancy New, Zachary New, Anne McGrew, and John Davis, and the enterprise of Mississippi
m
Community Education Center and the enterprise of New Learning Resources, Inc., all occurring
within the jurisdiction of this court and in violation of Section 97 -43-5(1 ), Mississippi Code
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a.
COUNT XLII
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or use thereof, in the acquisition of any title to, or any right, interest, or equity in, the
nj
establishment or operation of any enterprise, to wit: Nancy New and Zachery New each
so
engaged in racketeering activities by at least two (2) incidents with the same or similar
intents, results, accomplices, victims, or methods of commission or otherwise are interrelated
ck
by distinguishing characteristics and are not isolated incidents, by each committing, attempting
to commit, conspiring to commit any crime which is chargeable under Miss. Code §97-21-3
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(forgery and falsification of books of account of Mississippi Community Education Center) or

by each of them having solicited, coerced or intimidated each other, and another person or
persons, including Anne McGrew, to commit any crime which is chargeable under Miss.
Code §97-21-3 (forgery and falsification of books of account of Mississippi Community
Education Center), and Nancy New and Zachary New, each with criminal intent, did through a
pattern of racketeering activity acquired, directly or indirectly, an interest in enterprises known
: as Prevacus Inc., and PresolMD, all occurring within the jurisdiction of this court and in
: violation of Section 97-43-5(2), Mississippi Code Annotated (1972, as amended); and,
COUNT XLIII
Page 31 of 35
or use thereof, in the acquisition of any title to, or any right, interest, or equity in, the
establishment or operation of any enterprise, to wit: Nancy New and Zachary New each
engaged in racketeering activities by at least two (2) incidents with the same or similar
intents, results, accomplices, victims, or methods of commission or otherwise are interrelated
by distinguishing characteristics and are not isolated incidents, by each committing, attempting
to commit, conspiring to commit any crime which is chargeable under Miss. Code §97-21-3
(forgery and falsification of books of account of Mississippi Community Education Center) or
by each having solicited, coerced or intimidated each other and another person or persons,
m
including Anne McGrew, to commit any crime which is chargeable under Miss. Code
co
§97-21-3 (forgery and falsification of books of account of Mississippi Community
Education Center), and Nancy New and Zachary New, each being a person employed by, or
a.
associated with, the following enterprises: the association or group of individuals made up of
Nancy New, Zachary New, Anne McGrew, and John Davis, the enterprise of Mississippi
y
Community education Center and the enterprise of New Learning Resources, Inc., Nancy New
la
and Zachary New willfully, knowingly and each with criminal intent, did conduct or participate,
ba
directly or indirectly, in such enterprises through a pattern of racketeering activity as described
above, all occurring within the jurisdiction of this court and in violation of Section
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97-43-5(3), Mississippi Code Annotated (1972, as amended); and,·
COUNT XLIV
nj
so
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between September 1, 2018 and February 4, 2020, conspired with others to violate each
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of the provisions of subsections (1), (2) or (3) of Miss. Code §97-43-5, to wit: Nancy
: New and Zachary New conspired with each other and Anne McGrew and John Davis and other
· known and unknown to the Grand Jury, to violate subsections (1), (2) or (3) of Miss. Code
§97-43-5, by:
between September 1, 2018 and February 4, 2020, Nancy New and Zachary New each with
criminal intent received proceeds derived, directly or indirectly, from a pattern of racketeering
activity to use or invest, whether directly or indirectly, any part of such proceeds or the proceeds
derived from the investment or use thereof, in the acquisition of any title to, or any right, interest,
or equity in, the establishment or operation of any enterprise, to wit: Nancy New and Zachary
New engaged in racketeering activity by at least two (2) incidents with the same or similar
intents, results, accomplices, victims, or methods of commission or otherwise are interrelated by
distinguishing characteristics and are not isolated incidents, by herself committing, attempting to
Page 32 of 35
commit, conspmng to commit any crime which is chargeable under Miss. Code §97-21-3
(forgery or falsification of books of account of Mississippi Community Education Center) or by
each having solicited, coerced or intimidated each other, another person or persons, including
Anne McGrew, to commit any crime which is chargeable under Miss. Code §97-21-3 (forgery or
falsification of books of account of Mississippi Community Education Center), and Nancy New
and Zachary New, each with criminal intent, did receive proceeds derived, directly or indirectly,
from the pattern of racketeering activity and thereafter use or invest, directly or indirectly, any
part of such proceeds or the proceeds derived from the investment or use thereof, in the operation
of several enterprises, namely and the enterprise of the association or group of individuals made
up of Nancy New, Zachary New, Anne McGrew, and John Davis, and the enterprise of
Mississippi Community Education Center and the enterprise of New Learning Resources,
Inc., all occurring within the jurisdiction of this court and in Miss. Code §97-43-5(1 ); and/or
m
co
directly or indirectly, any part of such proceeds or the proceeds derived from the investment or
a.
use thereof, in the acquisition of any title to, or any right, interest, or equity in, the establishment
or operation of any enterprise, to wit: Nancy New and Zachery New each engaged in
y
racketeering activity by at least two (2) incidents with the same or similar intents, results,
la
accomplices, victims, or methods of commission or otherwise are interrelated by distinguishing
ba
characteristics and are not isolated incidents, by each committing, attempting to commit,
: conspiring to commit any crime which is chargeable under Miss. Code §97-21-3 (forgery and
am
i
1 falsification of books of account of Mississippi Community Education Center) or by each of
them having solicited, coerced or intimidated each other, another person or persons, including
Anne McGrew, to commit any crime which is chargeable under Miss. Code §97-21-3 (forgery
nj
and falsification of books of account of Mississippi Community Education Center), and Nancy
so
New and Zachary New, each with criminal intent, did through a pattern of racketeering activity
acquired, directly or indirectly, an interest in enterprises known as Prevacus Inc., and PresolMD,
ck
all occurring within the jurisdiction of this court and in violation of Miss. Code §97 -43-5(2); and/
or
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between September I, 2018 and February 4, 2020, with criminal intent received
proceeds derived, directly or indirectly, from a pattern of racketeering activity to use or
'invest, whether directly or indirectly, any part of such proceeds or the proceeds derived from
the investment or use thereof, in the acquisition of any title to, or any right, interest, or equity in,
! the establishment or operation of any enterprise, to wit: Nancy New and Zachary New
each engaged in racketeering activity by at least two (2) incidents with the same or
similar intents, results, accomplices, victims, or methods of commission or otherwise are
interrelated by distinguishing characteristics and are not isolated incidents, by each
committing, attempting to commit, conspiring to commit any crime which is chargeable
under Miss. Code §97-21-3 (forgery and falsification of books of account of Mississippi
Community Education Center) or by each having solicited, coerced or intimidated each other,
another person or persons, including Anne McGrew, to commit any crime which is chargeable
under Miss. Code §97-21-3 (forgery and falsification
Page 33 of 35
of books of account of Mississippi Community Education Center), and Nancy New and Zachary
New, each being a person employed by, or associated with, the following enterprises: the
association or group of individuals made up of Nancy New, Zachary New, Anne McGrew, and
John Davis, the enterprise of Mississippi Community education Center and the enterprise ofNew
Learning Resources, Inc., Nancy New and Zachary New willfully, knowingly and each with
criminal intent, did conduct or participate, directly or indirectly, in such enterprises through a
pattern of racketeering activity as described above, all occurring within the jurisdiction of this
court and in violation of Miss. Code §97-43-5(3); and
COUNT LXV
m
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between September 1, 2018 and February 4, 2020, did conduct, organize, supervise or manage,
directly or indirectly, an organized theft or fraud enterprise in violation of Miss. Code
a.
§97-43-3.1(1), to wit: Nancy New and Zachery New, between September 1, 2018 and February
4, 2020, did conduct, organize, supervise or manage, directly or indirectly, an association of
y
two (2) or more persons who engaged in the conduct of or are associated for the purpose of
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effectuating the transfer or sale of services or information acting as a subgrantee for TANF
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funds granted to State of Mississippi and its Mississippi Department of Human Services that had
a pecuniary value that causes a loss to a victim, being the State of Mississippi and its
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Mississippi Department of Human Services, and which conduct, organization, supervision or

management involved the fraud enterprise engaging in repeated violations of Miss. Code
§97-19-83, by transmitting money obtained by criminal fraud and forgery across state lines to
nj
Rise In Malibu in California and Prevacus Inc., and PresolMD in Florida, all occurring within
so
the jurisdiction of this court and in violation of Miss. Code §97-43-3.1(1); and
ck
COUNT LXVI
Ja
', years, and Zachary New being a male human being above the age of eighteen (18) years, did,
between September 1, 2018 and February 4, 2020, with criminal intent, receive proceeds or
services derived, directly or indirectly, from an organized theft or fraud enterprise in
violation of Miss. Code §97-43-3.1(2), to wit: Nancy New and Zachery New, between
September 1, 2018 and February 4, 2020, did with criminal intent, receive proceeds or
services derived, directly or indirectly, from an association of two (2) or more persons who
engaged in the conduct of or are associated for the purpose of effectuating the transfer or
sale of services or information acting as a subgrantee for TANF funds granted to State of
Mississippi and its Mississippi Department of Human Services that had a pecuniary value
that causes a loss to a victim, being the State of
Page 34 of 35
Mississippi and its Mississippi Department of Human Services, and which fraud enterprise
engaged in repeated violations of Miss. Code §97-19-83, by transmitting money obtained by
criminal fraud and forgery across state lines to Rise In Malibu in California and Prevacus Inc.,
and PresolMD in Florida, all occurring within the jurisdiction of this court and in violation of
Miss. Code §97-43-3.1(2)); and,
All of the above, Count I through Count LXVIII, inclusive of all Counts between, being contrary
to the form of the statute in such cases made and provided, and against the peace and dignity of
the State of Mississippi.
Endorsed: A True Bill
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Foreman of the Grand Jury
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Page 35 of 35

1 Indictment 1 WM

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Case: 25CI1:22-cr-00002-EFP Document #: 1 Filed: 01/13/2022 Page 1 of 35

INDICTMENT Defendant Nancy New CIRCUIT COURT NO. ~-l

Defendant Zachary New

Nancy New and Zachary New, Co-Defendants

In said District, County and State

$750,000.00 check in Prevacus, Inc., Suntrust Bank Account Number ********7709, a

Director of the Mississippi Community Education Center, a private non-profit entity

an inducement or incentive of awarding a contract modification by the Mississippi

an inducement or incentive for the accomplishment of any official act or purpose

of value as a bribe or an inducement or incentive for the awarding or refusal to award a

Mississippi Department of Human Services money, property, or other tangible or intangible

Section 97-7-10, Mississippi Code Annotated (1972, as amended); and,

entitled "Certification of Subgrant Compliance" to the Mississippi Department of Human

department, agency, office, board, commission, county, municipality or other subdivision

executing such scheme or artifice or attempting so to do, transmitted or caused to be

transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves,

microwaves, or other means of communication or by person, any writings, signs, signals,

microwaves, or other means of communication or by person, any writings, signs, signals,

funds entrusted to Mississippi Community Education Center by the Mississippi

(1972, as amended); and, ·

transmitted by mail, telephone, newspaper, radio, television, wire, electromagnetic waves,

electromagnetic waves, microwaves, or other means of communication or by person, any

(forgery and falsification of books of account of Mississippi Community Education Center) or

97-43-5(3), Mississippi Code Annotated (1972, as amended); and,·

Mississippi Department of Human Services, and which conduct, organization, supervision or

Endorsed: A True Bill

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