FILED:.2°2 t1A.Y '14 0'7:151JSDC-ORP 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

UNDER SEAL 

UNITED STATES OF AMERICA, 

Case No.3'. J 4- Cr- OQ;:;i08-lt/\-

v. 

SAVANNAH GARMON, LUKE 

ELLETT, CLARVETTA LARRY, and 

DONTAE PANKEY, 

Defendants. 

THE GRAND JURY CHARGES: 

INTRODUCTION 

At all times relevant to this Indictment: 

INDICTMENT 

18 u.s.c. §§ 2, 286, 641 

1028A, 981 (a)(l)(C) 

and 28 U.S.C. § 2461(c) 

1. Defendant SAVANNAH GARMON is the sister of defendant LUKE ELLETT 

and the mother of defendants CLARVETTA LARRY and DONTAE PANKEY. 

2. "GLW" is an unemployed resident of Portland, Oregon, who has filed no income 

tax returns. 

3. "GAP" is an unemployed resident of Portland, Oregon, who has filed no income 

tax returns. 

4. The Internal Revenue Service (IRS) is an agency of the United States Department 

of the Treasury and is responsible for enforcing and administering the tax laws of the United 

States, collecting taxes owed to the United States, and issuing refunds for excessive tax 

payments. 

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5. IRS Form 1040EZ Income Tax Return for Single and Joint Filers With No 

Dependents ("Form 1040EZ") is a simplified version of the IRS Form 1040 Income Tax Return. 

Filing a Form 1040EZ that shows the taxpayer's withholdings for the year exceeding his or her 

total tax liability for that year constitutes a claim for a refund of the excessive withholdings. 

6. In the ordinary course of business, the IRS routinely issues refunds to taxpayers 

before verifying the accuracy of the income and withholdings claimed on their tax returns or the 

actual identities of persons filing returns and receiving any refunds that are paid. 

COUNT ONE 

(Conspiracy to Defraud the Government with Respect to Claims, 18 U.S.C. § 286) 

7. The factual allegations contained in Paragraphs 1 through 6 of this Indictment are 

re-alleged and incorporated herein. 

8. Starting on or about December 2010, and continuing through approximately April 

2012, within the District of Oregon and elsewhere, defendants SAVANNAH GARMON, 

LUKE ELLETT, CLARVETTA LARRY, and DONTAE PANKEY, with each other and 

with others, both known and unknown to the grand jury, unlawfully and knowingly agreed, 

combined, and conspired to defraud the United States by obtaining and aiding each other to 

obtain the payment of false, fictitious, and fraudulent claims. 

MANNER AND MEANS 

9. Defendants SAVANNAH GARMON, LUKE ELLETT, CLARVETTA 

LARRY, and DONTAE PANKEY, with others, both known and unknown to the grand jury, 

agreed to file materially false federal income tax returns in their own names and the names of 

third parties without said parties' knowledge and authorization. 

10. Defendants LUKE ELLETT, CLARVETTA LARRY, and DONTAE 

PANKEY obtained third parties' means of identification, including their names, dates of birth, 

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and Social Security numbers, and shared them, as well as the defendants' own means of 

identification, with defendant SAVANNAH GARMON. 

11. Defendant SAVANNAH GARMON used these means of identification to 

prepare and to file approximately 99 false federal income tax returns, claiming approximately 

$285,731 in total refunds. Each of these tax returns directed payment of the fraudulently claimed 

refund to an address or bank account controlled by defendants SAVANNAH GARMON, 

LUKE ELLETT, CLARVETTA LARRY, or DONTAE PANKEY or resulted in a refund that 

was deposited into a bank account controlled by one or more of them. 

12. The federal income tax returns were materially false in that they each claimed 

fictitious income, to wit wages of either $7,080 or $7,087, and fictitious withholdings in the 

amount of $2,834. 

OVERT ACTS IN FURTHERANCE OF THE CONSPIRACY 

13. To accomplish the objectives of the conspiracy and in furtherance thereof, 

defendants, in the District of Oregon and elsewhere, perpetrated, among other acts, the 

following: 

14. SAVANNAH GARMON prepared and filed, and caused to be prepared and 

filed, false federal income tax returns in the names of, among others, the following individuals 

known to the grand jury, whose initials are listed below, on or about the dates listed below, 

claiming refunds for approximately the amounts listed below: 

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INDICTMENT 

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Subparagraph Filing Date Individual Refund Claimed 

A. April 15, 2011 "GLW" $2,834 

B. Jan. 26, 2011 "AJW" $2,834 

c. Jan. 3, 2011 "SMS" $2,834 

D. Jan.26,2011 "WW" $2,834 

E. Dec. 23, 2010 "CPI" $2,834 

F. March 21, 2012 "GAP" $2,834 

15. On or about the dates listed below, defendant DONTAE PANKEY deposited tax 

refunds issued by the IRS to third parties in the names and amounts listed below into his bank 

accounts as listed below: 

Subparagraph Payee Name Deposit Acct Deposit Date Refund Amt 

A. "MCE" BofA # .. .4466 Jan. 4, 2011 $3,134.95 

B. "AJW" BofA # .. .4466 Feb.22,2011 $3,234.75 

C. "WW" BofA # .. .4466 Feb.22,2011 $2,984.75 

D. "WW" BofA # .. .4466 March 2, 2011 $3,134.95 

E. "WW" WF # ... 1699 March 29, 2011 $2,844.52 

F. "GLW" JPMChase # ... 5277 Jan.9,2012 $2,834.75 

16. On or about the dates listed below, defendant CLARVETTA LARRY deposited 

fraudulently obtained tax refunds issued by the IRS to herself and third parties in the names and 

amounts listed below into her bank accounts as listed below: 

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Subparagraph Payee Name Deposit Acct Deposit Date Refund Amt 

A. LARRY BofA # ... 1352 Feb.4,2011 $3,234.75 

B. LARRY JPMChase # ... 3373 April 19, 2011 $402.76 

C. "SMS" JPMChase # ... 3373 June 9, 2011 $3,234.75 

D. "GLW" Wells Fargo # ... 3808 Aug. 22, 2011 $3,134.95 

E. "AJ" Wells Fargo # ... 3808 Nov. 14, 2011 $2,888.37 

17. On or about June 28, 2011, defendants CLARVETTA LARRY and LUKE 

ELLETT escorted "GL W" to a check-cashing service located in Portland, Oregon, to cash a 

refund check issued by the IRS to "GLW" at an address in Las Vegas, Nevada, pursuant to a tax 

return that "GL W" had never filed, reviewed, or authorized. 

18. On or about June 9, 2011, defendants CLARVETTA LARRY and LUKE 

ELLETT escorted "GAP" to a check-cashing service located in Portland, Oregon, to cash a 

refund check issued by the IRS to "GAP" at an address in Las Vegas, Nevada, pursuant to a tax 

return that "GAP" had never filed, reviewed, or authorized. 

All in violation of Title 18, United States Code, Section 286. 

COUNTS TWO AND THREE 

(Theft of Public Money, 18 U.S.C. §§ 2, 641 - LUKE ELLETT) 

19. The allegations set forth in Paragraphs 1 through 6, 17, and 18 of this Indictment 

are re-alleged and incorporated by reference as if fully set forth in each count herein. 

20. On or about the dates listed below, within the District of Oregon, defendant 

LUKE ELLETT did steal, purloin, and knowingly convert to his own use and the use of others 

money of the United States, namely funds in the amounts listed below, administered by the 

Department of the Treasury in the form of income tax refunds that were falsely claimed and 

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INDICTMENT 

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issued in the names of the individuals whose initials are listed below, which funds defendant 

LUKE ELLETT was not entitled to receive: 

Count Date Issued Date Individual in Whose Name Refund Amount of 

Negotiated Was Issued Refund 

2 May 27, June 28, 2011 "GLW" $3,134.95 

2011 

3 May 13, June 9, 2011 "GAP" $3,234.75 

2011 

All in violation of Title 18, United States Code, Sections 641 and 2. 

COUNTS FOUR AND FIVE 

(Theft of Public Money, 18 U.S.C. §§ 2, 641-CLARVETTA LARRY) 

21. The allegations set forth in Paragraphs 1 through 6, 16, and 17 of this Indictment 

are re-alleged and incorporated by reference as if fully set forth in each count herein. 

22. On or about the dates listed below, within the District of Oregon, defendant 

CLARVETTA LARRY did steal, purloin, and knowingly convert to her own use and the use of 

others money of the United States, namely funds in the amounts listed below, administered by 

the Department of the Treasury in the form of income tax refunds that were falsely claimed and 

issued in the names of the individuals whose initials are listed below, which funds defendant 

CLARVETTA LARRY was not entitled to receive: 

Count Date Issued Date Individual in Whose Name Refund 

Negotiated Was Issued 

4 Aug. 8, Aug. 22, 2011 "GLW" 

2011 

5 April 19, June 9, 2011 "SMS" 

2011 

All in violation of Title 18, United States Code, Sections 641 and 2. 

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INDICTMENT 

Amount of 

Refund 

$3,134.95 

$3,234.75. 

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COUNTS SIX AND SEVEN 

(Aggravated Identity Theft, 18 U.S.C. § 1028A - LUKE ELLETT) 

23. The allegations set forth in Paragraphs 1 through 6 and 17 through 20 of this 

Indictment and all paragraphs of Counts Two and Three of this Indictment are re-alleged and 

incorporated by reference as if fully set forth in each count herein. 

24. On or about the dates listed below, within the District of Oregon and elsewhere, 

defendant LUKE ELLETT did knowingly transfer, possess, and use a means of identification of 

another person without lawful authority during and in relation to the offenses in this Indictment 

identified as Related Counts below, that is, he knowingly used without lawful authority the 

names and Social Security numbers of actual persons known to the grand jury, listed by their 

initials below, to commit theft of government funds in violation of 18 U.S.C. § 641 by causing 

the filing of false income tax returns with fraudulent claims for refunds in the names of said 

actual persons and converting the proceeds of said claims to his own unlawful use, each such use 

of a means of identification of another person being a separate count of this Indictment: 

Count Date Name of Dependent Means of Identification Related Theft of 

Claimed on Return Used Government Money 

Count 

6 April 15, "GLW" Name and Social Security Count 2 

2011 Number xxx-xx-0967 

7 March "GAP" Name and Social Security Count 3 

21,2011 Number 

xxx-xx-5817 

All in violation of Title 18, United States Code, Sections 1028A(a)(l), (c)(l), (c)(5), and 

2. 

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INDICTMENT 

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FORFEITURE ALLEGATION 

25. Upon conviction of one or more of the offenses alleged in Counts One through 

Seven of this Indictment, defendants SAVANNAH GARMON, LUKE ELLETT, 

CLARVETTA LARRY, and DONTAE PANKEY shall forfeit to the United States pursuant to 

18 U.S.C. § 981(a)(l)(C) and 28 U.S.C. § 2461(c), any property constituting or derived from 

proceeds obtained directly or indirectly as a result of the said violation(s), including but not 

limited to a sum of money equal to $117,268.00 in United States currency, representing the 

amount of proceeds obtained as a result of the offenses of theft of government funds in the form 

of a money judgment. 

If any of the above-described forfeitable property, as a result of any act or omission of the 

defendants SAVANNAH GARMON, LUKE ELLETT, CLARVETTA LARRY, or 

DONTAE PANKEY: 

(a) cannot be located upon the exercise of due diligence; 

(b) has been transferred or sold to, or deposited with, a third party; 

(c) has been placed beyond the jurisdiction of the court; 

( d) has been substantially diminished in value; or 

(e) has been commingled with other property which cannot be divided without difficulty; 

it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) as incorporated by 

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INDICTMENT 

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18 U.S.C. § 982(b ), to seek forfeiture of any other property of defendants SAVANNAH 

GARMON, LUKE ELLETT, CLARVETTA LARRY, and DONTAE PANKEY up to the 

value of the forfeitable property described above. 

DATED this d~ day of May 2014. 

Presented By: 

S. AMANDA MARSHALL, OSB #95347 

United States Attorney 

District of Orego 

s Attorney 

United States v. Savannah Garmon, et al. 

INDICTMENT 

A TRUE BILL. 

OFFICIATING FOREPERSON 

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