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Justice News

Department of Justice
U.S. Attorney’s Office
District of Colorado

Friday, April 25, 2014

Federal Employee Appears In Court After Being Indicted For Scheme To Defraud Government

DENVER – Jaycee L. Collier, age 29, of Aurora, Colorado, was indicted by a federal grand jury in Denver on April 8, 2014 on charges of wire fraud and bribery of a public official in connection with a military recruiting program.  Collier received a summons to appear in U.S. District Court in Denver today, April 25, 2014.  He made his initial appearance, where he was advised of his rights and the charges pending against him.  He was then released on a $10,000 unsecured bond.  He is scheduled to return to court on Wednesday, April 30, 2014 at 10:00 a.m. for arraignment.

According to the indictment, the United States Army Reserve (USAR), located at Fort Bragg, North Carolina, had a contract with Document & Packaging Brokers, Inc. (“Docupak”) to administer a program called the Army Reserve Recruiting Assistance Program (AR-RAP).  The AR-RAP offered monetary incentives in the form of recruiting referral bonuses to Army Reserve soldiers, known as Recruiting Assistants (RAs), for encouraging others to join the Army Reserves.  The recruiting assistants were required to enroll and complete an online training course.  At the conclusion of the training, the RAs would establish an online account to record their nominations of others for enlistment.  An RA could receive up to $2,000 for each successful nomination.

Collier was employed as a civilian employee with the Department of Defense at the Military Entrance Processing Station (MEPS) in Denver.  In his position as a Lead Human Resources Division Assistant (HRA), Collier was responsible for handling enlistment packets for new recruits joining the USAR and processed through the Denver office.  As such, Collier was ineligible to participate in the AR-RAP program.

Between March 10, 2009 and July 25, 2012, Collier knowingly devised a scheme to defraud the USAR by means of materially false and fraudulent pretenses.  Specifically, he obtained or caused to be obtained the user names and passwords for eligible RAs so that Collier could enter nominations into those RAs accounts and share in the AR-RAP bonus money.  Over the time period alleged, Collier was involved in the nomination of over 65 recruits into the AR-RAP Program.

Approximately $125,000 in fraudulent referral bonuses were wired from Docupak to the RAs’ bank accounts.  In most instances, the RAs would pay Collier on average $500 as a kickback for each successful nomination.  In total, the indictment alleges that Collier personally received over $28,000 in payments from the RAs for fraudulent nominations.

Collier faces five counts of wire fraud.  If convicted, he faces not more than 20 years in federal prison, and up to a $250,000 fine, per count.  He also faces 13 counts of bribery of a public official.  If convicted, he faces not more than 15 years in federal prison, and up to a $250,000 fine, or three times the monetary thing of value, whichever is greater, per count.

This case was investigated by the U.S. Army Criminal Investigation Division and the Defense Criminal Investigative Service.

Collier is being prosecuted by Assistant U.S. Attorney Martha Paluch.

The charges contained in the indictment are allegations, and the defendant is presumed innocent unless and until proven guilty.

Updated June 22, 2015