Professional Documents
Culture Documents
INFORMATION
COUNT ONE
government. Among other responsibilities, OPM manages the Civil Service Retirement System
(“CSRS”). CSRS benefits are afforded to federal employees known as “annuitants” upon retirement
from federal service. An annuitant receives CSRS benefits throughout his lifetime based on his age,
average salary, and length of federal service. Upon an annuitant’s death, CSRS benefits do not
accrue to surviving children over 22 years of age. A survivor annuity is payable only to some
spouses and some children under 22, and only upon OPM’s approval of an application from the
RALPH SINCAVAGE’s date of birth is xx/xx/1946. RALPH SINCAVAGE is the son of Joseph
Sincavage, Sr., who was born in 1910. Joseph Sincavage, Sr. died on March 16, 1992, in Havre De
Grace, Maryland. RALPH SINCAVAGE is listed as the informant on the death certificate.
Case 1:10-cr-00252-EGS Document 2 Filed 09/14/10 Page 2 of 5
According to the death certificate, Joseph Sincavage, Sr. and RALPH SINCAVAGE both resided
at the same address in Aberdeen, Maryland at the time of the death of Joseph Sincavage, Sr.
3. Before his death, Joseph Sincavage, Sr. received retirement annuity payments from
CSRS based on his prior service as a government truck driver. These payments were automatically
deposited into a bank account. After Joseph Sincavage, Sr.’s death, RALPH SINCAVAGE did not
notify OPM of his father’s death. Instead, RALPH SINCAVAGE took steps to defraud OPM in
order to collect Joseph Sincavage, Sr.’s annuity – an annuity to which RALPH SINCAVAGE was
not entitled.
4. Before his death, Joseph Sincavage, Sr. also received health-care benefits through
OPM. On or about November 17, 1992, RALPH SINCAVAGE cancelled his father’s health-care
benefits by forging his father’s name on a Health Benefits Cancellation Confirmation form and
mailing the form to OPM’s address in the District of Columbia. RALPH SINCAVAGE took this
action in order to increase the dollar amount of the annuity; previously each annuity payment had
5. On or about January 1, 1993, OPM discovered the death of Joseph Sincavage, Sr. by
examining records of the Social Security Administration (“SSA”). On January 14, 1993, OPM
flagged Joseph Sincavage, Sr. in OPM’s database as being deceased, and OPM halted the annuity
payments. On January 28, 1993, RALPH SINCAVAGE contacted OPM and pretended to be Joseph
Sincavage, Sr. As a result of this phone call, OPM restored the annuity payments.
order to verify that an annuitant was still alive and that OPM had the annuitant’s correct address on
file. In three instances – in 1993, 1995, and 2005 – RALPH SINCAVAGE forged his father’s
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signature on an AVL and falsely asserted that his father was still alive, then mailed the AVL to
OPM’s address in the District of Columbia. Based on these certifications, OPM continued to pay
the annuity, which RALPH SINCAVAGE collected. On several occasions, RALPH SINCAVAGE
changed the bank account to which the annuity was directly deposited.
7. In or about October 2009, OPM again received information from SSA that Joseph
Sincavage, Sr. was dead. At this time, the annuity was being deposited in a Navy Federal Credit
Union (“NFCU”) checking account belonging to RALPH SINCAVAGE. OPM notified NFCU, and
NFCU contacted RALPH SINCAVAGE. On the next AVL, dated October 13, 2009, RALPH
SINCAVAGE signed his correct name and wrote “survivor annuity,” although he knew that he was
not entitled to such an annuity. Shortly thereafter, OPM halted the annuity payments.
Columbia, defendant RALPH SINCAVAGE wilfully and knowingly did steal and purloin money,
in the form of annuity payments with a total value of $335,882.45, from an agency and department
1. The allegations set forth in Count One of this Information are re-alleged as though
set forth fully herein and incorporated by reference for the purpose of alleging forfeiture to the
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United States of America pursuant to the provisions of Title 18, United States Code, Section
2. As a result of the offense alleged in Count One of this Information, the defendant,
RALPH SINCAVAGE, shall forfeit to the United States any and all property, real or personal,
constituting, or derived from, proceeds obtained directly or indirectly, as the result of theft of
Money Judgment
3. By virtue of the commission of the felony offense charged in Count One of this
Information, any and all interest that RALPH SINCAVAGE has in the property constituting, or
derived from, proceeds obtained directly or indirectly as the result of theft of government money,
is vested in the United States and hereby forfeited to the United States pursuant to Title 18, United
States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c). If, as a result
e. has been commingled with other property that cannot be subdivided without
difficulty;
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it is the intention of the United States, pursuant to Title 18, United States Code, Section
981(a)(1)(C), and Title 28, United States Code, Section 2461(c), and incorporating by reference
Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of said
defendant up to the value of said property listed above as being subject to forfeiture.
(Criminal Forfeiture, in violation of Title 18, United States Code, Section 981(a)(1)(C)
and Title 28 United States Code, Section 2461(c)).
Respectfully submitted,
By: ___________/s/_________________________
BRYAN SEELEY
Assistant United States Attorney
D.C. Bar No. 501681
555 4th Street, N.W., Room 5840
Washington, D.C. 20530
(202) 353-3602
Bryan.Seeley@usdoj.gov