Case: 45CI1:20-cr-00086 Document #: 1 Filed: 02/25/2020 Page 1 of 3

FI LEr\
JL WADISOMCOIJNTY JLJI'

IN THE CIRCUIT COURT OF MADISON COUNTY, MISSISSIPPlFES 12 2020

._20^ Judicial District MlJA WRAYJ^ CLERK
vllaAA Term, A.D. 2020 BY ^_______D.C.
STATE OF MISSISSIPPI

vs.
CauseNo.^pflQ.flftfl,
TONI TAMEKA BORDEN

MULTI-COUNT INDICTMENT

The GRAND JURORS ofthe State ofMississippi, taken from the body ofthe good and lawful
citizens ofMadison County, Mississippi, being duly selected, impaneled, sworn and charged in
the Circuit Court ofMadison County, Mississippi, Circuit Court District #20, upon their oaths,
present that:

COUNT I
(INSURANCE FRAUD)

TONI TAMEKA BORDEN did on or about October 31, 2019 , in Madison County
Mississippi, unlawfully, willfully, fraudulently and feloniously, commit the crime of Insurance
Fraud by making false and misleading and untrue statement(s) and representation(s) to an
insurance company for the purpose of receiving benefit and payment to wit: while in Madison
County, Mississippi and at a time when her daughter had been involved in an automobile
accident in said county, did embark on a scheme and artifice to defraud Safeco Insurance
Company, by stating she had been involved in an accident while in Madison County Mississippi
and did continue with her scheme and artifice to defraud Safeco Insurance Company by filing
and reporting a false insurance claim with Safeco Insurance Company representing, in essence,
that she had been the driver in an automobile accident which occurred on October 14, 2019;
when, in fact, heruninsured, unlicensed daughter was driving the automobile involved in an
accident and did occur at a time when she had no insurance coverage with Safeco on her
unlicensed daughter, being an attempt to execute and an execution of a scheme and artifice to
defraud, in violation ofSection 7-5-303 ofthe Mississippi Code of 1972, as amended and against
the peace and dignity of the State of Mississippi.

COUNT II
(WIRE FRAUD)

TONI TAMEKA BORDEN did on or about November 4, 2019, in Madison County

Mississippi, unlawfully, willfully, fraudulently and feloniously commit the crime of Wire Fraud
to wit: having devised a scheme and artifice to defraud and for obtaining money and personal
lof 2 I Pa ;• c
 Case: 45CI1:20-cr-00086 Document #: 1 Filed: 02/25/2020 Page 2 of 3

advantage by means offalse and fraudulent pretense(s) and representation(s), transmit or cause
to be transmitted across county and jurisdictional lines, by mail and telephone and wire and
internet and other means ofcommunication and for the purpose ofexecuting such scheme and
artifice to defraud did, in essence, request from and file a claim to Safeco Insurance Company
shortly after her uninsured daughter was involved in an automobile accident, for the purpose of
subsequently filing a false insurance claim and did subsequently file a false insurance claim
with Safeco by, in essence, representing that she had been involved in an automobile accident
when, in fact her uninsured daughter was driving in the automobile accident and did occur at a
time when she had no insurance coverage with Safeco on her unlicensed daughter, in violation
ofSection 97-19-83 ofthe Mississippi Code of 1972, as amended and against the peace and
dignity of the State of Mississippi.

COUNT III
(ALTERATION OF RECORDS)

TONI TAMEKA BORDEN did on orabout and between October 20, 2019, and November 4,
2019, in Madison County, Mississippi, did wittingly, willfully, unlawfully and feloniously make,
alter, or change a record belonging to a public office, to wit: the Canton's Police Department, in
that she created and altered a false Uniform Crash Report by falsely reporting she was the driver
of the automobile involved in the accident alleged in Counts I and II of this indictment on the
Uniform Crash Report and falsely entering the name ofan officer no longer employed by the
Canton Police Department when in fact the report was generated by TONI TAMEKA
BORDEN in her capacity as an Police Officer ofthe Canton Police Department in violation of§
97-11-1 of the Mississippi Code of 1972, as amended.

This being a multi-count indictment pursuant to Section 99-7-2 of the Mississippi Code of 1972,
as amended.

A TRUE BILL

, ^_
Jrad A.TTberhousen
_ " ^
__.. 0. Q^ii
Special Assistant Attorney General
550 High Street
Jackson, MS 39201
bober@ago. state,ms. us
ph# 601-576-4254

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 Case: 45CI1:20-cr-00086 Document #: 1 Filed: 02/25/2020 Page 3 of 3

AFFIDAVIT

COMES NOW Irmilif f, (Alyl ,Foreman ofthe aforesaid Grand Jury, and
makes oath that this indictment presented to this Court was concurred in by twelve (12) or more
members ofthe Grand Jury and at least fifteen (15) members thereof were present during all
deliberations.

FOREMAN OF THEUGRAND JURY

SWORN TO AND SUBSCRIBED before me on this, the £2, day of ^eL- ,2020
tyfWs*0~.

Anita E.

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