Eight Defendants Indicted for Allegedly Defrauding Taxpayer-Funded Traumatic Brain Injury Fund of Over $700K

For Immediate Release: March 22, 2024

Office of the Attorney General
– Matthew J. Platkin, Attorney General
Office of Public Integrity and Accountability
– Thomas J. Eicher, Executive Director

For Further Information:

Media Inquiries-
Dan Prochilo

TRENTON — Attorney General Matthew J. Platkin and the Office of Public Integrity and Accountability (OPIA) announced today that a state grand jury has indicted six women and two companies who were allegedly engaged in a decade-long conspiracy to defraud the taxpayer-funded New Jersey Traumatic Brain Injury Fund (TBI Fund) of over $700,000.

Following an investigation by the Corruption Bureau of OPIA, the state grand jury returned indictments against the following defendants:

  • Maria Sirange Viana DeSouza, 48, of Newark
  • Marlene Souza-Sales, 45, of Elizabeth
  • Patricia Souza Lima, 36, of Newark
  • Stephanie Andrade, 36, of Elizabeth
  • Estela Marisol Zapata, 46, of Edison
  • Clara Rincon, 48, of the Bronx, New York
  • Marlene’s Cleaning Service LLC, founded in 2018 and based in Newark
  • S&N Household Management LLC, founded in 2018 and based in Elizabeth

According to the allegations in the indictment, fraudulent vendor payments made by the TBI Fund, a publicly funded program run by the New Jersey Division of Disability Services (NJDDS), led to hundreds of thousands of dollars being unlawfully and purposely misdirected to the defendants.

The fund provides victims of traumatic brain injuries with services and support, including therapy, home modifications, medications, and home maintenance. The goal is giving patients assistance with meeting needs not covered by insurance, their personal finances, or other programs.

If approved by fund personnel, applicants receive services from vendors who submit invoices to the fund for payment, and then receive checks from the State Treasury.

The indictment alleges the defendants stole public money from the TBI Fund by giving the false impression that they and their corporate entities provided vendor services to beneficiaries, when in fact no services had been provided. From about January 2009 until approximately October 2019, the defendants participated in the scheme, receiving payments from the TBI Fund for services that were never rendered.

“This taxpayer-supported fund helps people challenged by long-term impairments resulting from a traumatic brain injury,” said Attorney General Platkin. “Stealing from that fund, as the defendants allegedly did, not only takes advantage of taxpayers, but also victimizes the injured who need help.”

“As alleged in the indictment, these defendants did not work for this money. All they did was fraudulently work the system,” said Thomas J. Eicher, Executive Director of OPIA. “This indictment should serve as a warning to anyone who would abuse public resources for personal gain at the expense of community members in need.”

All of the defendants were indicted on charges of conspiracy, theft by deception, misapplication of government property, tampering with public records, falsifying or tampering with records, and official misconduct. Certain defendants were also charged with misconduct by a corporate official, after they allegedly used and operated the charged limited liability companies to commit criminal acts.

These charges and allegations are merely accusations, and the defendants are presumed innocent unless and until proven guilty in a court of law.

Attorney General Platkin thanked the U.S. Attorney’s Office for the District of New Jersey for its assistance. The case is being prosecuted by Deputy Attorneys General Brian Kenney and Max Lesser from the Corruption Bureau of OPIA, under the supervision of Deputy Bureau Chiefs Andrew Wellbrock and Jeffrey J. Manis, OPIA Deputy Director Anthony Picione, and Executive Director Eicher.

Defense attorneys:
None listed at this time

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