Notice of Related Cases: CR-23-134-AMO; CR-23-136-JST, filed by USA as to Frank Mosley,… — USA v. Mosley et al (Dkt. 2)

Record facts

U.S. District Court for the Northern District of California · No. 4:23-cr-00134-AMO · Doc. 2 · 2023-05-11 · Docket on CourtListener

Summary

A Notice of Related Case in a Criminal Action filed by the United States on May 11, 2023 as Doc. 2 in United States v. Frank Mosley, et al., No. 4:23-cr-00134-AMO, in the U.S. District Court for the Northern District of California. Under Local Criminal Rule 8-1, it states that No. 4:23-CR-00134-AMO, filed May 3, 2023, and No. 4:23-CR-00136-JST, filed May 4, 2023, are related. It states that the first Information alleges that Frank Mosley, Reginald Mosley, Marcus Wilborn, Aaron Boren and Scott Conway conspired during 2020 and 2021 to submit fraudulent PPP loan applications and obtained over $3 million. It states that the second Information alleges a separate PPP scheme by that case's defendant, who also aided and advised others including Frank and Reginald Mosley. The two-page notice cites Local Rule 8-1(b)(1) and 8-1(b)(2) and is signed by Assistant U.S. Attorney Abraham Fine.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

NOTICE OF RELATED CASES  
 
1 
U.S. v. Mosley et. al.  
 
 
 
 
 
 
 
 
v. 7/10/2018 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
26 
27 
28 
ISMAIL J. RAMSEY (CABN 189820) 
United States Attorney 
 
THOMAS A. COLTHURST (CABN 99493) 
Chief, Criminal Division 
 
ABRAHAM FINE (CABN 292647) 
Assistant United States Attorney 
 
1301 Clay Street, Suite 340S 
Oakland, California 94612 
Telephone: (510) 637-3680 
FAX: (510) 637-3724 
Abraham.fine@usdoj.gov 
 
 
Attorneys for United States of America 
 
UNITED STATES DISTRICT COURT 
 
NORTHERN DISTRICT OF CALIFORNIA 
 
OAKLAND DIVISION 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
FRANK MOSLEY, 
REGINALD MOSLEY, 
MARCUS WILBORN, 
AARON BOREN, and  
SCOTT CONWAY 
Defendants. 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
NO. 4:23-CR-00134-AMO 
[FILED MAY 3, 2023] 
NOTICE OF RELATED CASE IN A CRIMINAL 
ACTION 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
KENYA ELLIS, 
Defendant. 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
NO. 4:23-CR-00136-JST 
[FILED MAY 4, 2023] 
NOTICE OF RELATED CASE IN A CRIMINAL 
ACTION 
 
      
Case 4:23-cr-00134-AMO     Document 2     Filed 05/11/23     Page 1 of 2

 
 
 
NOTICE OF RELATED CASES  
 
2 
U.S. v. Mosley et. al.  
 
 
 
 
 
 
 
 
v. 7/10/2018 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
26 
27 
28 
The United States of America, pursuant to Local Criminal Rule 8-1, hereby notifies the Court 
that the two above-captioned criminal cases are related.  The first-filed case, United States v. Frank 
Mosley et. al., No. 23-cr-00134-AMO, alleges that Frank Mosley, Reginald Mosley, Marcus Wilborn, 
Aaron Boren, and Scott Conway conspired during 2020 and 2021 to submit fraudulent loan applications 
to the Covid-19 Paycheck Protection Program (“PPP”).  The Information alleges that these defendants 
obtained over $3 million in illicit proceeds during the course of their conspiracy.  The second-filed case, 
United States v. Kenya Ellis, No. 23-cr-00136-JST, alleges that Kenya Ellis engaged in a separate PPP 
fraud scheme in which she submitted fraudulent loan applications to the PPP.  That Information also 
alleges that Ellis aided and advised others, including Reginald Mosley and Frank Mosley, in submitting 
fraudulent PPP loans on behalf of their own companies, including the fraudulent loans encompassed 
within the first-filed case.  Although Ellis was not charged as a co-conspirator in the first-filed case, she 
actively participated in that scheme with Frank and Reginald Mosley, and engaged in similar conduct on 
her own, which she is separately charged with in the second-filed case.  Based upon these facts, the 
cases are related within the meaning of Local Rule 8-1(b)(1) because they involve the same defendant 
and the same events and occurrences.  Furthermore, the cases are related within the meaning of Local 
Rule 8-1(b)(2) because, if heard by separate judges, the actions likely would involve substantial 
duplication of labor by the two judges. 
 
Per the requirement of Local Criminal Rule 8-1(c)(4), government counsel states that assignment 
of these cases to a single judge is likely to conserve judicial resources and promote an efficient 
determination of each action. 
 
DATED: May 11, 2023 
 
 
 
Respectfully submitted, 
ISMAIL J. RAMSEY 
United States Attorney 
 
/s/ Abraham Fine 
ABRAHAM FINE 
Assistant United States Attorney 
Case 4:23-cr-00134-AMO     Document 2     Filed 05/11/23     Page 2 of 2

File and source

File

gov.uscourts.cand.412167.2.0.pdf

Size

132,160 bytes

SHA-256

562946bc92b7fc6b6e47b8d7d9cfb1319f9cdc08d66b9ccdc78ad1f7a03a3483

Our copy

gov.uscourts.cand.412167.2.0.pdf

Original

PACER (login required)