Criminal complaint — United States v. Jackson (C.D. Cal.)

Record facts

U.S. District Court for the Central District of California · No. 2:23-cr-00210-DSF · Doc. 1 · 2023-04-11 · Docket on CourtListener

Full text

AUSA Andrew Brown, 11th Floor, x0102 
AO 91 (Rev. 11/11)  Criminal Complaint (Rev. by USAO on 3/12/20) 
܆Original     ܆ Duplicate Original
UNITED STATES DISTRICT COURT 
for the 
Central District of California 
United States of America 
v. 
BOBBY JOE JACKSON JR., 
     Register Number: 24472-112, 
            Defendant 
Case No. 
CRIMINAL COMPLAINT BY TELEPHONE  
OR OTHER RELIABLE ELECTRONIC MEANS 
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.  
As described in the accompanying attachment, defendant violated the following statutes: 
Code Section 
Offense Description 
18 U.S.C. §§ 1344, 1349, 1028A 
Conspiracy to Commit Bank Fraud, 
and Aggravated Identity Theft 
This criminal complaint is based on these facts: 
Please see attached affidavit. 
_ Continued on the attached sheet.
/s Lyndon Versoza 
Complainant’s signature 
Lyndon Versoza, Postal Inspector 
Printed name and title 
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone. 
Date: 
Judge’s signature 
City and state: Los Angeles, California 
Hon. Pedro V. Castillo, U.S. Magistrate Judge 
Printed name and title 
2:23-mj-01714
4/11/2023
TV
$SULO
Judg
d e’s sigi
Crim. P. 4.1 by telephon
nature 
April 11, 2023
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 1 of 15   Page ID #:1

Complaint Attachment 
 
Count One, 18 U.S.C. § 1349 
 
Beginning on an unknown date, and continuing through at least July 22, 2022, in Los Angeles 
County, within the Central District of California, and elsewhere, defendant BOBBY JOE JACKSON 
JR., and others, conspired to commit bank fraud, in violation of Title 18, United States Code, Section 
1344.  The object of the conspiracy was carried out, and to be carried out, in substance, as follows:   
Defendant would acquire the personal identifying information of others from his friends and family, and 
by purchasing it on the black market for victims of identity theft.  Defendant would use that information 
to apply for unemployment benefits in those names, falsely stating that those persons had recently lost 
their jobs.  After the California Employment Development Department had Bank of America mail debit 
cards to addresses defendant controlled, he would have his co-conspirators use those cards to withdraw 
in cash the unemployment benefits and deliver them to him.  Defendant would also use the personal 
identifying information of others to apply for CARES Act relief loans in their names, falsely stating that 
they ran businesses.  As a result of this fraud, defendant and his co-conspirators defrauded federally-
insured financial institutions including Bank of America and Capital Plus Financial. 
             
Count Two, 18 U.S.C. § 1028A 
 
Beginning on an unknown date, and continuing through at least July 22, 2022, in Los Angeles 
County, within the Central District of California, and elsewhere, defendant BOBBY JOE JACKSON JR. 
knowingly transferred, possessed, and used, without lawful authority, a means of identification of 
another person during and in relation to a felony violation of Title 18, United States Code, Section 1349, 
Conspiracy to Commit Bank Fraud, as charged in Count One, knowing that the means of identification 
belonged to another actual person. 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 2 of 15   Page ID #:2

AFFIDAVIT 
 
I, Lyndon A. Versoza, being duly sworn, hereby depose and state 
as follows:  
I. 
TRAINING AND EXPERIENCE 
1. 
I am a United States Postal Inspector employed by the 
United States Postal Inspection Service (“USPIS”), Los Angeles 
Division, in Los Angeles, California, where I have served since 
June 2005.  Currently, I am responsible for investigating 
criminal violations of money laundering and structuring laws, 
such as when the services of the United States Postal Service 
are employed by criminals as part of the means to launder or 
conceal illicit funds, and/or avoid banking reporting 
requirements.  I am also one of seven Postal Inspectors in the 
U.S. currently designated by USPIS as a Subject Matter Expert 
(“SME”) in money laundering investigations.  As a SME, I have 
spoken at money laundering conferences and provided training to 
the financial and banking industry and other law enforcement 
agents. I have also received both formal and informal money 
laundering training from USPIS and other government and private 
agencies.  During my almost 18-year career as a Postal 
Inspector, I have investigated: mail thieves, burglars, rapists, 
murderers, armed robbers, prison and street gangs, drug 
trafficking organizations, and perpetrators of financial 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 3 of 15   Page ID #:3

- 2 - 
 
violations (including money launderers, darknet vendors, digital 
currency launderers, identity thieves and fraudsters).  For 
approximately five years prior to investigating money 
laundering, I was assigned to investigate child exploitation and 
sex trafficking.  In that assignment, I worked both 
independently and in a task force where I led and participated 
in investigations related to crimes involving the exploitation 
of children and sex trafficking domestically and 
internationally.  In that capacity, I also earned a designation 
by USPIS as a SME in Child Exploitation Investigations.   
2. 
From 2002 to 2005, prior to my service as a US Postal 
Inspector, I served as a law enforcement officer with the US 
Immigration and Naturalization Service, which later became part 
of the US Department of Homeland Security.  In this capacity I 
enforced immigration and customs law at an international airport 
and seaport, and later, worked in an intelligence unit for local 
and national counter-terrorism and smuggling operations. 
3. 
I am familiar with the facts and circumstances 
described herein.  This affidavit is based upon my personal 
involvement in this investigation, my training and experience, 
and information obtained from various law enforcement personnel 
and witnesses, including information that has been reported to 
me either directly or indirectly.  This affidavit does not 
purport to set forth my complete knowledge or understanding of 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 4 of 15   Page ID #:4

- 3 - 
 
the facts related to this investigation.  Unless specifically 
indicated otherwise, all conversations and statements described 
in this affidavit are related in substance and part only.  All 
figures, times, and calculations set forth herein are 
approximate. 
II. 
SUMMARY AND PURPOSE OF AFFIDAVIT: COMPLAINT 
4. 
 This affidavit is made in support of a criminal 
complaint against BOBBY JOE JACKSON JR. (“JACKSON”) for 
violations of 18 U.S.C. §§ 1344 and 1349 (conspiracy to commit 
bank fraud), and 1028A (aggravated identity theft). 
5. 
 From March through July 2022, I investigated JACKSON 
for his role in an unemployment fraud scheme through the 
California Employment Development Department (“EDD”) and a loan 
fraud scheme through the Small Business Administration (“SBA”).  
I also learned that JACKSON, who was on federal probation at the 
time, and was lying to his probation officer about his conduct 
and whereabouts.  
6. 
On July 22, 2022, a federal search warrant was 
executed at the residence of JACKSON at 194 S. Tamarisk, Rialto, 
CA 92376 (“JACKSON Residence”). During the search, numerous 
stolen credit cards and social security cards were found, along 
with fake identification cards and driver licenses in names 
matching the stolen cards but with photos of JACKSON. Several 
Visa Debit cards issued by California Employment Development 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 5 of 15   Page ID #:5

- 4 - 
 
Department in the names of stolen identities were also found, 
indicative of unemployment insurance fraud.  
7. 
I interviewed JACKSON who admitted to buying stolen 
identities from McArthur Park, using them to commit fraud, and 
filing for at least 20 California Employment Development Program 
claims using the stolen identities, and receiving about $15,000 
from each successful claim. Jackson used the stolen identities 
to fraudulently file for Paycheck Protection Program (“PPP”) or 
Economic Injury Disaster Loans (“EIDL”) and also used them to 
rent property, which he would sublease to tenants who could not 
qualify for the property. Jackson used cash from his fraud 
scheme to buy assets, including a $35,000 commercial truck he 
paid for in cash. Jackson also admitted to lying to his 
probation officer about living in Compton when, in fact, he 
lived at a different address, and did not disclose his income or 
loan applications to probation.  JACKSON was later arrested for 
violating the conditions of his supervised release based on the 
conduct described above, and is currently serving the revocation 
sentence imposed. 
III. PROBABLE CAUSE STATEMENT 
A. 
JACKSON CONSPIRED TO COMMIT FRAUD 
8. 
On or about March 16, 2022, I spoke with EDD 
Investigator Ivant Romo who reviewed EDD records and told me 
that JACKSON was associated to multiple EDD claims in Las Vegas, 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 6 of 15   Page ID #:6

- 5 - 
 
Nevada.  Specifically, on or about March 15, 2020, an 
unemployment insurance application using the address of 3897 
Gulliver Street, Las Vegas, Nevada and JACKSON’s personal 
identifying information, was filed.  EDD Investigator Romo told 
me that along with JACKSON, 18 other unemployment insurance 
claims were filed from that same address in 2020 using the 
identifying information of different individuals.  JACKSON, in 
an interview (as later described in this affidavit), told me 
that some of these claims were either victims whose identities 
he used, or members of his conspiracy.  
9. 
EDD Investigator Romo also told me JACKSON’s EDD 
application in his true name also used the JACKSON Residence as 
a mailing address.  A second EDD unemployment application for 
the JACKSON Residence was filed under the name whose initials 
are “S.R.B.” 
10. 
I reviewed ATM surveillance videos and observed a 
person that I recognized based on his DMV photo as JACKSON 
conducting the ATM cash withdrawals on his own card. 
B. 
JACKSON CONSPIRED WIH HIS RELATIVES 
11. 
On or about May 4, 2022, I reviewed prison emails sent 
between JACKSON and “Moma Baby.”  In one email dated January 28, 
2022, JACKSON responds to Moma Baby and said:  
GOOD MORNING YES I DID HER FORGIVENESS THING FOR HER SHE 
WAS ONE OF THE FIRST PEOPLE THAT I DID DO I WILL DOUBLE 
CHECK WHEN I GET HOME OKAY BUT YES I BELIEVE ITS DONE OKAY 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 7 of 15   Page ID #:7

- 6 - 
 
I WILL SEE YOU IN 23 DAYS THAT'S WHEN I WILL BE BACK I WILL 
COME BY OKAY. SAVE THE LETTER SO THAT I CAN READ IT OKAY, I 
GOT YOU 
-----Baby, Moma on 1/28/2022 8:36 AM wrote: 
> 
Good morning they sent my daughter sum thing saying that 
she might have to pay back that money u got for her did u 
do the 
forgiveness thinh 
 
12. 
I believe this email is talking about JACKSON having 
applied for a PPP Loan for Moma Baby’s daughter.  JACKSON also 
confessed to me that he facilitated numerous loans and loan 
forgiveness applications including the loan and loan forgiveness 
for Moma Baby’s daughter. 
C. JACKSON’s Own PPP and EIDL Applications Were Fraudulent 
13. 
On June 8, 2022, I spoke with Small Business 
Administration, Office of the Inspector General, Special Agent 
Angel Huling.  SA Huling told me JACKSON, using the JACKSON 
Residence address and a phone number which I later confirmed 
through US Probation belonged to JACKSON (the “JACKSON Phone”), 
applied for Paycheck Protection Program Loans (PPP) and Economic 
Injury Disaster Loans (EIDL) in his true name.  JACKSON was 
approved for the PPP loan for $20,832, but his EIDL application 
was denied. 
14. 
On June 14, 2022, I reviewed the PPP loan application 
that I received from SA Huling.  According to the application, 
JACKSON (who attached his California Driver License to the 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 8 of 15   Page ID #:8

- 7 - 
 
application) claimed to be an Independent Contractor who started 
his business on March 1, 2018.  I later spoke with US Probation 
who told me JACKSON was in federal custody on March 1, 2018, and 
was not released until November 25, 2019.  His probation was 
revoked on November 1, 2021. 
15. 
In the PPP application JACKSON also stated his gross 
income was $120,000 with a net income of $45,000.  (The income 
JACKSON reported in his loan application contradicts the income 
reported to US Probation, where he claimed to be unemployed.) 
16. 
In the PPP application, JACKSON attested “NO” to the 
following question: 
Is the Applicant (if an individual) or any individual 
owning 20% or more of the equity of the Applicant presently 
incarcerated or, for any felony, presently subject to an 
indictment, criminal information, arraignment, or other 
means by which formal criminal charges are brought in any 
jurisdiction?  NO 
Within the last 5 years, for any felony involving fraud, 
bribery, embezzlement, or a false statement in a loan 
application or an application for federal financial 
assistance, or within the last year, for any other felony, 
has the Applicant (if an individual) or any owner of the 
Applicant 1) been convicted; 2) pleaded guilty; 3) pleaded 
nolo contendere; or 4) commenced any form of parole or 
probation (including probation before judgment)? NO 
 
17. 
JACKSON executed the documents for the loan on April 
15, 2021.  He commenced probation on November 25, 2019, about 5 
months prior to his loan application.  According to the SBA, the 
PPP loan to JACKSON has since been forgiven.  
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 9 of 15   Page ID #:9

- 8 - 
 
D. JACKSON Submitted Another Fraudulent PPP Application in the 
Name of his Uncle, Gino Hickey 
18. 
SA Huling also sent me another application for Gino 
Hickey (“Hickey”) at the JACKSON Residence.  The application 
appears similar to JACKSON’s with the same reported gross income 
of $120,000 for the same requested loan amount of $20,832.  Like 
JACKSON’s application, the Hickey application also claimed that 
Hickey was an independent contractor.  Hickey’s loan was also 
approved and has since been forgiven. (I later learned during my 
interview of JACKSON that Hickey is JACKSON’s uncle and this was 
also a fraud committed by JACKSON and Hickey). 
19. 
On June 14, 2022, I reviewed banking records from 
Capital Plus Financial (“CPF”).  According to their website CPF 
“is a real estate financial institution specializing in 
residential mortgage lending in the Hispanic single-family 
residential market of the Dallas/Fort Worth, Houston, and San 
Antonio areas.” From reviewing the banking records I learned 
that Capital Plus Financial performed a review related to the 
PPP loan application of JACKSON and Hickey and reported:   
CPF has reviewed the above referenced application 
and loan file and found that the borrower failed to 
provide appropriate documentation. Borrower and Hickey 
both applied for an SBA loan as an Independent 
Consultant, Commercial and Institutional Building 
Construction, NAICS (236220). 
[JACKSON] and Hickey are connected provided the 
same address on their PPP loan applications; 194 South 
Tamarisk Ave, Rialto, California 92376. Each borrower 
also provided very similar Schedule C documents. 
[JACKSON] and Hickey provided a draft 2020 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 10 of 15   Page ID #:10

- 9 - 
 
Schedule C that states the borrower and Hickey have a 
gross income of $120,000.00 each, JACKSON’s expenses of 
$66,000.00, and a net profit of $45,000.00, while Hickey 
has expenses of $65,000.00 and a net profit of 
$46.000.00. The Schedule Cs are very similar. The 
business type and NAICS code matches, the addresses are 
the same, the gross revenue is the same. The expenses 
are different by $1,000.00 however the type of expenses 
are identical (the line items). 
In conjunction with the loan documents and 
activity described above, borrowers were approved and 
funded for a PPP loan in the amount of $20,832.00.00 
each for a total of $41,664.00. The loss to CPF is 
$41,664.00. 
The borrowers appear to have obtained a PPP loan 
based on the above-described conduct which may 
constitute fraud which CPF finds suspicious. 
 
20. 
On July 22, 2022, I told Hickey that I was aware that 
he committed fraud with Jackson, and that his application for a 
PPP loan was fraudulent.  I told Hickey that I know that he did 
not earn the income stated in his application, and that he was 
never an independent contractor.  Hickey said “uh huh,” 
acknowledging what I had said; he never denied participating in 
the fraud.     
E. 
JACKSON LIED TO PROBATION 
21. 
On May 24, 2022, I spoke with United States Probation 
Officer Robert Gardner who supervises JACKSON.  According to 
Probation Officer Gardner, he communicated with JACKSON through  
the JACKSON Phone.  Officer Gardner said JACKSON was supposed to 
report all income to his probation officer.  Officer Gardner 
said JACKSON claims to be unemployed and did not report 
receiving state benefits for unemployment or any other financial 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 11 of 15   Page ID #:11

- 10 - 
 
benefits.  Officer Gardner also said that JACKSON used to live 
at the JACKSON Residence but no longer lives there.  Instead, 
the probation officer said, JACKSON claimed he occupies a 
converted garage at 919 address on North Locust Ave, Compton, 
California.  (However based on my investigation and as discussed 
below, I know that JACKSON was not truthful with Officer 
Gardner). 
 
F. 
SEARCH WARRANTS ISSUED AND EXECUTED AT THE JACKSON 
RESIDENCE: EVIDENCE OF FRAUD FOUND 
22. 
On July 15, 2022, the Honorable U.S. Magistrate Judge 
John E. McDermott authorized a search warrant for the residence 
of JACKSON in Rialto, California (“JACKSON Residence”). 
23. 
On July 22, 2022, I, along with other law enforcement 
agents executed the federal search warrant at the JACKSON 
Residence.  During this search, agents found numerous stolen 
credit cards and social security cards in names other than 
Jackson.  Along with the stolen cards, also found were fake 
identification cards and driver licenses in names matching the 
stolen cards but with photos of JACKSON as the bearer of the 
fake IDs.  We also found several Visa Debit cards issued by 
California Employment Development Department in the names of 
stolen identities. 
G. 
JACKSON ADMITTED TO COMMITTING FRAUD 
24. 
On July 22, 2022, FBI Special Agent Lynne Zellhart and 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 12 of 15   Page ID #:12

- 11 - 
 
I interviewed JACKSON who told us that he would buy stolen 
identities from McArthur Park. The identity profiles he bought 
would include fake driver licenses bearing his photo, along with 
social security numbers and fake credit cards and other PII.   
25. 
JACKSON said he would use the stolen identities to 
commit fraud.  JACKSON stated that he has filed for at least 20 
California Employment Development Program (EDD) claims using the 
stolen identities and received about $15,000 from each 
successful claim.  JACKSON would go to bank ATM machines and 
would hire others to withdraw the fraudulent cash to avoid 
detection.  Occasionally JACKSON would conduct the withdrawal 
himself. 
26. 
In my discussion with JACKSON, I went down the list of 
identities that EDD Investigator Romo previously provided me of 
fraudulent claims from addresses tied to JACKSON.  JACKSON 
identified some of those names as identities he had purchased 
for his scheme.  Others he said belonged to his conspirators.  
JACKSON claimed he did not remember all of the names.   
27. 
JACKSON also said he used the stolen identities and 
identities of friends and family to fraudulently file for PPP or 
EIDL loans.  These identities would include his uncle, Gino 
Hickey, and daughter.  JACKSON would also assist in filing the 
paperwork for loan forgiveness of the fraudulent loans of his 
friends and family. JACKSON admitted that the documents he 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 13 of 15   Page ID #:13

- 12 - 
 
signed or produced to Small Business Administration were 
fraudulent and that he and the beneficiaries of the loans (his 
family members and friends) knew they were not entitled to the 
loans.   
28. 
JACKSON also used the stolen identities to rent 
property which he would sublease to tenants who could not 
qualify for the property.  
29. 
JACKSON used cash from his fraud scheme to buy assets 
including a $35,000 commercial truck he paid for in cash. 
30. 
JACKSON acknowledged lying to his probation officer 
about living in Compton when in fact he lived at the Tamarisk 
Address. JACKSON also admitted that he did not disclose his 
income or his loan applications to probation. 
/// 
 
 
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 14 of 15   Page ID #:14

- 13 -
IV.
CONCLUSION
31.
For the reasons stated above, there is probable cause
to believe that BOBBY JOE JACKSON JR violated 18 U.S.C. 1344 and 
1349 (conspiracy to commit bank fraud), and 1028A (aggravated 
identity theft). 
Attested to by the applicant in accordance 
with the requirements of Fed. R. Crim. P. 4.1 
by telephone on this ____ day of April, 2023. 
UNITED STATES MAGISTRATE JUDGE 
WK
39&
STATES MAGISTRAT
Case 2:23-cr-00210-DSF   Document 1   Filed 04/11/23   Page 15 of 15   Page ID #:15

File and source

File

doc-001-Complaint-or-Information-Jackson.pdf

Size

377,873 bytes

SHA-256

30c91073e150366eceeb023fc370efe0a6250abb92edfc41c57e84c1676cc90b

Our copy

doc-001-Complaint-or-Information-Jackson.pdf

Original

No public link identified.