complaint against, and arrest warrants for, Stephen GLOVER (year
- Date
- 2022-05-13
Summary
An affidavit filed May 13, 2022 as Document 1 in Case 2:22-cr-00268-SB, by a Department of Labor Office of Inspector General special agent, supporting a criminal complaint and arrest warrants against Stephen Glover and Travis McKenzie for mail fraud under Title 18, United States Code, Section 1341. The affidavit describes an investigation into Pandemic Unemployment Assistance claims under the CARES Act. It alleges that Glover, a U.S. Postal Service mail carrier, and McKenzie caused more than 50 EDD debit cards containing approximately $800,000 in COVID-related UI benefits to be mailed to addresses primarily along Glover's route. It states that searches in May and June 2021 seized more than 200 pieces of stolen mail and EDD-related mail and debit cards. The 46-page affidavit was attested by telephone before United States Magistrate Judge Douglas F. McCormick.
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
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Case 2:22-cr-00268-SB Document 1 Filed 05/13/22 Page 1 of 46 Page ID #:1
Case 2:22-cr-00268-SB Document 1 Filed 05/13/22 Page 2 of 46 Page ID #:2
A F F I D A V I T
I, Jeffrey Wolf, being duly sworn, declare and state as
follows:
I. PURPOSE OF AFFIDAVIT
I make this affidavit in support of a criminal
complaint against, and arrest warrants for, Stephen GLOVER (year
of birth: 1989) and Travis McKENZIE (year of birth: 1996) for
violating Title 18, United States Code, Section 1341 (Mail
Fraud).
The facts set forth in this affidavit are based upon
my personal observations, my review of the documents and records
discussed herein, my training and experience, and information
obtained from other agents and witnesses. This affidavit is
intended to show merely that there is sufficient probable cause
for the requested complaint and arrest warrants and does not
purport to set forth all of my knowledge of or investigation
into this matter. Unless specifically indicated otherwise, all
conversations and statements described in this affidavit are
related in substance and in part only.
II. BACKGROUND OF SPECIAL AGENT JEFFREY WOLF
I am a Special Agent (SA) with the United States
Department of Labor, Office of Inspector General (DOL-OIG), and
have served in this capacity for a year and a half. I am
presently assigned to the Los Angeles Regional Office. My
responsibilities as a DOL-OIG SA include investigating
Unemployment Insurance (UI) fraud, mail fraud, identity theft,
and other related crimes. I am a graduate of the Federal Law
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Enforcement Training Center (FLETC) in Glynco, Georgia. As part
of the training provided at FLETC, I successfully completed the
Basic Training course, which included, but was not limited to,
courses in criminal and constitutional law. Additionally, I
have completed the Inspector General Academy at FLETC in Glynco,
Georgia. Before my employment with DOL-OIG, I was employed for
five years as an investigator for the DOL, Office of Labor
Management Standards, responsible for conducting civil and
criminal investigations. I also served on active duty with the
United States Coast Guard for more than 13 years, and more than
nine years with the United States Coast Guard Reserve.
Through my training and experience, including
discussions with other law enforcement officers experienced in
investigating crimes involving UI and benefits fraud, I have
become familiar with the methods used by people who commit
benefits fraud offenses.
III. SUMMARY OF PROBABLE CAUSE
The DOL-OIG, United States Postal Service - Office of
Inspector General (USPS-OIG), California Employment Development
Department (EDD), and the Los Angeles County Sheriff’s
Department (LASD) have been investigating a fraudulent scheme in
which perpetrators fraudulently apply for and obtain UI benefits
under the Pandemic Unemployment Assistance (PUA) provisions of
the federal Coronavirus Aid, Relief, and Economic Security
(CARES) Act, a provision that was designed to help unemployed
individuals obtain UI benefits as part of the nation’s response
to the economic harms caused by the COVID-19 pandemic.
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Federal and state law enforcement uncovered and
investigated an unemployment insurance fraud, identity theft,
and mail fraud scheme perpetrated by McKENZIE and GLOVER in 2020
and 2021. GLOVER was a U.S. Postal Service mail carrier at the
time and abused his position to further the fraudulent scheme.
When interviewed, both McKENZIE and GLOVER confessed
to engaging in a scheme to defraud EDD, which included using EDD
debit cards in other people’s names to withdraw thousands of
dollars in cash from ATMs. GLOVER also admitted that to execute
the fraudulent scheme, he used his position as a U.S. Postal
Service mail carrier to assist McKENZIE (who lived on GLOVER’s
mail route) with intercepting, stealing, and possessing U.S.
Mail intended for others. In addition to stealing EDD-related
mail, GLOVER also admitted to stealing personal and business
checks from the U.S. mail.
During the execution of search warrants at the
residences of McKENZIE, GLOVER, and GLOVER’s girlfriend in May
and June 2021, law enforcement discovered and seized
credit/debit cards in the names of other people, many of which
had been issued by state workforce agencies such as California
EDD and Virginia’s Employment Commission. The searches also
revealed large volumes of stolen mail, including personal and
business checks intended for third parties. In total, more than
200 pieces of stolen mail and EDD-related mail and debit cards
were seized during the searches.
Subsequent investigation also uncovered that McKENZIE,
his girlfriend, and GLOVER worked in concert to create fake EDD
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profiles and apply for COVID-related UI benefits, often using
stolen identities, with mailing addresses on GLOVER’s route that
GLOVER had provided.
Thus far, the investigation has uncovered that in
their fraudulent scheme, GLOVER and McKENZIE, together with
other co-schemers, fraudulently caused more than 50 EDD debit
cards containing approximately $800,000 in COVID-related UI
benefits to be mailed to addresses primarily along GLOVER’s mail
route, including McKENZIE’s residence, which were then used to
withdraw cash, transfer funds, or for personal expenditures.
IV. STATEMENT OF PROBABLE CAUSE
A. Background on Unemployment Insurance Benefits
Since 1935, the U.S. Department of Labor’s UI program
has provided unemployment benefits to eligible workers who
become unemployed through no fault of their own. This program
ensures that at least a significant portion of the necessities
of life -- most notably food, shelter, and clothing -- are met
on a weekly basis while the worker seeks employment. UI
beneficiaries who meet the requirements of the applicable state
law are eligible for this temporary financial assistance. Each
state administers a separate UI program within the guidelines
established by Federal law. In the state of California, EDD
administers the UI program for residents and others physically
performing work activities in California.
Generally speaking, regular UI claimants must be:
(1) unemployed through no fault of their own; (2) able and
available for work; (3) willing to accept suitable work; and
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(4) actively seeking work.
B. Pandemic Unemployment Assistance under the federal
CARES Act
On March 13, 2020, the President of the United States
declared COVID-19 to be an emergency under the Robert T.
Stafford Disaster Relief and Emergency Assistance Act. As a
result, Congress passed the CARES Act, which the President
signed into law on March 27, 2020. The CARES Act provides over
$2 trillion in economic relief protections to the American
people for the public health and economic impacts of COVID-19.
Prior to the enactment of the CARES Act, to be
eligible for UI administered by EDD, a person must have been
employed and worked in California and received at least a
certain amount of wages from an employer in the 18 months
preceding his/her UI benefits claim. Because of this
requirement, self-employed workers, independent contractors, and
employees with insufficient earnings were not eligible to
receive regular UI benefits.
The CARES Act established a new program – PUA – to
provide unemployment benefits during the COVID-19 pandemic to
people who do not qualify for regular unemployment insurance
benefits, including business owners, self-employed workers,
independent contractors, and those with a limited work history
who are out of business or have significantly reduced their
services as a direct result of the pandemic. UI benefits
provided under the PUA program are sometimes referred to as PUA
benefits.
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Under the PUA provisions of the CARES Act, a person
who is a business owner, self-employed worker, independent
contractor, or gig worker can qualify for PUA benefits
administered by EDD if s/he previously performed such work in
California and is unemployed, partially unemployed, unable to
work, or unavailable to work due to a COVID-19-related reason. 1
Examples of non-business-owner occupations that may qualify a
person for PUA benefits are realtor, barber, hairstylist,
freelance photographer, construction handyman/woman, gardener,
and ride-share driver. 2
California EDD began accepting applications for PUA
benefits on or about April 28, 2020. To make benefits available
as quickly as possible, payments are issued in phases. If a
1 COVID-19 related reasons for being out of work include:
being diagnosed with COVID-19 or experiencing symptoms of COVID-
19 and seeking a medical diagnosis; being unable to work because
a health care provider advised self-quarantining due to concerns
related to COVID-19; having a household member who has been
diagnosed with COVID-19; providing care for a family or
household member who has been diagnosed with COVID-19; having
primary caregiving responsibility for a child or other household
member who is unable to attend school or another facility that
is closed as a direct result of the COVID-19 and the school or
facility care is required for the claimant to work; becoming the
breadwinner or major support for a household because the head of
household died due to COVID-19; the claimant has quit his/her
job due to COVID-19; the place of employment has closed due to
COVID-19; a job that the claimant was scheduled to start is no
longer available due to the COVID-19 public health emergency; or
the place of employment is inaccessible due to the COVID-19
public health emergency.
2 To be eligible, such person must also not be participating
in the UI Elective Coverage program. Under the provisions of
the California Unemployment Insurance Code (CUIC), employers may
elect UI and State Disability Insurance (SDI) or only Disability
Insurance (DI) coverage for themselves. Self-employed
individuals, who are not employers, may only elect SDI coverage
for themselves.
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claimant qualifies for PUA benefits, the minimum payments are as
follows based on the claim’s start date:
Phase 1: For claims with start dates from February 2
to March 28, 2020, $167 per week for each week the
claimant is unemployed due to COVID-19.
Phase 2: For claims with start dates from March 29 to
July 25, 2020, $167 plus $600 per week for each week
the claimant is unemployed due to COVID-19.
Phase 3: For claims with start dates from July 26 to
December 26, 2020, $167 per week for each week the
claimant is unemployed due to COVID-19.
Phase 4: Phase 4: For claims with start dates from
December 27, 2020, to the end of the program (which
ended on September 4, 2021), $167 plus $300 per week
for each week the claimant is unemployed due to COVID-
19. Claimant may qualify for PUA benefits for up to a
total for up to a total of 57 weeks (minus any regular
UI and FED/ED benefits received). PUA benefits ended
September 4, 2021. The last day one could apply for a
PUA claim was October 6, 2021, for the weeks of
unemployment before September 4, 2021.
PUA applicants may be eligible for more than the
minimum weekly benefit amount of $167 if their annual income for
2019 reported on the PUA application meets a minimum threshold.
A UI claimant can usually collect 26 weeks of regular
state UI benefits. The CARES Act provides for additional
Pandemic Emergency Unemployment Compensation (PEUC), which
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provides up to 13 weeks of additional payments, for a total of
39 weeks of benefits. PEUC is available to persons who were or
are fully or partially unemployed at any time between from March
29 through December 26, 2020. Persons with a regular UI claim,
a PUA claim or a PEUC extension filed between March 29 and July
25, 2020, also receive Federal Pandemic Unemployment
Compensation (“FPUC”), which is the extra $600 per week.
On August 8, 2020, after FPUC expired, the President
of the United States signed a Presidential Memorandum
authorizing FEMA to use disaster relief funds pursuant to
Section 408 Other Needs Assistance of the Stafford Act to
provide supplemental payments for lost wages to help ease the
financial burden on individuals who were unemployed as a result
of COVID-19. The “Lost Wages 10 Assistance Program” (LWAP)
served as a temporary measure to provide an additional $300 per
week via a total of $44 billion in FEMA funds. The period of
assistance for LWAP was August 1, 2020, to December 27, 2020, or
termination of the program, whichever was sooner. On December
27, 2020, the President signed into law the Consolidated
Appropriations Act, 2021. The guidance provides states with
important information about several provisions of the law,
including the extension of programs first authorized by the
CARES Act earlier, as well as the creation of a new UI benefit
for “mixed earners.”
The law extends the PUA program created by the CARES
Act, which provides UI benefits to gig workers and others not
traditionally eligible for them. Under the law, the end of the
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period of applicability for the PUA program extends to those
weeks of unemployment ending on or before March 14, 2021. In
states where the week of unemployment ends on a Sunday, the last
payable week of PUA is the week ending March 14, 2021 (March 13
if weeks of unemployment end on Saturday). For individuals on
PUA who have not exhausted their benefit eligibility of up to 50
weeks, the program also provides for continuing benefits for
eligible individuals for weeks of unemployment through April 5,
2021. The law also strengthens documentation requirements to
ensure PUA program integrity.
Additionally, FPUC, which expired July 31, 2020, is
reauthorized and modified to provide $300 per week to supplement
benefits for weeks of unemployment beginning after December 26,
2020, and ending on or before March 14, 2021. FPUC is not
payable with respect to any week during the gap in
applicability, that is, weeks of unemployment ending after July
31, 2020, through weeks of unemployment ending on or before
December 26, 2020.
On March 21, 2021, the President signed into law the
American Rescue Plan Act (ARPA) of 2021. The law extended
certain programs first authorized by the CARES Act beyond the
expiration date of March 14, 2021, to September 6, 2021. FPUC,
which expired on March 14, 2021, was reauthorized to provide
$300 per week through the week ending on or before September 6,
2021.
Persons applying for PUA benefits do not need to
submit any supporting documents to the EDD with their
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applications. Claimants enter their total income for the 2019
calendar year on the application. The stated income will be
used to pay the minimum benefits of $167 per week. EDD may
request documentation to provide proof of the stated income. 3 If
the income information provided by the PUA claimant meets an
annual earnings threshold of $17,368 or more, the EDD will work
as quickly as possible to verify the claimant’s income using
other resources available to EDD in order to increase the PUA
weekly benefit amount.
Like regular UI claims, PUA claims can be filed
online. When an individual files a PUA claim online, EDD
automatically maintains certain information regarding the filing
of the claim. This information includes the date and time the
claim was submitted, the name of the person for whom the claim
was filed, and the IP address of the computer, or ISP account,
that was used to file the claim.
A PUA claimant must answer various questions to
establish his/her eligibility for PUA benefits. The claimant
must provide his/her name, Social Security Number, and mailing
address. The claimant must also identify a qualifying
occupational status and COVID-19 related reason for being out of
work.
After it accepts a UI claim, including a claim
submitted pursuant to the PUA program, EDD typically deposits UI
funds every two weeks to an EBP debit card administered by the
In general, EDD accepts items such as tax returns, IRS
3
Forms 1099 and W-2, and paystubs as proof of income.
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BofA, which the claimant can use to pay for his/her expenses.
The EBP card is sent via the U.S. Postal Service to the claimant
at the address the claimant provides in their UI claim.
Claimants can activate their debit card over the phone or
online.
When receiving regular UI benefits, a claimant must
complete a Continued Claim Form (DE 4581) and certify every two
weeks, under penalty of perjury, that he/she remains unemployed
and eligible to receive UI benefits. EDD authorizes and
deposits payment to the EBP debit card after it receives the
Continued Claim Form.
Weekly PUA benefits typically range from $40 to $450.
In order to receive the maximum weekly benefit of $450, a
claimant must have earned $11,674.01 or more in the highest
quarter of the claimant's base employment period.
The submission of the PUA claims cause mailings to the
addresses provided on the claims, including mailings of
Electronic Benefit Payment (EBP) debit cards administered by
Bank of America (BofA) that are used to access UI benefits. In
fraudulent claim schemes, co-schemers then use the EBP debit
cards to withdraw fraudulently obtained UI benefits by making
cash withdrawals at Automated Teller Machines and point of sale
(POS) purchases at merchants across the United States.
Based on my training and experience, I know that
individuals scheming to fraudulently obtain UI benefits
generally follow recognizable patterns, including, among other
indicia:
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a. Co-schemers commonly buy or outright steal the
identities of other people to file for fraudulent UI benefits in
the ID-theft victims’ names and then collect the UI funds. Co-
schemers commonly withdraw UI benefits via ATMs or make POS
purchases at merchants for goods and services.
b. Using addresses the schemers control as the
addresses submitted to EDD for the claims so that EBP debit
cards and other EDD correspondence will be mailed to these
addresses and thus be accessible to the schemers.
c. Submitting multiple UI claims from the same IP
address for multiple claimants. These claims are sometimes
submitted on the same day close in time.
d. Failing to provide a phone number or providing a
wrong number on multiple UI claims so it may be difficult to
reach the identity holder.
C. May 2021: Search of McKENZIE and his girlfriend’s
residence
Based on my review of investigative reports and my
conversations with other law enforcement officers and agents who
have participated in this investigation, I am aware of the
following:
a. On or about May 19, 2021, the Honorable Suzette
Clover, Los Angeles County Superior Court, authorized and signed
a search warrant for the residence located at xx841 Arroyo Park
Drive, Apt. 812, Valencia, California 91355 (McKENZIE
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residence 4), and three persons, including McKENZIE.
b. On or about May 20, 2021, the LASD executed the
search warrant at the McKENZIE residence during which they
encountered McKENZIE and D.S.L. Following the search, McKENZIE
and D.S.L. were arrested by LASD. I have reviewed police
reports, evidence, and related items from the warrants executed
by LASD, from which I know the following:
c. During the search of the McKENZIE residence, the
following items were discovered:
i. Over 170 pieces of EDD mail addressed to
more than 50 different names using the McKENZIE residence as
their purported mailing address, while other mailings contained
mailing addresses in Bakersfield, Fresno, Los Angeles, and
Torrance, California. The addressees on the mail included S.P.,
C.S., R.S., D.G., M.S., M.M., W.S., I.T., L.M., K.A., and J.T.
ii. At least five pieces of mail from the
Virginia Employment Commission (VEC) addressed to three 5
different names: S.P., C.S., and R.S.
iii. At least 14 pieces of general mail addressed
to at least nine different names.
iv. A check in the name of R.C. issued from the
4 The lease associated with xx841 Arroyo Park Drive, Apt.
812, Valencia, CA 91355 is in the name of D.S.L and her
(D.S.L.’s) father. During an interview, McKENZIE admitted to
residing at the residence with D.S.L.
5 Duplicative PUA claims were filed with both the EDD and
VEC using the same three identities of S.P., C.S., and R.S.
Claims with both EDD and VEC unemployment insurance claims used
the McKENZIE residence as their mailing address.
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County of Los Angeles.
v. 13 California EDD EBP debit cards in the
names of others:
(I) Card ending in 6643 in the name of K.B.
(II) Card ending in 4290 in the name of I.T.
(III) Card ending in 0419 in the name of
C.R.
(IV) Card ending in 0922 in the name of A.J.
(V) Card ending in 5478 in the name of M.B.
(VI) Card ending in 4629 in the name of S.S.
(VII) Card ending in 1113 in the name of
D.H.
(VIII) Card ending in 2853 in the name of
B.A.
(IX) Card ending in 6369 in the name of D.G.
(X) Card ending in 8846 in the name of W.S.
(XI) Card ending in 9843 in the name of C.S
(XII) Card ending in 6329 in the name of
M.M.
(XIII) Card ending in 6013 in the name of
R.S.
vi. Three VEC debit cards in the names of
others:
(I) Card ending in 4393 in the name of C.S.
(II) Card ending in 0708 in the name of R.S.
(III) Card ending in 4937 in the name of
S.P.
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vii. One Chase Freedom credit card ending in 6780
in the name of T.M.
viii. One Wells Fargo debit/credit card
ending in 9219 in the name of P.A.
ix. Two cell phones
x. Two computers
xi. One iPad
xii. At least four Bank of America (BofA) ATM
withdrawal receipts identifying a total of $4,000 in cash
withdrawals from an ATM in Newhall, California, using the
following debit cards:
(I) California EDD EBP debit card in the
name of K.B., ending in 6643;
(II) California EDD EBP debit card in the
name of W.S., ending in 8846;
(III) California EDD EBP debit card in
the name of C.R., ending in 0419; and
(IV) California EDD EBP debit card in the
name of B.A., ending in 2853.
D. McKENZIE’s arrest and subsequent confession
Based on my review of investigative reports and my
conversations with other law enforcement officers and agents, I
am aware of the following:
a. After McKENZIE was arrested, McKENZIE was
transported to the Crestena Valley Sheriff’s Station Jail where
he was read his Miranda rights and agreed to speak to LASD
Detectives D. Gaisford and L. Phillipi, who then conducted an
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audio-recorded interview of McKENZIE.
b. I reviewed that recording and the police report
of McKENZIE’s interview, from which I learned the following in
part:
i. McKENZIE is originally from New York and was
currently unemployed.
ii. McKENZIE and D.S.L. are the only occupants
who reside at unit 812, also known as xx841 Arroyo Park Drive,
Apt. 812, Valencia, CA (McKENZIE’s residence).
iii. McKENZIE’s cell phone ends in 7096.
iv. McKENZIE acknowledged possessing at least 10
EDD debit cards in the names of others.
v. McKENZIE claimed the EDD debit cards were
supposed to be picked up by the person who got him into “the
EDD.”
vi. McKENZIE and D.S.L tried to help family
members apply for EDD. After applying for D.S.L.’s family
members, McKENZIE and D.S.L failed to receive at least two EDD
debit cards associated with D.S.L.’s family members’ claims.
vii. McKENZIE believed the mailman might have
been responsible for the EDD debit cards not being delivered.
viii. McKENZIE later observed an African
American mailman delivering mail at the community mail box
located at the apartment complex he and D.S.L. lived at in
Valencia, California. During his observations, McKENZIE
allegedly witnessed the mailman stealing mail.
ix. McKENZIE approached the mailman who he knew
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as “Erin” (known to law enforcement as GLOVER) and questioned
the mailman about various undelivered EDD mail to his apartment
(McKENZIE residence). GLOVER reportedly admitted to McKENZIE
that he (GLOVER) was stealing EDD cards.
x. GLOVER allegedly asked McKENZIE to work with
him in exchange for money.
xi. McKENZIE reportedly agreed to accept mail
from EDD in the names of others at his residence (McKENZIE
residence). GLOVER offered McKENZIE between $250 and $500 per
EDD debit card delivered to him (McKENZIE).
xii. McKENZIE sometimes returned the EDD debit
cards to GLOVER after making cash withdrawals at BofA ATMs to
take his “cut.” On a $1,000 withdrawal, McKENZIE would receive
$250 and GLOVER would receive $750.
xiii. McKENZIE admitted to making more than
10, but less than 30, ATM cash withdrawals with EDD cards, and
he said he split the monies associated with those withdrawals
with GLOVER.
xiv. McKENZIE admitted to receiving “a lot” of
mail from EDD in the names of others while working with GLOVER.
xv. McKENZIE was aware of some of the EDD debit
cards having $30,000 to $40,000 balances on them.
xvi. McKENZIE tried making cash withdrawals on
some of the EDD debit cards left at his residence by GLOVER but
the cards had been turned off.
xvii. GLOVER was responsible for delivering
mail in the names of others to McKENZIE’s residence.
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xviii. GLOVER was also responsible for
processing change of addresses with the bank that enabled EDD
debit cards to be routed for delivery to McKENZIE’s residence.
xix. The information needed to change the address
with the bank was the social security number and email
associated with the EDD account.
xx. McKENZIE admitted to receiving personal and
business checks made payable to others that GLOVER had stolen
from the mail.
xxi. McKENZIE was supposed to find a way to cash
them.
xxii. The delivery of EDD debit cards to
McKENZIE’s residence occurred primarily between May and
September 2020.
xxiii. McKENZIE believed the EDD debit cards
were associated with real individuals because California used
Id.me. 6
xxiv. McKENZIE acknowledged corresponding
with GLOVER via text message regarding the scheme.
xxv. On McKENZIE’s phone, GLOVER was saved as
“mailman.”
xxvi. McKENZIE stopped communicating with
GLOVER after the Post Office changed his mail route.
xxvii. McKENZIE admitted to being affiliated
On or about October 5, 2020, EDD implemented ID.me to
6
confirm the identity of applicants. As part of the identity
verification process, a facial recognition scan can be done
using a smart phone.
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with the Mac Baller Bloods gang in New York.
E. June 2021: Searches of GLOVER’s residence and his
girlfriend’s separate residence
Based on my review of investigative reports and my
conversations with other law enforcement officers and agents who
have participated in this investigation, I am aware of the
following:
a. On or about June 15, 2021, the Honorable Suzette
Clover, Los Angeles County Superior Court, authorized and signed
a search warrant for a residence located on Catania Ct.,
Palmdale, CA 93552 (GLOVER Residence), GLOVER’s person, and
GLOVER’s girlfriend A.D.’s residence located on E. Nugent
Street, Lancaster, CA 93534 (A.D. residence.)
b. On or about June 17, 2021, the LASD executed the
search warrants at the GLOVER and A.D. residences. During the
search of the GLOVER residence, GLOVER was encountered there.
Following the search, GLOVER was arrested by LASD. I reviewed
police reports, evidence, and related items from LASD, from
which I know the following:
c. During the search of the GLOVER residence, the
following items were discovered:
i. Three pieces of EDD mail with EDD EBP debit
cards in the names of others:
(I) Card ending in 6752 in the name of S.M.
(II) Card ending in 7444 in the name of R.M.
(III) Card ending in 9467 in the name of
K.Br.
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ii. One cell phone
d. During the search of A.D.’s residence, the
following items were discovered:
i. At least 25 pieces of mail from EDD
addressed to at least 15 different names primarily using mailing
addresses in Valencia and Santa Clarita, California, on GLOVER’s
USPS mail route, including McKENZIE’s residence.
(I) The addressees on the mail included
I.T., L.M., K.A., D.G., D.B., K.B., S.P., and J.T, W.S., J.K.,
R.M., K.Br. and S.M. Mail addressed to the some of those same
names was also located during the search of McKENZIE’s
residence.
ii. 11 personal and business checks made payable
to different names at addresses in the Valencia area, which
appear to be on or near GLOVER’s mail route.
A total of more than 200 pieces of stolen mail were
found during the 2021 searches of McKENZIE and his girlfriend’s
residence, GLOVER’s residence, and GLOVER’s girlfriend’s
residence.
F. GLOVER’s confession
Based on my review of investigative reports and my
conversations with other law enforcement officers and agents
involved in the investigation, I am aware of the following:
a. During the execution of the search warrant at his
residence, GLOVER was detained and read his Miranda rights. On
site, LASD Det. Gaisford, USPS-OIG SA S. Lanzl, and EDD CI I.
Romo conducted an audio-recorded interview of GLOVER.
20
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b. At the conclusion of the search, GLOVER was
arrested and transported to the Crescenta Valley Sheriff Station
where he was Mirandized and interviewed by LASD Detectives
Gaisford and Ventigan, which was recorded.
c. I reviewed the recordings and reports of both of
those interviews, from which I learned the following in part:
i. GLOVER acknowledged being employed by the
USPS at the Valencia Post Office.
ii. GLOVER’s cellular phone number ended in
7787.
iii. GLOVER told law enforcement they were at his
home because of a person he knew as guapo (subsequently
identified as McKENZIE).
iv. GLOVER met McKENZIE on his mail route,
during which MCKENZIE introduced GLOVER to EDD fraud.
v. McKENZIE routed EDD debit cards to addresses
on GLOVER’s mail route, and GLOVER would intercept the EDD debit
cards and provide them to McKENZIE.
vi. McKENZIE was responsible for making the fake
EDD accounts and sending mail to addresses on GLOVER’s route.
vii. McKENZIE did not care if the addresses on
GLOVER’s route were vacant or occupied.
viii. McKENZIE would drive around and ask
GLOVER if certain addresses were part of his mail route.
ix. Initially, McKENZIE did not tell GLOVER he
was going to “put in” EDD applications and send mail to those
addresses.
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x. Shortly after GLOVER met McKENZIE, a lot of
EDD mail started to be sent to addresses on GLOVER’s mail route
addressed to people who GLOVER knew did not live there.
xi. GLOVER kept those pieces of mail, which he
knew was wrong, but he did so because McKENZIE expected GLOVER
to “grab em,” and GLOVER did not want anyone to know McKENZIE
was sending mail to those addresses.
xii. GLOVER stated “I got myself into with him
but he didn’t even f**king know the dude like that, like and was
just, he wouldn’t stop, he’d just keep sending shit, sending
shit…”
xiii. McKENZIE gave GLOVER $1,000 in exchange
for two EDD debit cards that GLOVER had intercepted in the U.S.
Mail.
xiv. GLOVER kept a lot of the EDD mail in his
personal residence, as well as at his girlfriend A.D.’s home.
xv. In addition to stealing the EDD debit cards
from the U.S. mail, GLOVER stole other EDD correspondence sent
in the mail. He did so to avoid returning a lot of EDD mail to
the post office and raising suspicion.
xvi. In addition to intercepting EDD debit cards,
GLOVER stole mail containing checks with the intention of giving
the stolen checks to McKENZIE.
xvii. GLOVER acknowledged knowing that
stealing mail was wrong.
xviii. GLOVER admitted to using two of the EDD
debit cards that he had stolen from the U.S. Mail to make cash
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withdrawals at ATMs in Valencia, California. He estimated that
he withdrew approximately $4,000 to $5,000 from ATMs.
xix. GLOVER activated the EDD debit cards he used
by calling EDD. GLOVER received the PIN by knowing the last
four digits of the SSN associated with the EDD account. GLOVER
received the last four digits of the SSN by intercepting other
EDD mail that contained the last four digits of the SSN.
xx. GLOVER confirmed the mail he stole was on
mail route 46 in zip code 91355.
xxi. When shown a photograph of McKENZIE, GLOVER
positively identified McKENZIE as the person he knew as guapo.
xxii. In addition to stealing EDD-related
mail, GLOVER admitted to stealing approximately 10-11 personal
and business checks from the U.S. mail.
xxiii. GLOVER estimated the value of the
stolen checks to total approximately $22,000.
xxiv. GLOVER specifically recalled discussing
the stolen checks via text message with McKENZIE.
xxv. GLOVER supplied McKENZIE with five or six
addresses on his (GLOVER’s) mail route, which McKENZIE could use
to send EDD mail.
xxvi. GLOVER knew to steal all EDD mail and
provide it to McKENZIE.
xxvii. GLOVER knew McKENZIE needed both the
EDD debit card and the letter from EDD containing the last four
digits of the SSN.
xxviii. GLOVER stopped communicating with
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McKENZIE because he knew what he was doing was wrong and
McKENZIE was a scam artist.
xxix. GLOVER felt bad about stealing mail,
but claimed he did it because he was “broke” and needed money.
G. Text messages between McKENZIE and GLOVER
Based on my review of investigative reports and my
conversations with other law enforcement officers and agents who
have participated in this investigation, I am aware of the
following:
a. DOL-OIG Assistant Special Agent in Charge (ASAC)
Marcus Valle reviewed Cellbrite 7 phone extraction reports of
digital devices seized on May 19, 2021, from McKENZIE and his
girlfriend’s residence, and digital devices seized on June 17,
2021, from GLOVER’s residence, which contained text messages
between MCKENZIE, using phone number ending in 7096, and GLOVER,
using phone number ending in 7787. ASAC Valle provided me with
a sampling of text messages transcriptions between McKENZIE and
GLOVER during which both appear to be discussing their
fraudulent scheme.
b. Based upon my review of the following text
messages, it appears that GLOVER and McKENZIE were working
together to procure and/or use debit cards and/or mail in other
people’s names.
c. On or about December 20, 2020, McKENZIE and
GLOVER had the following conversation via text message:
7 Cellbrite is software program primarily used to review
digital devices and highlight important data.
24
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i. McKENZIE: “Somebody on ur route snatched 2
of my jawns wassup with that?”
ii. McKENZIE: “LMK what time u heading to me bro
I need those been missing days on those”
iii. GLOVER: “Imma be headed out ther in 10 min
bro”
iv. GLOVER: “I should be out there around 1230.”
v. McKENZIE: “Alright bet”
vi. McKENZIE: “Bring all 3 u have gang”
vii. GLOVER: “Bet”
viii. MCKENZIE: “Eta gang”
ix. MCKENZIE: “Lmk”
x. GLOVER: “I’m be hopping off the fwy in 10
bro”
xi. McKENZIE: “Alright Kopy”
xii. McKENZIE: “Lmk when u outside I’m gonna come
outside to u”
xiii. GLOVER: “light Fasho”
xiv. McKENZIE: “Not trynna rush just missed mad
days and they starting to cut niggas cards off and shit”
xv. GLOVER: “Nah you good bro I know them days
be running out quick that’s why I’m tryna get it to u”
d. Between on or about December 28, 2020, and on or
about December 29, 2020, MCKENZIE and GLOVER had the following
conversation via text message:
i. McKENZIE: “Gonna send something along the
route gonna text u the name to grab it for me Brody”
25
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ii. GLOVER: “Yo I got u might have to pull a
couple of strings cuz I’m out rn jus take care of me bro and I
got u fasho”
iii. McKENZIE: “light I got y for sure gang”
iv. McKENZIE: “Send me a few addresses along ur
route gang”
v. McKENZIE: “Addys vrody”
vi. McKENZIE: “Brody need it rn lol”
e. On or about January 19, 2021, GLOVER and McKENZIE
had the following text message conversation:
i. GLOVER: “xxx616 moreno dr 91355”
“xx706 via thomas dr 91355”
“xx055 bellis dr 91355”
“xx049 bellis dr 91355”
“xx025 arroyo park dr #15 91355”
“xx091 bellis dr 91355”
ii. McKENZIE: “Gonna do 3 cards to each address
the most”
iii. McKENZIE: “Bet good looks gang the ones
without apartment numbers is houses?”
iv. GLOVER: “All good just lmk when u send em so
I’ll be on the lookout”
v. GLOVER: “Yea the ones with no numbers is
cribs”
vi. McKENZIE: “And anything u see going to my
address grab it and lmk”
vii. GLOVER: “Gotchu”
26
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f. On or about January 20, 2021, McKENZIE and GLOVER
had the following text message conversation:
i. McKENZIE: “Yoo”
ii. GLOVER: “Yo”
iii. McKENZIE: “If u run into real cc and real
checks u know what to do I pay fir [sic] those too”
iv. GLOVER: “Bet i kinda got a nigga I be juggin
wit but I’ll fucc with you if it’s good money”
v. McKENZIE: “Facts bro always good bred with
me”
vi. GLOVER: “Fasho imam keep you tapped in bro”
vii. McKENZIE: “Look out for 5 yards on ur route”
viii. McKENZIE: “Any credit cards or debit
cards that come through too we could do sum with them”
g. On or about January 22, 2021, McKENZIE sent the
following text message to GLOVER:
i. McKENZIE: “Yoo, if u cN [sic] find me
personal chase checks grab them shits we can be millionaire”
ii. McKENZIE: “Yoo hit me”
h. On or about January 23, 2021, McKENZIE and GLOVER
had the following conversation via text message:
i. McKENZIE: “Lmk which house/bank it’s from”
ii. GLOVER: “They all different banks and shit
hella different address”
iii. McKENZIE: “Oh they all add up to 22k not
just one is 22k?”
iv. GLOVER: “Yea”
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v. GLOVER: “Couple big ones and some baby ones”
vi. GLOVER: “Hit me when u can so we can chop I
ain’t tryna send no info thru text”
i. Between on or about January 28 and 31, 2021,
MCKENZIE and GLOVER had the following conversation via text
message:
i. McKENZIE: “J[] K[] 8”
ii. McKENZIE: “xx016 Monteno Dr
iii. McKENZIE: “Yoooo hit me”
iv. McKENZIE: “Yooo please tell me u still on
that route gang like 10 cards landing today”
v. GLOVER: “Yea I’m still on it we don’t do
mail on Sunday g tomorrow they should be there”
j. Between on or about February 11 and 12, 2021,
McKENZIE and GLOVER had the following conversation via text
message:
i. McKENZIE: “J[] K[]”
ii. McKENZIE: “xx016 Moreno Drive, Valencia, CA
91355”
iii. McKENZIE: “Yooo gang”
iv. McKENZIE: “Hit me Brody”
v. GLOVER: “Yowhats good I still aint see no
card come thru yet just the papers with the socials.still
waiting”
8 J.K. is an identity that was used to file a PUA
application with EDD.
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vi. McKENZIE: “Grab those for me too gang”
vii. GLOVER: “I know wassup”
H. Text messages between McKENZIE and D.S.L.
Based on my review of investigative reports and my
conversations with other law enforcement officers and agents who
have participated in this investigation, I am aware of the
following:
a. ASAC Valle reviewed Cellbrite phone extraction
reports of digital devices seized on May 20, 2021, from the
residence of MCKENZIE and his girlfriend D.S.L., which contained
text messages between MCKENZIE, using phone number ending in
7096, and D.S.L., using phone number ending in 7467. ASAC Valle
informed me that between in or around August 2020 and in or
around April 2021, McKENZIE and D.S.L. appeared to discuss the
scheme and actions they took to execute the scheme.
b. According to ASAC Valle, McKENZIE and D.S.L.
engaged in text messages where they appeared to discuss
defrauding various state unemployment insurance programs,
including California and Virginia. McKENZIE and D.S.L. used
text messages to send and receive directions necessary to
execute the scheme, such as:
i. Sending PII of others to McKENZIE to use in
the filing of fraudulent UI applications.
ii. Identifying physical addresses to be used in
order to route UI benefit cards to McKENZIE, which included
D.S.L.’s and McKENZIE’s residential address in Valencia,
California, as well as addresses of D.S.L.’s family and friends
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who resided in the Bakersfield, California, area.
iii. Creation of “fake” email accounts in the
names of others to be used when creating EDD profile accounts
during the application process.
iv. Sending and receiving lists of EDD applicant
names, some of which were ID theft victims, so that D.S.L and/or
her family and friends could be on notice to receive mail in
those names.
v. Directives to receive/retrieve EDD mail and
other correspondence.
vi. Conducting EDD weekly certifications to
enable benefits to be issued.
vii. Solicitation of names, social security
numbers, driver’s license numbers, and dates of birth of
identities, which could be used by McKENZIE to file fraudulent
UI applications.
c. In addition to the above, McKENZIE and D.S.L.
appeared to acknowledge the criminal activity occurring on a
number of different occasions, which the following conversations
exemplify.
According to ASAC Valle’s review of Cellbrite phone
extraction reports and text message transcriptions, McKENZIE and
D.S.L had the following conversations via text messages on or
about the following dates:
a. August 18, 2020: MCKENZIE sent D.S.L. a list of
10 names of EDD applicants whose EDD cards MCKENZIE was routing
to an address affiliated with D.S.L. in Bakersfield.
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b. September 8, 2020: McKENZIE tells D.S.L. the
following with respect to her IP address…“?? I dint want them
having our IP address when I’m calling up the cards etc”
c. October 3, 2020:
i. McKENZIE: “They just pulling over ppl
randomly in LA now to see if they have EDD cards on them”
ii. D.S.L.: “sigh”
iii. D.S.L.: “you alright right”
iv. D.S.L.: “you don’t have none right?”
d. October 24, 2020: McKENZIE tells D.S.L. the
following in part“... I’m about to come back to California and
do some more EDD cause I came out here to get a 18wheeler to
start my business and I did that now it’s time to work on my
money.”
e. November 9, 2020: McKENZIE and D.S.L. had the
following conversation via text message:
(I) McKENZIE: “Trying to get ppl to sign up
for California Edd verify themselves then send me they login if
u know anyone that need my help getting it too Lmk love.”
(II) D.S.L.: “okay I will”
f. January 22, 2021: McKENZIE states the following
to D.S.L.: “60 apps is 1.8 mil”
g. March 3, 2021: McKENZIE tells D.S.L. that “I’m
gonna teach u how to do Virginia unemployment love and give u
some pros to use so u can make a lot of money too.”
h. May 19, 2021: McKENZIE informs D.S.L. of a
problem activating what is believed to be an EDD card, stating
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“…I did 2 other ppp’s that was been supposed to come but they
not here yet like shit still say pending this dumb ass nigga
still ain’t send the pic so can’t activate these cards and
fucking edd cut the cards I got off talking bout verify the
addresses and I need money to even get the fake proof of
addresses made Smfh it’s a lot I be having to deal with fr fr”
i. On multiple occasions, McKENZIE texted D.S.L.
that he is “doing apps” (believed to be referring to the
electronic filing of UI applications with EDD).
I. Research re: EDD Cards tied to McKENZIE and/or GLOVER
Based on my review of investigative reports and my
conversations with other law enforcement officers and agents who
have participated in this investigation, I am aware of the
following:
a. On July 23, 2021, BofA investigator J. Wilkinson
informed ASAC Valle that at least 23 EDD EBP debit cards
containing unemployment insurance benefits were mailed by BofA
to McKENZIE’s residence in Valencia, California. Of those 23
EDD EBP debit cards, 22 were in the names of others, and one was
in the name of D.S.L.
b. In addition to the EDD EBP debit cards mailed to
McKENZIE’s residence, BofA identified a link between the above
referenced claims and two EDD EBP debit cards mailed to xx016
Moreno Drive, Valencia, CA (which the investigation identified
as an address provided to McKENZIE by GLOVER).
c. As of July 12, 2021, BofA reported that the above
25 EDD EBP debit cards had been loaded with a total benefit
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amount of $411,626. At least $318,771 of that $411,626 had been
liquidated via ATM cash withdrawals, direct deposit funds
transfer to checking/savings, purchase of goods or services, and
teller cash withdrawals.
d. Between in or around February and March 2022, EDD
Criminal Investigator (CI) Ignacio Romo identified additional
claims associated with this fraudulent scheme, which brought the
suspected total loss of GLOVER and McKENZIE’s fraudulent scheme
to approximately $798,733, based upon approximately 52
fraudulent PUA claims. Of those 52 claims, 44 claims listed the
McKENZIE residence as the mailing address, five claims listed
two other addresses in the Valencia/Santa Clarita area of Los
Angeles, three claims used two addresses in Bakersfield,
California, and one claim listed an address in Hayward,
California. 9
e. Four of the 13 EDD debit cards found during the
search of McKENZIE’s residence were used to make cash
withdrawals at a drive-thru ATM on or about December 18, 2020,
for the following amounts:
i. CA EDD debit card in the name of K.B.,
ending in 6643 in the amount of $1,000.
ii. CA EDD debit card in the name of C.R.,
ending in 0419 in the amount of $1,000.
9 Both of the Bakersfield addresses were used in the
applications for EDD cards that were found during the search of
McKENZIE’s residence. Likewise, the Hayward address was used in
the applications for an EDD card that was found during the
search of McKENZIE’s residence.
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iii. CA EDD debit card in the name of B.A.,
ending in 2853 in the amount of $1,000.
iv. CA EDD debit card in the name of W.S.,
ending in 8846 in the amount of $1,000.
f. ASAC Valle obtained ATM surveillance photos from
BofA, which revealed that on or about December 18, 2020, a male
fitting the physical description of McKENZIE made cash
withdrawals from a BofA drive-thru ATM between 9:06 p.m. and
9:10 p.m. using a silver four door sedan. 10
J. Victim K.B.
As noted above, one of the EDD EBP debit cards that
McKENZIE used to make a cash withdrawal of at least $1,000,
which was also found in McKENZIE’s residence when it was
searched, was in the name of K.B.
Based on my review of records provided to me by EDD
and conversations with other agents and investigators who have
participated in this investigation, I know the following:
a. On or about November 24, 2020, a PUA claim in the
name of K.B. was filed with EDD, stating that claimant K.B. was
unemployed because of the COVID-19 pandemic.
b. The PUA application contained K.B.’s name, date
of birth (DOB), Social Security Number (SSN), and alleged that
K.B. was employed as an assembler/production. The claim
identified a last employer as Paramount Pictures.
10Based upon observations during the 2021 searches,
McKENZIE’s girlfriend D.S.L drives a vehicle matching the
physical description of the vehicle depicted on those ATM
surveillance photographs.
34
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c. The claim listed McKENZIE’s residential address
as K.B.’s reported mailing address.
d. The filing of the PUA claim triggered an EBP
debit card ending in 6643 in the name of K.B. to be generated
and sent by U.S. Mail to K.B. at the listed mailing address,
which was McKENZIE’s residence.
On or about April 21, 2022, ASAC Valle interviewed
K.B. by telephone regarding the PUA claim that had been filed in
K.B.’s name. Based on ASAC Valle’s report, I know that K.B.
told ASAC Valle the following:
a. K.B. has never resided or worked in, nor visited,
California.
b. K.B. confirmed that the DOB and SSN provided on
the PUA claim in her name belonged to her.
c. K.B. had never been employed as an
assembler/production.
d. K.B. never lived in Valencia, California.
e. K.B. never filed a PUA claim with California EDD
and did not authorize anyone to file a claim in his or her name.
K. Victim W.S.
As noted above, one of the EDD EBP debit cards that
McKENZIE used to make a cash withdrawal of at least $1,000,
which was also found in McKENZIE’s residence when it was
searched, was in the name of W.S.
Based on my review of records provided to me by EDD
and conversations with other agents and investigators who have
participated in this investigation, I know the following:
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a. On or about November 19, 2020, a PUA claim in the
name of W.S. was filed with EDD, stating that claimant W.S. was
unemployed because of the COVID-19 pandemic.
b. The PUA application contained W.S.’s name, DOB,
SSN, and alleged that W.S. was employed as an
assembler/production. The claim identified a last employer as
Paramount Pictures.
c. The claim listed McKENZIE’s residential address
as W.S.’s reported mailing address
d. The filing of the PUA claim triggered an EBP
debit card ending in 8846 in the name of W.S. to be generated
and sent by U.S. Mail to W.S. at the listed mailing address,
which was McKENZIE’s residence.
On or about April 21, 2022, ASAC Valle interviewed
W.S. by telephone regarding the PUA claim that had been filed in
W.S.’s name. Based on ASAC Valle’s report, I know that W.S.
told ASAC Valle the following:
a. W.S. has never resided in, worked in, or visited
the State of California.
b. W.S. had never been employed as an
assembler/production.
c. W.S. never lived in Valencia, California.
d. W.S. never filed a PUA claim with EDD.
L. Victim M.M.
As noted above, one of the EDD EBP debit cards that
was found in McKENZIE’s residence when it was searched was in
the name of M.M.
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Based on my review of records provided to me by EDD
and conversations with other agents and investigators who have
participated in this investigation, I know the following:
a. On or about February 4, 2021, a PUA claim in the
name of M.M. was filed with EDD, stating that claimant M.M. was
unemployed because of the COVID-19 pandemic.
b. The PUA application contained M.M.’s name, DOB,
SSN, and alleged that M.M. was employed as an
assembler/production line. The claim identified a last employer
as Paramount Pictures.
c. The claim listed McKENZIE’s residential address
as M.M.’s reported mailing address.
d. The filing of the PUA claim triggered an EDD EBP
debit card ending in 6329 in the name of M.M. to be generated
and sent by U.S. Mail to M.M. at the listed mailing address,
which was McKENZIE’s residence.
On or about February 7, 2022, ASAC Valle interviewed
M.M. by telephone regarding the PUA claim that had been filed in
M.M.’s name. Based on ASAC Valle’s report, I know that M.M.
told ASAC Valle the following:
a. M.M. has never resided in, worked in, or visited
the State of California.
b. M.M. was never employed as an assembler.
c. M.M. never lived in Valencia, California, and was
not familiar with the address xx841 Arroyo Park Drive, Apt. 812,
Valencia, California 91355 (McKENZIE’s residence).
d. M.M. did not have any friends or associates who
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reside in California.
e. M.M. never filed a PUA claim with EDD and did not
authorize anyone to file a claim in his or her name.
f. M.M. did not know McKENZIE.
M. Victim C.S.
As noted above, one of the EDD EBP debit cards that
was found in McKENZIE’s residence when it was searched was in
the name of C.S.
Based on my review of records provided to me by EDD
and conversations with other agents and investigators who have
participated in this investigation, I know the following:
a. On or about November 11, 2020, a PUA claim in the
name of C.S. was filed with EDD, stating that claimant C.S. was
unemployed because of the COVID-19 pandemic.
b. The PUA application contained C.S.’s name, DOB,
SSN, and alleged that C.S. was employed as an
assembler/production. The claim identified a last employer as
Paramount Pictures.
c. The claim listed McKENZIE’s residential address
as C.S.’s mailing address.
d. The filing of the PUA claim triggered an EDD EBP
debit card ending in 9843 in the name of C.S. to be generated
and sent by U.S. Mail to C.S. at the listed mailing address,
which was McKENZIE’s residence.
On or about February 7, 2022, ASAC Valle interviewed
C.S. by telephone regarding the PUA claim that had been filed in
C.S’s name. Based on ASAC Valle’s report, I know that C.S. told
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ASAC Valle the following:
a. C.S. has never resided or worked in, nor visited,
California.
b. C.S. was never employed by Paramount Pictures.
c. During the pandemic, C.S. was employed by Dave
and Busters.
d. C.S.’s employment was negatively impacted by
COVID-19, resulting in C.S. receiving UI benefits in New York.
e. C.S. was not familiar with the address xx841
Arroyo Park Drive, Apt. 812, Valencia, California (McKENZIE’s
residence).
f. C.S. never filed a PUA claim with EDD and did not
authorize anyone to file a claim in his or her name.
N. Victim M.S.
As noted above, EDD mail in the name of M.S. was found
in McKENZIE’s residence when it was searched.
Based on my review of records provided to me by EDD
and conversations with other agents and investigators who have
participated in this investigation, I know the following:
a. On or about August 16, 2020, a PUA claim in the
name of M.S. was filed with EDD, stating that claimant M.S. was
unemployed because of the COVID 19 pandemic.
b. The PUA application contained M.S.’s name, DOB,
SSN, and identified M.S. as self-employed.
c. The claim listed McKENZIE’s residential address
as M.S.’s mailing address.
d. The filing of the PUA claim triggered an EDD EBP
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debit card ending in 0146 in the name of M.S. to be generated
and sent to by U.S. Mail to M.S. at the listed mailing address,
which was McKENZIE’s residence.
On or about February 7, 2022, ASAC Valle interviewed
M.S. by telephone regarding the PUA claim that had been filed in
M.S’s name. Based on ASAC Valle’s report, I know that M.S. told
ASAC Valle the following:
a. M.S. has never resided or worked in the State of
California.
b. M.S. was never self-employed or worked as a bank
teller.
c. M.S. was not familiar with the address xx841
Arroyo Park Drive, Apt. 812, Valencia, California (McKENZIE’s
residence).
d. M.S. never filed a PUA claim with EDD and did not
authorize anyone to file a claim in his or her name.
O. Victim R.M.
As noted above, one of the EDD EBP debit cards that
was found in GLOVER’s residence when it was searched was in the
name of R.M.
Based on my review of records provided to me by EDD
and conversations with other agents and investigators who have
participated in this investigation, I know the following:
a. On or about August 20, 2020, a PUA claim in the
name of R.M. was filed with EDD, stating that claimant R.M. was
unemployed because of the COVID-19 pandemic.
b. The PUA application contained R.M.’s name, DOB,
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SSN, and identified R.M.’s occupation as a cook.
c. The claim listed a residential address in
Lancaster, California.
d. After the application was filed, the address was
changed to xx015 Cooper Hill Drive, #4302, Valencia,
California. 11
e. The filing of the PUA claim triggered an EDD EBP
debit card ending in 7444 in the name of R.M. to be generated
and sent using the U.S. Mail in the name of R.M to the Valencia
address, which was on GLOVER’s mail route.
On or about February 23, 2022, ASAC Valle interviewed
R.M. by telephone regarding the PUA claim that had been filed in
R.M.’s name. Based on ASAC Valle’s report, I know that R.M.
told ASAC Valle the following:
a. R.M. resides in Little Rock, Arkansas.
b. R.M. has never resided or worked in the State of
California.
c. R.M. was never employed as a cook.
d. In or about April or May 2020, R.M.’s employer
informed R.M. that R.M.’s identity had been stolen.
e. R.M. was not familiar with the Valencia address
to which the EDD EBP debit card in his/her name had been mailed.
(As noted above, that was an address on GLOVER’s USPS mail
route.)
11xx015 Cooper Hill Drive, #4302, Valencia, California was
an address on GLOVER’s USPS mail route. Review of text messages
between GLOVER and McKENZIE revealed the address was supplied to
McKENZIE as an address that could be used.
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f. R.M. never filed a PUA claim with EDD and did not
authorize anyone to file a claim in his or her name.
g. R.M. did not authorize anyone to possess mail in
R.M.’s name at any addresses including the above referenced
Valencia address.
P. Victim K.Br.
As noted above, an EDD EBP debit card in the name of
K.Br. was found in GLOVER’s residence when it was searched.
Based on my review of records provided to me by EDD
and conversations with other agents and investigators who have
participated in this investigation, I know the following:
a. On or about August 24, 2020, a PUA claim in the
name of K.Br. was filed with EDD, stating that claimant K.Br.
was unemployed because of the COVID-19 pandemic.
b. The PUA application contained K.Br.’s name, DOB,
SSN, and identified K.Br.’s occupation as a cook.
c. The claim listed a residential address in
Hesperia, California.
d. After the application was filed, the address was
changed to an address in Valencia on GLOVER’s mail route.
e. The filing of the PUA claim triggered an EDD EBP
debit card ending in 9467 in the name of K.Br. to be generated
and sent by U.S. Mail to K.Br. at the Valencia address, which
was on GLOVER’s mail route.
On or about February 23, 2022, ASAC Valle interviewed
K.Br. by telephone regarding the PUA claim that had been filed
in K.Br.’s name. Based on ASAC Valle’s report, I know that
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K.Br. told ASAC Valle the following:
a. K.Br. resides in Texas.
b. K.Br. has never resided or worked in the State of
California.
c. K.Br. was not familiar with the Valencia address
to which the EDD EBP debit card in K.Br.’s name had been mailed.
d. K.Br. never filed a PUA claim with EDD, and did
not authorize anyone to file a claim in his or her name.
e. K.Br. did not authorize anyone to possess mail
addressed to K.Br. at any addresses, including the above
referenced Valencia address.
Q. Other stolen mail
As noted above, different pieces of EDD-related mail
addressed to the same person, S.M., including an EDD EBP debit
card ending in 6752, were found at separate locations - at
GLOVER’s residence and the residence of his girlfriend A.D. 12
On or about February 23, 2022, ASAC Valle interviewed
S.M. by telephone regarding the EDD mail addressed to S.M. that
was seized during the searches of the GLOVER and A.D.
residences. Based on ASAC Valle’s report, I know that S.M. told
ASAC Valle the following:
a. S.M. currently resides in Castaic, California,
but previously resided at xx853 Arroyo Park Drive, Apt. 309,
Valencia, California 91355 (an address on GLOVER’s mail route).
12During his interview with law enforcement, GLOVER
admitted to stealing and storing mail matter at his girlfriend
A.D.’s home.
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b. S.M. had not received EDD benefits since 2017,
and was unaware of how an EDD EBP debit card would have been
issued in his/her name and sent to his/her previous address.
c. S.M. was not impacted by the COVID-19 pandemic.
d. S.M. did not authorize anyone to possess mail, to
include correspondence from EDD and/or an EDD EBP debit card
addressed to S.M.’s previous address on Arroyo Park Drive in
Valencia, CA 91355.
R. GLOVER’s termination from USPS employment
Based on my review of investigative reports and my
conversations with other law enforcement officers and agents who
have participated in this investigation, I am aware of the
following:
a. On or about June 17, 2021, the USPS suspended
GLOVER without pay from his position as a mail carrier for
potential loss of mail or funds.
b. On or about August 18, 2021, USPS informed GLOVER
in writing of a Notice of Removal (NOR) from his position of
mail carrier. The NOR informed GLOVER that the USPS intended to
terminate GLOVER within 30 days from the date of receipt of the
letter (August 25, 2021). The reason for the NOR was “failure to
follow instructions/unacceptable conduct-mail theft.”
Specifically, the NOR referenced the following reasons for the
actions taken by the USPS in part:
i. Possession of EDD mail and other mail matter
by GLOVER at his residence and vehicle.
ii. Admission to law enforcement that GLOVER had
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stolen mail on route 046 in zip code 91355.
V. CONCLUSION
Based on the information set forth above, there is
probable cause to believe that Stephen GLOVER and Travis
McKENZIE violated Title 18, United States Code, Section 1341
(Mail Fraud).
Therefore, I respectfully request that the Court issue
the complaint and two arrest warrants.
Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1 by
telephone on this 13th
____ day of May
2022.
DOUGLAS F. McCORMICK
HONORABLE DOUGLAS F. McCORMICK
UNITED STATES MAGISTRATE JUDGE
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