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Brandy Iglesias — Felony Complaint, Superior Court of the State of California, County of Sacramento

Summary

Felony complaint dated August 11, 2022, filed by Attorney General Rob Bonta in the Superior Court of the State of California, County of Sacramento, against Brandy Iglesias. It charges false statements to obtain unemployment insurance benefits under Unemployment Insurance Code section 2101(a), grand theft, forgery and unauthorized use of personal identifying information. One count alleges $51,750 in benefits obtained from April 28, 2020 through September 15, 2021; others concern applications filed with the Employment Development Department in the names of other people, including Scott Peterson and Cary Stayner. It also alleges a 2005 robbery conviction in the County of Contra Costa.

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ROB BONTA
Attorney General of California
JAMES ROOT
Senior Assistant Attorney General
RANDY MAILMAN
Supervising Deputy Attorney General
State Bar No. 246134
MYLES CAMPBELL
State Bar No, 299145
MARGARBT PETTIGREW
State Bar No, 284960
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: (916) 860-4802
_ Fax: (916) 322-2368
Attorneys for the People of the State of California

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SACRAMENTO

PEOPLE OF THE STATE OF Case No,
CALIFORNIA,

Plaintiff,

FELONY COMPLAINT

BRANDY IGLESIAS,

Defendant,

The Attorney General of the State of California hereby accuses BRANDY IGLESIAS of
the following criminal offenses:
COUNT ONE

(OFFERING A FALSE STATEMENT TO OBTAIN UNEMPLOYMENT INSURANCE
BENEFITS)

On or about April 7, 2020, in the County of Sacramento, the crime of OFFERING A
FALSE STATEMENT, REPRESENTATION OR CONCEALMENT TO OBTAIN

UNEMPLOYMENT INSURANCE BENEFITS, in violation of Unemployment Insurance Code
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Felony Complaint
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section 2101 (a), a felony, was committed by BRANDY IGLESIAS, who did knowingly make a
false statement or representation, or fail to disclose a material fact, when making an application
for unemployment benefits filed with the Employment Development Department of the State of

California in the name of Brandy Iglesias.

COUNT TWO
(GRAND THEFT BY FALSE PRETENSES)

On or about the period of April 28, 2020 through September 15, 2021, in the County of
Sacramento, the crime of GRAND THEFT, in violation of Penal Code section 487(a), a felony,
was committed by BRANDY IGLESIAS, who knowingly and designedly, by a false and
fraudulent representation and pretense, obtained money, real and personal property by fraud,
which had a value exceeding Nine Hundred Fifty Dollars ($950), to wit: Unemployment

Insurance benefits in the amount of $51,750.

COUNT THREE
(OFFERING A FALSE STATEMENT TO OBTAIN UNEMPLOYMENT INSURANCE

On or about June 16, 2020, in the County of Sacramento, the crime of OFFERING A
FALSE STATEMENT, REPRESENTATION OR CONCEALMENT TO OBTAIN
UNEMPLOYMENT INSURANCE BENEFITS, in violation of Unemployment Insurance Code
section 2101(a), a felony, was committed by BRANDY IGLESIAS, who did knowingly make a
false statement or representation, or fail to disclose a material fact, when making an application
for unemployment benefits filed with the Employment Development Department of the State of

California in the name of Scott Peterson.

Felony Complaint
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COUNT FOUR

(FORGERY)
On or about June 16, 2020, in the County of Sacramento, the crime of FORGERY, in

violation of Penal Code section 470(a), a felony, was committed by BRANDY IGLESIAS, who
knowingly and with intent to defraud, falsely signed the name of another person to a contract for
money submitted under penalty of perjury, to wit: application for unemployment benefits filed
with the Employment Development Department of the State of California in the name of Scott

Peterson,

COUNT FIVE

(UNAUTHORIZED USE OF PERSONAL IDENTIFYING INFORMATION)
On or about June 16, 2020, in the County of Sacramento, the crime of UNAUTHORIZED

USE OF PERSONAL IDENTIFYING INFORMATION, in violation of Penal Code section
530,5(a), a felony, was committed by BRANDY IGLESIAS, who willfully obtained the personal
identifying information of another person and used that information for an unlawful purpose, to
wit: fraudulently obtaining unemployment benefits from the Employment Development

Department of the State of California, using the name of Scott Peterson.

COUNT SIX

(GRAND THEFT BY FALSE PRETENSES)
On or about the period of June 18, 2020 through January 7, 2020, in the County of

Sacramento, the crime of GRAND THEFT, in violation of Penal Code section 487(a), a felony,
was committed by BRANDY IGLESIAS, who knowingly and designedly, by a false and
fraudulent representation and pretense, obtained money, real and personal property by fraud,
which had a value exceeding Nine Hundred Fifty Dollars ($950), to wit: Unemployment

Insurance benefits intended for Scott Peterson in the amount of $18,562.

Felony Complaint
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COUNT SEVEN

(OFFERING A FALSE STATEMENT TO OBTAIN UNEMPLOYMENT INSURANCE
BENEFITS)

On or about July 21, 2020, in the County of Sacramento, the crime of OFFERING A
FALSE STATEMENT, REPRESENTATION OR CONCEALMENT TO OBTAIN
UNEMPLOYMENT INSURANCE BENEFITS, in violation of Unemployment Insurance Code
section 2101 (a), a felony, was committed by BRANDY IGLESIAS, who did knowingly make a
false statement or representation, or fail to disclose a material fact, when making an application
for unemployment benefits filed with the Employment Development Department of the State of

California in the narne of Cary Stayner.

COUNT EIGHT
(FORGERY)
On or about July 21, 2020, in the County of Sacramento, the crime of FORGERY, in

violation of Penal Code section 470(a), a felony, was committed by BRANDY IGLESIAS, who
knowingly and with intent to defraud, falsely signed the name of another person to a contract for
money submitted under penalty of perjury, to wit: application for unemployment benefits filed
with the Employment Development Department of the State of California in the name of Cary

Stayner,

COUNT NINE

(UNAUTHORIZED USE OF PERSONAL IDENTIFYING INFORMATION)
On or about July 21, 2020, in the County of Sacramento, the crime of UNAUTHORIZED

USE OF PERSONAL IDENTIFYING INFORMATION, in violation of Penal Code section

530. 5(a), a felony, was committed by BRANDY IGLESIAS, who willfully obtained the personal
identifying information of another person and used that information for an unlawful purpose, to
wit; fraudulently obtaining unemployment benefits from the Employment Development

Department of the State of California, using the name of Cary Stayner,
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COUNT TEN

(GRAND THEFT BY FALSE PRETENSES)
On or about the period of September 11, 2020 through November 16, 2020, in the County

of Sacramento, the crime of GRAND THEFT, in violation of Penal Code section 487(a), a felony,
was committed by BRANDY IGLESIAS, who knowingly and designedly, by a false and
fraudulent representation and pretense, obtained money, real and personal property by fraud,
which had a value exceeding Nine Hundred Fifty Dollars ($950), to wit: Unemployment

Insurance benefits intended for Cary Stayner in the amount of $20,194.
ALLEGATIONS

ITIS FURTHER ALLEGED, as to COUNT ONE through COUNT TEN, that pursuant to Penal
Code Sections 1170.12(a) through 1170.12(d) and 667(b) through 667(i), the said defendant,
Brandy Iglesias, has suffered the following prior conviction ofa serious or violent felony: Penal
Code section 212.5, Robbery in the First Degree, on October 5, 2005, in the County of Contra

Costa,

Pursuant to Penal Code Section 1054.5(b), the People hereby informally request
that defense counsel provide the People with discovery as required by Penal Code section
1054.3.

DECLARATION

I verify under information and belief, pursuant to Penal Code section 806, that the forgoing

is true and correct.

Felony Complaint
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Dated; August 11, 2022

Respectfully Submitted,

ROB BONTA
Attorney Genera! of California

JAMES ROOT
Senior Assistant Attorney General

RANDY MAILMAN
Supervising Deputy Attorney General

MYLES CAMPBELL
Deputy Attorney General

MARGARET PETTIGREW

Deputy Attorney General

Attorneys for the People of the State of
California

Felony Complaint

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