Criminal Complaint — United States v. Sequoia Edwards (No. 5:21-mj-00239, C.D. Cal.)

Summary

A Criminal Complaint (AO 91) in United States of America v. Sequoia Edwards, Case No. 5:21-mj-00239, in the U.S. District Court for the Central District of California, filed April 2, 2021 as Document 1. It charges fraud in connection with emergency benefits and wire fraud under 18 U.S.C. Sections 1040, and 1343, for conduct from July 2020 to August 2020. The affidavit of FBI Special Agent Stephen Harrison describes the PUA unemployment program administered by the California EDD and alleges that UI claims were filed from an IP address associated with Edwards. It states that on September 6, 2020 eight Bank of America accounts linked to those claims each made $1,000 ATM cash withdrawals at a Moreno Valley location within 10 minutes of each other. The complaint was attested before the Honorable Sheri Pym, United States Magistrate Judge.

Summary drafted by a model from the text of the original file linked on this page 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

Cite this document

“Criminal Complaint — United States v. Sequoia Edwards (No. 5:21-mj-00239, C.D. Cal.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-no-5-21-mj-00239-dkt-1-c-d-cal-e9c46cd88d/, SHA-256 e530efa38e6b50073b51ba862d85aafd0da7273fd8e8a78b9d482f8dcffd0e9c.

Full text

Case 5:21-mj-00239-DUTY Document 1 Filed 04/02/21 Page 1 of 28 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint

LODGED
CLERK, U.S. DISTRICT COURT UNITED STATES DISTRICT COURT
for the
04/02/2021 Central District
__________ of of
District California
__________
CENTRAL DISTRICT OF CALIFORNIA
AP
BY: ____________BB______ DEPUTY
United States of America ) April 2, 2021
v. )
Sequoia Edwards
) Case No. KC
) 5:21-mj-00239
)
)
)
Defendant(s)

CRIMINAL COMPLAINT%<7(/(3+21(2527+(55(/,$%/((/(&7521,&0($16

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of July 2020 to August 2020 in the county of Riverside in the
Central District of California , the defendant(s) violated:

Code Section Offense Description
18 U.S.C. Sections 1040, and 1343 Fraud in Connection with Emergency Benefits and Wire Fraud.

This criminal complaint is based on these facts:

✔ Continued on the attached sheet.
u

/s/
Complainant’s signature

Stephen Harrison, Special Agent
Printed name and title

$WWHVWHGWRE\WKHDSSOLFDQWLQDFFRUGDQFHZLWKWKHUHTXLUHPHQWVRI)HG5&ULP3E\WHOHSKRQH

02
Date: 04/01/2021
Judge’s signature

City and state: Riverside, California Honorable Magistrate Judge Sheri Pym
Printed name and title

$86$ B. Tuyay
Case 5:21-mj-00239-DUTY Document 1 Filed 04/02/21 Page 2 of 28 Page ID #:2

AFFIDAVIT

I, Stephen Harrison, being duly sworn, declare and state as

follows:

I.INTRODUCTION

1. I am a Special Agent (“SA”) with the Federal Bureau of

Investigation (“FBI”) and have been so employed since January

2019. I am currently assigned to the Los Angeles Division,

Riverside Resident Agency, where my duties include the

investigation of bank fraud, wire fraud, and money laundering.

I have received 21 weeks (approximately 840 hours) of

instruction in the fundamentals of law, ethics, behavioral

science, interviewing, report writing, firearms, surveillance,

defensive tactics, and case management at the FBI Academy in

Quantico, Virginia. During my employment with the FBI, I have

participated in a variety of investigations, including drug

trafficking, violent crimes, fugitives, bank fraud, wire fraud,

money laundering, and public corruption.

2. I have received instruction on the identification,

collection, and preservation of evidence, photography, latent

fingerprint collection, and crime scene investigations. I have

also completed hundreds of hours of criminal investigation,

including compiling information; interviewing victims,

witnesses, and suspects; and collecting evidence to support the

filing of criminal complaints and search warrants.

3. During the course of my investigations, I have

interviewed witnesses, conducted physical surveillance, executed

arrest and search warrants, and reviewed various forms of
Case 5:21-mj-00239-DUTY Document 1 Filed 04/02/21 Page 3 of 28 Page ID #:3

evidence including telephone call detail records, bank records,

invoices, photographs, recorded telephone calls, and other

miscellaneous financial documents. Through my training,

education, and experience, I have become familiar with a variety

of fraud schemes.

4. In addition to my formal training and personal

experiences, I have learned from and worked alongside

experienced senior FBI agents in various criminal investigations

including, but not limited to, corporate and securities fraud,

mail fraud, wire fraud, securities fraud, and insider trading.

These senior agents have provided me with guidance, training,

and hands-on experience in various investigative techniques

including, interviewing, surveillance, financial analysis, and

the identification and tracing of illicit proceeds.

II.PURPOSE OF AFFIDAVIT
5. I make this affidavit in support for the issuance of a

criminal complaint and arrest warrant against Sequoia Edwards

(“EDWARDS”), for a violation of Title 18, United States Code,

Sections 1040 (Fraud in Connection with Emergency Benefits) and

1343 (Wire Fraud).

6. The facts set forth in this affidavit are based upon

my personal observations, 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 warrant

and does not purport to set forth all of my knowledge of or

investigation into this matter. Unless specifically indicated
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otherwise, all conversations and statements described in this

affidavit are related in substance and in part only.

III.BACKGROUND INFORMATION ON UNEMPLOYMENT INSURANCE
BENEFITS AND COVID-19-RELATED FRAUD

A. Unemployment Benefits
7. Since 1935, the DOL’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, the EDD administers the UI

program for residents and others physically performing work

activities in California.

8. 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

(4) actively seeking work.

B. PUA Under the CARES Act
9. On March 13, 2020, the President of the United States

declared the COVID-19 pandemic an emergency under the Robert T.

Stafford Disaster Relief and Emergency Assistance Act. On March

27, 2020, the CARES Act was enacted to provide emergency

assistance and health care response for individuals, families,
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and businesses affected by the COVID-19 pandemic. The CARES Act

included, among others, the establishment of (1) PUA benefits to

provide financial assistance to individuals who are out of work

due to the pandemic, including those who do not usually qualify

for regular state UI such as self-employed, contract, and “gig

workers,” (2) the Pandemic Emergency Unemployment Compensation

(“PEUC”) benefit, a 13-week benefit extension for people who

have used all benefits available in their regular UI claim, and

(3) the Pandemic Additional Compensation (“PAC”) benefit, an

additional $600 federal stimulus payment automatically added to

each week of benefits received between March 29, 2020 and July

25, 2020.

10. On August 8, 2020, after Federal Pandemic Unemployment

Compensation (“FPUC”) expired, the President signed a

Presidential Memorandum authorizing the Federal Emergency

Management Agency (“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 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 is August 1, 2020 to December 27, 2020, or

termination of the program, whichever is sooner.

11. On December 27, 2020, the President signed into law

the Consolidated Appropriations Act of 2021. The guidance

provided states with important information about several
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provisions of the law, including the extension of programs first

authorized by the CARES Act earlier in the year, as well as the

creation of a new UI benefit for “mixed earners.”

12. The law extended 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

period of applicability for the PUA program extended 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 was 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 provided for continuing benefits for

eligible individuals for weeks of unemployment through April 5,

2021. The law also strengthened documentation requirements to

ensure PUA program integrity.

13. Additionally, FPUC, which expired July 31, 2020, was

reauthorized and modified to provide $300 per week to supplement
benefits for weeks of unemployment beginning after December 26,

2020 and ending on March 14, 2021, which was extended to

September 4, 2021 by the COVID-19 Relief Bill. FPUC was 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.

14. In addition, the time period for receiving the PEUC

benefit was extended from December 27, 2020 to March 14, 2021,
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then through September 4, 2021, and the number of weeks that an

individual could claim PEUC benefits was increased from 13 to 24

weeks.

15. Prior to the enactment of the CARES Act, to be

eligible for UI administered by the 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.

16. The CARES Act established a new program -- PUA -- to

provide unemployment benefits during the coronavirus pandemic to

people who do not qualify for regular UI 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.

17. Under the PUA program, workers who are not eligible

for regular UI benefits but are unemployed or partially

unemployed for a COVID-19-related reason1 permissible under

1 COVID-19-related reasons for being out of work include:
being diagnosed with COVID-19 or experiencing symptoms of
COVID19 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

6
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federal law may receive unemployment benefits for up to 46

weeks. Under the PEUC program, workers who are eligible for the

regular UI benefits for up to 26 weeks may receive an additional

13 weeks of benefits for a total of 39 weeks, which was later

increased to a total of 50 weeks. Under the PAC program, for an

individual receiving a regular UI benefit, a PUA benefit, or a

PEUC benefit between March 29, 2020 and July 25, 2020, the EDD

paid an additional $600 in CARES Act funds for each week of

benefits. Between December 26, 2020 and March 14, 2021, the

FPUC program provided an additional $300 per week for

unemployment. Examples of non-business-owner occupations that

may qualify a person for PUA benefits include realtor, barber,

hairstylist, freelance photographer, construction

handyman/woman, gardener, and ride-share driver.2
18. The California EDD began accepting applications for

PUA benefits on April 28, 2020. Applications may be made online

from any digital device, including smartphones, that connects to

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 UI Code, employers may elect UI and State Disability
Insurance (SDI) or only Disability Insurance coverage for
themselves. Self-employed individuals, who are not employers,
may only elect SDI coverage for themselves.
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the Internet and is capable of accessing the EDD website’s UI

benefits page. To make benefits available as quickly as

possible, payments are issued in phases. If a claimant

qualifies for PUA benefits, the minimum payments are as follows

based on the claim’s start date:

a. 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.

b. 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.

c. 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.

19. 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.

20. Persons applying for PUA benefits do not need to

submit any supporting documents to the EDD with their

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. The 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

3 In general, the EDD accepts items such as an annual tax
return, 1099 forms, W-2s, and pay stubs as proof of income.
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as quickly as possible to verify the claimant’s income using

other resources available to the EDD in order to increase the

PUA weekly benefit amount.

21. Like regular UI claims, PUA claims can be filed

online. When an individual files a PUA claim online, the 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 Internet

Service Provider (“ISP”) account, that was used to file the

claim.

22. A PUA claimant must answer various questions to

establish eligibility for PUA benefits. The claimant must

provide name, social security number (“SSN”), and mailing

address. The claimant must also identify a qualifying

occupational status and COVID-19 related reason for being out of

work.

23. After it accepts a UI claim, including a claim
submitted pursuant to the PUA program, the EDD typically

deposits UI funds every two weeks to an Electronic Benefit

Payment (“EBP”) debit card administered by 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.

24. When receiving regular UI benefits, a claimant must

complete a Continued Claim Form (DE 4581) and certify every two
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weeks, under penalty of perjury, that he/she remains unemployed

and eligible to receive UI benefits. The EDD authorizes and

deposits payment to the EBP debit card after it receives the

Continued Claim Form. On or about April 23, 2020, California

Secretary of Labor Julie Su directed the EDD to temporarily

suspend the requirement for UI claimants to provide unemployment

certifications (Continued Claim Forms).4 The Continued Claim

Form was waived to prevent any unnecessary delays in dispensing

benefit payments.

25. At present, 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.

26. The submission of the PUA claims cause mailings to the

addresses provided on the claims, including mailings of EBP

debit cards administered by BofA that are used to access the

fraudulently obtained UI benefits. The co-schemers and their

associates use the EBP debit cards to withdraw the fraudulently

obtained UI benefits by making cash withdrawals at Automated

Teller Machines (“ATM”) and point of sale purchases at merchants

across the United States.

C. UI Benefit Fraud Schemes
27. Based on my conversations with other law enforcement

officers, I know that individuals scheming to fraudulently

4The temporary suspension of the continued claims forms
covered the weeks ending March 14, 2020 through May 9, 2020.
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obtain UI benefits generally follow recognizable patterns,

including, among other indicia:

a. Co-schemers commonly buy or outright steal the

personally identifiable information (“PII”) of other people to

file for fraudulent UI benefits in the ID-theft victims’ names

and then collect the UI funds. Co-schemers often buy PII from

other fraudsters or from the Dark Web5 (using cryptocurrency such
as Bitcoin) and verify that the PII belongs to real persons by

checking the PII at background check websites such as

Beenverified, Spokeo, Intelius, and Whitepages.

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. Once the EBP

debit cards arrive, co-schemers commonly withdraw UI benefits

via ATMs or make POS purchases at merchants for goods and

services.

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.

5Dark Web is the set of web pages on the Internet that
cannot be indexed by search engines, are not viewable in a
standard web browser, require specific means (such as
specialized software or network configuration) in order to
access, and use encryption to provide anonymity and privacy for
users. Dark Web has become the Internet’s black market in
recent years where visitors can make illegal purchases of PII,
guns, and drugs, and trade child pornography.
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d. Failing to provide a phone number or provide a

wrong number on multiple UI claims so it may be difficult to

reach the identity holder.

IV.STATEMENT OF PROBABLE CAUSE

A. Summary of Probable Cause
28. The U.S. Department of Labor, Office of Inspector

General (“DOL-OIG”), California EDD, FBI, Homeland Security

Investigations, and United States Postal Inspection Service are

investigating a fraudulent scheme in which the perpetrators

fraudulently apply for and obtain UI benefits under the PUA

provision of the CARES Act, a provision that is designed to help

unemployed individuals obtain UI benefits as part of the

nation’s response to the economic harms caused by COVID-19.
29. The investigation initially obtained evidence that at

least 27 fraudulent UI claims were filed from EDWARDS’s

residence located on Courtney Drive in Moreno Valley,

California, asserting falsely that the named claimants were

self-employed independent contractors who were negatively

affected by the COVID-19 pandemic, triggering eligibility for UI

benefits under the PUA provision of the CARES Act. The UI

claims submitted in furtherance of the scheme falsely reported

income to EDD for the named claimants on their applications, in

order to receive UI benefits.

30. The applications for the fraudulent UI claims asserted

that the named claimants were entitled to UI benefits

administered by EDD when, in fact, they were not. At least 6 of

the UI claims were for inmates at California state correctional
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facilities, including Centinela State Prison in Imperial,

California; Valley State Prison in Chowchilla, California; and

California State Prison Solano in Vacaville, California. Due to

their custody status, the inmates listed as named claimants were

not were not eligible to apply UI benefits because they were

not: (1) unemployed through no fault of their own; (2) able and

available for work; and/or (3) actively seeking work. These

actions in concert were material false statements leading to the

theft of federal funds.

31. The fraudulent UI claims were submitted electronically

using an IP address that was registered EDWARDS’s residence

under the name D.J., who I later confirmed to be EDWARDS’s

fiancé. The submission of the UI claims caused mailings to the

addresses provided on the claims, including mailings of EBP

debit cards administered by BofA that were used to access the

fraudulently obtained UI benefits.

32. A federal search warrant was obtained in Case No.

5:21-MJ-37, approved by the Honorable Sheri Pym, United States
Magistrate Judge, to search EDWARDS’s residence and was executed

on February 10, 2021. During the search FBI seized 5 EBP debit

cards, none of which belonged to EDWARDS or D.J., including two

cards bearing the names of individuals previously identified

from the UI claims filed from EDWARDS’s IP Address. FBI also

seized EDWARDS’s and D.J.’s digital devices and approximately

$45,000 in cash.

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33. From July 2020 to August 2020, EDD paid out

approximately $455,000 in UI benefits on the 27 claims mentioned

above.

B. The Scheme to Fraudulently Obtain UI Benefits

DOL-OIG Investigates Public Reports of Fraudulent

UI Claims Filed Under California Inmates’ Names
34. Based on my review of reports, conversations with

other law enforcement officers, and my own involvement in

this investigation, I know the following.

35. On or about November 24, 2020, as reported in the

New York Times, a task force led by district attorneys in San

Diego and Fresno Counties sent a letter to California

Governor Gavin Newsom raising concerns about widespread

fraudulent UI claims being filed by inmates in California

correctional facilities.6 On December 1, 2020, as reported in

the Los Angeles Times, investigators with State of California

estimated that approximately $400 million had been disbursed

on approximately 21,000 suspected fraudulent UI claims filed

using the PII of California prison inmates.7

36. Following these reports of fraudulent UI claims

using inmate information, DOL-OIG investigated potentially

6 “Unemployment Scam Using Inmates’ Names Cost California
Hundreds of Millions,” N.Y. Times, Nov. 24, 2020, available at
https://www.nytimes.com/2020/11/24/us/california-unemployment-
fraud-inmates.html.
7 “California’s Prisoner Unemployment Fraud Now Estimated at
$400 Million, Officials Say,” L.A. Times, Dec. 1, 2020,
available at https://www.latimes.com/california/story/2020-12-
01/california-prisoner-unemployment-fraud-estimated-400-million.
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fraudulent claims using California inmates’ PII.

Specifically, DOL-OIG obtained from the California Department

of Corrections and Rehabilitation (“CDCR”) the PII of inmates

housed in CDCR facilities at least since 2018. The inmates

were those who, due to their incarceration, were ineligible

for UI benefits under the EDD’s requirements. DOL-OIG cross-

referenced the inmates’ PII with the data automatically

stored by DOL-OIG and EDD for each UI benefit claim submitted

to EDD. Through this process, DOL-OIG identified hundreds of

UI claims submitted using CDCR inmates’ PII. After

identifying the IP addresses used to submit the UI claims

using inmates’ PII, DOL-OIG identified instances of multiple

UI benefit claims made (both using inmates’ PII and non-

inmates’ PII) from the same IP addresses. In some cases,

DOL-OIG found that a single IP address had been used to file

dozens of UI claims resulting in hundreds of thousands of

dollars of UI benefit disbursements. DOL-OIG then obtained

from ISPs specific subscriber information for the IP

addresses from which multiple UI benefits claims were filed

using CDCR inmates’ PII.

37. In December 2020, I received information from DOL-

OIG Supervisory Special Agent Michael Blas and SA Christina

Wang, regarding suspected fraudulent UI claims filed with EDD

from an IP address originating in the Central District of

California: 47.149.228.126 (the “Target IP Address”).

Records obtained from DOL and EDD databases reflected that

the Target IP Address was used to file at least 27 fraudulent
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UI claims with EDD between July 2020 and August 2020.

Approximately 6 of the 27 UI claims filed from the Target IP

Address were for inmates incarcerated in California state

prisons, including Centinela State Prison in Imperial,

California; Valley State Prison in Chowchilla, California; and

California State Prison Solano in Vacaville, California.

The UI Claims Were Fraudulent
38. The UI benefits have become a prime target for fraud.

The six UI claims submitted for California state inmates were

fraudulent. The inmates whose PII had been used to submit UI

claims were not eligible to apply for UI benefits because

they did not meet EDD’s eligibility requirements. Those

inmates were not: (1) unemployed through no fault of their own;

(2) able and available for work; and/or (3) actively seeking

work.

39. The remaining 21 UI claims also had indicia of fraud.

Based on my training and experience, I know that individuals

scheming to fraudulently obtain UI benefits generally follow

recognizable patterns, including the following, among others:

a. Using the identities of other people to file for

fraudulent UI benefits in the other persons’ names and then

collecting the UI funds. In some instances, the named claimants

are victims of identity theft; in other instances, the named

claimants have provided their personal identifying information

to the schemers and have agreed to pay the schemers a portion of

the fraudulent benefits that are obtained; in yet other

instances, the named claimants believe they may be entitled to
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benefits but do not know that the schemers are reporting false

information to EDD to fraudulently increase the amount of the

benefits claimed.

b. Using addresses the schemers control as the

addresses submitted to EDD for the UI claims so that EBP debit

cards and other EDD correspondence will be mailed to these

addresses and thus be accessible to the schemers. According to

EDD records, three of the 27 UI claims described above used

EDWARDS’s residence on Courtney Drive in Moreno Valley,

California as the claimant’s mailing address (and none of the

claims were for EDWARDS).

c. Submitting multiple UI claims from the same IP

address for multiple claimants. As described further below, all

of the relevant fraudulent UI claims were submitted from the

same Target IP Address associated EDWARDS’s residence.

d. Submitting UI claims close in time. The majority

of the UI claims here were filed between July 2020 and August

2020.
e. Providing similar or identical identifying

information across multiple different claim applications. In

addition to the three UI claims that listed EDWARDS’s residence

as the claimants’ address, the UI claims submitted from the

Target IP Address showed the following similarities:

i. Two UI claims listed as the claimants’

address the same address on California Avenue in Bakersfield,

California; and

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ii. Ten UI claims listed as the claimants’

addresses apartments from the same complex on Beardsley Avenue

in Bakersfield, California.

f. The same or similar mailing addresses were used

for 26 of the 27 UI claims submitted from the Target IP address.

Twenty-five of the 27 UI claims provided no contact telephone

number. According to law enforcement database queries, the two

UI claims that listed telephone numbers used the same claimant

address on Highgate Avenue in Victorville, California which was

the same address used in a UI claim for C.R. an inmate at

Centinela State Prison. C.R.’s UI claim was submitted online to

EDD from the Target IP Address associated with EDWARDS’s

residence.

The Fraudulent Claims Were Connected to EDWARDS and

the SUBJECT PREMISES
40. Further investigation revealed that the fraudulent

claims discussed above were connected to EDWARDS and her

residence in the following ways:

a. Records obtained from Frontier Communications,

the ISP for the Target IP Address, reflect that at the time

the UI claims were submitted online to EDD from the Target IP

Address, the subscriber for the Target IP Address was D.J.. As

discussed below, EDWARDS stated in a voluntary interview with

FBI that D.J. was her fiancé. The service address for the

Target IP address was EDWARDS’s residence. The customer name

for the subscriber account associated with the IP Target

Address was D.J. and the e-mail address was XXXXXX@gmail.com.
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The lease for the Target IP address went from July 14, 2020

to August 5, 2020.

b. On January 8, 2021, I conducted surveillance at

EDWARDS’s residence and saw D.J. and EDWARDS, who I identified

from their DMV photographs. I saw EDWARDS and D.J. walk out of

the house, take out the trash, and go back inside. As described

more fully below, on February 10, 2021, FBI executed a search

warrant at the address associated with the Target IP Address

during which agents confirmed that EDWARDS lived at that address

with D.J., her fiancé.

Sample of the Fraudulent Claims
41. I reviewed a sampling of 6 of the fraudulent UI claims

discussed above, which were submitted to EDD between July 2020

and August 2020.

42. The table below sets forth a sample of the

fraudulent claims for certain California state inmates:
Claimant Claim Date Claimed Claimed Claimed Dates of
Reason for Affected Amount Incarceration
Unemployment Work
Charles 07/14/2020 COVID-19 Lawn Service Approved 6/26/2001-
Redeaux Worker ($7,414) PRESENT
Jose
07/24/2020 COVID-19 Barber Approved 4/3/2015-
Garcia ($5,460) PRESENT
Tyrone 07/24/2020 COVID-19 Barber Approved 10/3/1997-
Jones ($8,762) PRESENT
Jermey 07/26/2020 COVID-19 Barber Approved 5/16/2018-
Heller ($9,390) PRESENT
Carlos 07/26/2020 COVID-19 Lawn Care Approved 12/20/2018-
Martinez Specialist ($9,390) PRESENT
Jay
07/31/2020 COVID-19 Catering Approved 3/27/2001-
Metoyer Assistant ($12,600) PRESENT
43. All six claims were electronically filed from the

above-referenced IP address located at EDWARDS’s residence.

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44. All six claims were filed using similar information,

as follows:

a. All six claimants reported being unemployed

because of a “disaster,” namely, “COVID-19”;

b. Five UI claims selected the following self-

attestation: “I am unable to travel due to restrictions”;

c. All six claims list the same information for

“Last Employer” and “Last Employer mailing address”; and

d. Four of the six UI claims used the same mailing

addresses either on Oregon Street in Bakersfield, California or

on Flintlock Trail in Moreno Valley, California.

Federal Search Warrant of EDWARDS’s Residence
45. On February 10, 2021, the FBI executed a search

warrant EDWARDS’s residence on Courtney Drive in Moreno Valley,

California. The search warrant (5:21-MJ-37) was issued by the

United States District Court for the Central District of

California and signed by the Honorable Sheri Pym, United States

Magistrate Judge. During the search, the FBI seized five EBP

debit cards including two EBP debit card linked to a UI claims

filed from EDWARDS’ IP address which DOL previously identified.

FBI also seized EDWARDS and D.J.’s digital devices and

approximately $45,000 in cash.

Interview of EDWARDS
46. On February 10, 2021, after the execution of the

above-reference search warrant, FBI SA Amy Pfeifer conducted a

voluntary interview of EDWARDS at her residence. EDWARDS told

us the following:
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a. EDWARDS is engaged to D.J.

b. EDWARDS had applied for and was receiving UI

benefits.

c. EDWARDS stated that the inmates’ information for

the UI claims which were filed using her IP address came from

her cousin T.T. who is currently incarcerated at a California

state prison.8
d. T.T. would give PII of third persons to his

girlfriend B.R., who would then pass the information to EDWARDS,

so that EDWARDS could file the UI claims.

e. EDWARDS stated that she filed UI claims for her

mother, father, and son. EDWARDS also stated that her sister-

in-law D.W., who is married to EDWARDS’s incarcerated brother,

filed UI claims which were sent to EDWARDS’s parents’ house on

Highgate Avenue, Victorville, California.

Review of Digital Devices
47. I reviewed the digital devices that were seized from

EDWARDS’s residence on February 10, 2021. EDWARDS’s cell phone

showed that she had conversations with various individuals about

EDD claims. EDWARDS worked with people to file UI claims and

had people help her acquire personal information which she used

to file UI claims.

8T.T.is currently incarcerated at Centinela State Prison in
California, where at least three other inmates who filed UI
claims using EDWARDS’ IP address are incarcerated.
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48. Specifically, on or about July 22, 2020, J.K.B sent a

text message9 to EDWARDS, which appears to be highly detailed
step-by-step instructions on how to file UI claims online using

information of minors. J.K.B.’s instructions stated, among

other things, the following:

“You need an email address that has never been used

with EDD. Go to the EDD UI website and register for

an account under ‘Benefits Program Online’ after

submitting the registration you’ll receive a

confirmation email, click the link from the

confirmation email. It’ll say, ‘Registration

Success’ you’ll then click on Benefits Program

Online, log in to ‘UI Online’ and File New Claim!

Answer NO to the first 6 questions and press NEXT.

The next screen you’ll enter YOUR CHILDS personal

info (social, DOB, etc.) . . .The following screen

inquires of the child has worked within the last 18

months. Answer No! . . . The following screen ask

what type of work the child normally performs. Click

‘Add Work Type’ type in actor and press ‘Search’,

choose actor scroll down and press Save. Do that for

questions 1 & 2. You’ll answer No to every question

EXCEPT #6!! #6 is YES!!”

9Text messages include messages sent via SMS text as well
as other messaging applications including WhatsApp and Facebook
Messenger.
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The text message continues to provide specific answers to

questions throughout the online UI claim process. J.K.B. also

explained via text message how to certify continued unemployment

so that each UI claim continued to receive benefits, and how to

check the status of approved UI claims and determine the

shipping date for EBP debit cards.

49. In the following series of messages with J.K.B,

EDWARDS agreed to pay J.K.B. $1000 for each minor for whom she

filed a UI claim:

a. On or about July 23, 2020, EDWARDS sent a text

message to P.J. asking if she could use P.J.’s address on Oregon

Street in Bakersfield, California, to file UI claims. EDWARDS

agreed to pay P.J. $100 for each EBP debit card that sent to

P.J.’s. address. After P.J. allowed EDWARDS to use her address,

EDWARDS asked P.J. if she could help EDWARDS find more

addresses, so EDWARDS could file additional UI claims. P.J.

sent EDWARDS via text message approximately six addresses, which

matched claimants’ addresses listed on UI claims filed from
EDWARDS’s residence and IP address. Later, EDWARDS exchanged

text messages coordinating with P.J. to pick up the EBP debit

cards and timesheets.

b. On or about July 24, 2020, EDWARDS text messaged

a contact identified as “KESH.”10 EDWARDS told KESH that she had

been receiving from people in jail her “profiles,” which

Based on database checks of the telephone number for the
10
contact “KESH”, I believe the telephone number belongs to
MARKISHA J.
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included the PII of individuals required to file UI claims.

EDWARDS’s messages to KESH further explained that EDWARDS’s

cousin was talking to people in jail. EDWARDS then told KESH

that KESH could use four “profiles” per physical address to file

UI claims. EDWARDS sent KESH profiles to file UI claims.

c. On or about July 23, 2020, a contact identified

as “PIG” messaged EDWARDS and asked for cellmate information for

“TRE”11 for his UI claim. EDWARDS replied to PIG with TRE’s

cellmate information and what appeared to be EDD log-in

information.

d. On or about July 28, 2020, EDWARDS sent profiles

to PIG12 to file UI claims. EDWARDS told PIG to pay her

approximately $1,000 per day after PIG received the EBP debit

cards from filing the UI claims using the information that

EDWARDS sent.

e. The table below sets forth a sample of the

profiles (which included dates of birth and social security

numbers) that EDWARDS sent to KESH and PIG:

11 Based on reviewing phone messages and the interview of
EDWARDS, I believe TRE to be C.T.E., who is EDWARDS’ brother.
Based on reviewing EDWARDS messages with PIG and
12
conducting database checks, I believe PIG to be D.W.
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Profiles EDWARDS sent to KESH Profiles EDWARDS sent to PIG
Brenda R. Cordero B.
Nathaniel G. Justin P.
Letty S. Maria F.
Dayquanna M. Nolberto F.
Justin P. Andrew N.
Brandon M. Donald A.
Demetria P. Ericka M.
Caterina L.
Nathan M.
Rodney B.
50. On or about July 29, 2020, EDWARDS messaged PIG the

following:

EDWARDS: use a computer

EDWARDS: or a phone that’s off just on WiFi

EDWARDS: I did them all on my computer

PIG: ok

EDWARDS: They not gonna be watching like that too many ppl

doing it

PIG: K

PIG: It’s just the email part

EDWARDS: just cant be foolish like niggas buying a

Lamborghini smh

51. Based on my participation in this investigation and my

training and experience, I interpret EDWARDS’s text messages

above to be telling PIG to use a computer to file UI claims and

that PIG should not be concerned about being caught filing UI

claims (i.e., “they not gonna [sic] be watching like that”).

52. On or about September 16, 2020, EDWARDS messaged T.T.

to update him about the amount on each of the inmates’ EBP debit

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cards. EDWARDS said, “Ok I just logged on to all of them Jones

10k, Jose 16, Carlos 14, Jermey 20.”

53. In the Notes application on EDWARDS’s telephone, I

found a file that was created on or about June 30, 2020, which

showed names listed under addresses that were connected with the

UI claims filed from EDWARDS’ IP address.

54. The table below shows the information from the file

found in the Notes application on EDWARDS’s telephone:
ANDREW BRENDA Oregon Washington Beardsley Oregon
HOUSE HOUSE Apt A. Ave House Apt. 2 Apt B.
TIKKA F. YEHENIA Nevaeh E. TOSHALENA RAYMONTE TYRONE
E. H. J.
DOMINIK ANNA R. MALIENA JC M. STEVEN B. PHILLIP
M. G. A.
JAMAREE AMBROSE AALIYAH G. BREYEA M. JOSE G.
T.
DAVIN O. DORIAN SHARYA A.
CLEON J.

REVIEW OF EBP DEBIT CARD STATEMENTS
55. I reviewed a spreadsheet prepared by FBI Forensic

Accountant Stacy Martin that compiled data from BofA account

statements or at least 20 UI claims filed from EDWARDS’s IP

Address. The data shows a pattern of transactions consistent

with identity theft and fraud based on my training and

experience.

56. Specifically, the summary of transactions show that

between August 2020 and November 2020, multiple ATM cash

withdrawals were made from the same BofA location in Moreno

Valley. Each cash withdrawal was for the amount of $1,000. For

instance, on September 6, 2020, eight BofA accounts linked to UI

claims made from EDWARDS’s IP address each made $1,000 ATM cash

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withdrawals from a BofA location in Moreno Valley within 10

minutes of each other. Similarly, two days later, on September

8, 2020, eight BofA accounts linked to UI claims submitted from

EDWARDS’s IP address each made $1,000 ATM cash withdrawals from

a BofA location in Moreno Valley within an hour of each other.

V.CONCLUSION
57. For all the reasons described above, there is probable

cause to believe that EDWARDS has committed violations of Title

18, United States Code, Sections 1040 (Fraud in Connection with

Emergency Benefits) and 1343 (Wire Fraud).

Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1 by
2nd day of
telephone on this ____
April 2021.

HONORABLE SHERI PYM
UNITED STATES MAGISTRATE JUDGE

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