Indictment — United States v. Mark Vallejos et al. (Dkt. 2, August 25, 2020)

Summary

An Indictment in United States v. Mark Vallejos, Amanda Padilla, Ashley Garcia and another defendant, No. 1:20-cr-01626-WJ, in the U.S. District Court for the District of New Mexico, Document 2, filed August 25, 2020. The caption lists Count 1, 18 U.S.C. § 1708, Theft of Mail; Count 2, 18 U.S.C. § 1349, Conspiracy to Commit Bank Fraud; and Counts 3-8, Bank Fraud and Aiding and Abetting. Count 1 states that, in Bernalillo County, Mark Vallejos stole and took mail matter from an authorized depository. The grand jury also alleges a scheme using stolen mail, stolen identity information and falsified checks deposited into a Nusenda Credit Union account, followed by a table of check transactions.

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Case 1:20-cr-01626-WJ Document 2 Filed 08/25/20 Page 1 of 3
FILED
UNITED STATES DISTBICT
COURT
ALBUQUERQUE, NEW T,/IC
ICO.,
IN THE LINITED STATES DISTzuCT COURT
AUG 2 52020
FOR THE DISTRICT OF NEW MEXICO
MITCHELL H. ELFERS
LTNITED STATES OF AMERICA, ) CLEHK

Plaintifi criminat No.'\O'IULU \ilJ.

vs. Count 1: 18 U.S.C. $ 1708: Theft of Mail;

MARK VALLEJOS, JESUS Count 2: 18 U.S.C. $ 1349: Conspiracy to
CIilAYF-[ AMANDA PADILLA, ANd Commit Bank Fraud;
ASHLEY GARCIA,
Counts 3-8: 18 U.S.C. $ BaaQ): Bank Fraud; 18
Defendants. U.S.C. $ 2: Aiding and Abetting.

INDICTMENT
The Grand Jury charges:

Count 1

On or about January 13,2019, in Bernalillo County, in the District of New Mexico, the

defendant, MARK VALLEJOS, stole and took from and out of an authorized depository for

deposit and delivery of mail matter, packages, envelopes, letters and the contents therein.

In violation of 18 U.S.C. $ 1708.

Count 2

From on or about January 12,2)lg,through on or about January 18,2019, in Bernalillo

County, in the District of New Mexico, the defendants MARK VALLEJOS, JESUS CIJAYE,Z,

AMANDA PADILLA and ASHLEY GARCIA, unlawfully, knowingly and intentionally

combined, conspired, confederated, agreed, and acted interdependently with each other and with

others whose names are known and unknown to the Grand Jury to devise a scheme and artifice to

obtain money and property under the custody and control of financial institutions, by means of

false and fraudulent pretenses, representations, and promises, namely through the use of stolen
Case 1:20-cr-01626-WJ Document 2 Filed 08/25/20 Page 2 of 3

checks and identity information, in violation of 18 U.S.C. $ 1344.

In violation of 18 U.S.C. $ 1349.

Counts 3-8

From on or about January ll,2}l9,through on or about January 16,2019, in Bernalillo

County, in the District of New Mexico, the defendants, MARK VALLEJOS, JESUS

CIdAYEZ, AMANDA PADILLA and ASHLEY GARCIA, knowingly executed and attempted

to execute a scheme and artifice to obtain money and property under the custody and control of

financial institutions, by means of false and fraudulent pretenses, representations, and promises,

namely through the use of stolen mail, stolen identity information, and falsified checks.

It was a part of the scheme and artifice that the defendant, MARK VALLEJOS, and

other persons known and unknown to the Grand Jury, stole checks and other items from the mail

and obtained identity information from the stolen checks and from the other items stolen from

the mail.

It was apartof the scheme and artifice that the defendant, ASHLEY GARCIA, obtained

a new debit card, on January 12,2019, for an account previously opened in her name and into

which stolen checks were subsequently deposited by the conspirators.

It was apartof the scheme and artifice that the defendants, MARK VALLEJOS and

JESUS CIHAYIJZ, and others known and unknown to the Grand Jury, deposited the stolen

checks and counterfeit checks, created using identity information stolen from mail matter, using

Automated Teller Machines (ATMs) into aNusenda Credit Union account opened by the
:.. /)

defendant, ASHLEY GARCIA.

It was part of the scheme and artifice that the defendants, AMANDA PADILLA, posing

as ASHLEY GARCIA, and JESUS CHAYEZ, made contact with Nusenda Credit Union
Case 1:20-cr-01626-WJ Document 2 Filed 08/25/20 Page 3 of 3

officials to gain access to the account.

On the dates listed below, in Bernalillo County, in the District of New Mexico and

elsewhere, the defendants, MARK YALLEJOS, JESUS CHAYE,Z, and ASHLEY GARCIA,

for the purpose of executing and attempting to execute the above-described scheme and artifice

to obtain money and property under the custody and control of financial institutions, conducted

the following transactions :

Ct. Date Check Amount Financial Financial Depositor
No. Institution that Institution
Issued the Stolen Where Check
Check Was Deposited
Ut2l20l9 358263 $10,946.31 T. D. Bank Nusenda Credit Chavez
Union
4. Ut3l20l9 t02701 $964.07 Chase Bank Nusenda Credit Garcia
Union
5. U|sl20t9 7288 $27s Bank of the West Nusenda Credit Chavez
Union
6. Ut6l20t9 1019 $37s Bank of America Nusenda Credit Chavez
Union
7. Ut6l20t9 t027 s320 Wells Fargo Nusenda Credit Chavez
Union
8. Ur6t20t9 t2l2 $333 U.S. Bank Nusenda Credit Vallejos
Union

In violation of 18 U.S.C. $$ 1344(2) ard2.

A TRT]E BILL:

/sl
FOREPERSdIV OT TFIE GRAND JURY

United States

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