Criminal Complaint — U.S. v. Natalie Le Demola et al. (C.D. Cal.)
Summary
A criminal complaint, Case No. 2:22-mj-01656, against Natalie Le Demola, Carleisha Neosha Plummer and other defendants, filed April 27, 2022 as Document 1 in No. 2:22-cr-00205-JFW in the U.S. District Court for the Central District of California, charging wire fraud conspiracy under 18 U.S.C. § 1349 from about June 2020 to April 2021. It rests on the affidavit of HSI Special Agent Alfredo Rossi, attested before Magistrate Judge Gail J. Standish. The affidavit alleges the defendants used stolen personal information, including from prison inmates, to file fraudulent pandemic unemployment insurance applications with the California Employment Development Department and withdrew benefits at ATMs. It describes a September 6, 2020 traffic stop that recovered EDD cards, cash and a ledger of 98 victim profiles, and states the scheme opened hundreds of fraudulent EDD accounts.
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“Criminal Complaint — U.S. v. Natalie Le Demola et al. (C.D. Cal.).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-22-cr-00205-dkt-1-c-d-cal-b60beb47c5/
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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 1 of 49 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ܆Original ܆Duplicate Original
4/27/22
EQ
UNITED STATES DISTRICT COURT
for the 4/27/2022
VAM
Central District of California
United States of America,
v.
Natalie Le Demola,
Carleisha Neosha Plummer,
aka “LG,” Khanshanda
EugenHa King,
aka “Cassandra King,”
Cleshay Johnson II,
James Antonio Johnson,
aka “Niddy Johnson,”
aka “Big Dawg Niddy,” Case No. 2:22-mj-01656 -DUTY
aka “Niddy,”
Felicite Aleisha King,
Shafequah Lynete Mitchell,
Loresha Shamone Davis,
Porsha Latrice Johnson,
Donisha Lashawn Pace,
Dominique Charmone Martin,
Mykara Destiny Robertson, and
Amber Jane Wade,
Defendants.
CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
Beginning no later than in or around June 2020 and continuing until at least in or around April 2021, in the
county of Los Angeles in the Central District of California, the defendants violated:
Code Section Offense Description
18 U.S.C. § 1349 Wire fraud conspiracy
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 2 of 49 Page ID #:2
This criminal complaint is based on these facts:
Please see attached affidavit.
/S/ Alfredo Rossi
Complainant’s signature
Alfredo Rossi, HSI Special Agent
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.
Date: April 27, 2022
Judge’s i
signature
City and state: Los Angeles, California The Hon. Gail J. Standish
Printed name and title
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 3 of 49 Page ID #:3
AFFIDAVIT
I, Alfredo Rossi, being duly sworn, declare and state as
follows:
PURPOSE OF AFFIDAVIT
1. This affidavit is made in support of a criminal
complaint against and warrants to arrest the following
individuals for a violation of 18 U.S.C. § 1349 (wire
conspiracy): NATALIE LE DEMOLA, CARLEISHA NEOSHA PLUMMER,
K+$1SHANDA EUGEN(A KING (“K. KING”), CLESHAY JOHNSON II (“C.
JOHNSON”), JAMES ANTONIO JOHNSON (“J. JOHNSON”), FELICITE
ALEISHA KING (“F. KING”), SHAFEQUAH LYNETE MITCHELL
(“MITCHELL”), LORESHA SHAMONE DAVIS (“DAVIS”), PORSHA LATRICE
JOHNSON (“P. JOHNSON”), DONISHA LASHAWN PACE (“PACE”), DOMINIQUE
CHARMONE MARTIN (“MARTIN”), MYKARA DESTINY ROBERTSON
(“ROBERTSON”), and AMBER JANE WADE (“WADE”).
2. The facts set forth in this affidavit are based upon
my personal observations, my training and experience, and
information obtained from various law enforcement personnel and
witnesses.
3. This affidavit is intended to show only that there is
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.
4. Unless specifically indicated otherwise, all
conversations and statements described in this affidavit are
related in substance and in part only. Further, all dates and
1
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amounts are approximations, and the words “on or about” and
“approximately” are omitted for clarity.
5. The beliefs I express in this affidavit are based on
my training, experience, knowledge of the investigation, and the
reasonable inferences I have drawn from the foregoing sources of
information.
BACKGROUND OF AFFIANT
6. I am a Special Agent with Homeland Security
Investigations (“HSI”) and have been so employed since June
2019. I am currently assigned to the El Camino Real Financial
Crimes Task Force, where I investigate fraud, identity theft,
money laundering, and other financial crimes. Prior to becoming
a Special Agent with HSI, I was employed as a Special Agent with
the United States Secret Service (“USSS”), where I was
responsible for investigating financial crimes, including theft,
fraud, fraudulent identification documents, access device
crimes, credit card fraud, check fraud, and money laundering.
7. To become an HSI Special Agent, I completed nine
months of training at the Federal Law Enforcement Training
Center in Brunswick, Georgia. During my employment with HSI and
USSS, I have participated in numerous aspects of criminal
investigations, including record analysis, electronic
surveillance, physical surveillance, search warrants, arrests,
and reviewing evidence from digital devices. I have also spoken
to law enforcement agents regarding their experience in criminal
investigations, and interviewed defendants, confidential
2
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informants, and witnesses who had personal knowledge of the
methods used to commit different criminal offenses.
SUMMARY OF PROBABLE CAUSE
8. The defendants executed a large-scale fraud scheme to
use personal identifying information (“PII”), often stolen from
identity theft victims, to fraudulently acquire unemployment
insurance (“UI”) benefits from the California Employment
Development Department (“EDD”) and several financial
institutions. In general, the defendants executed the scheme in
the following ways:
9. DEMOLA, who is serving a life sentence for first-
degree murder in the California Department of Corrections and
Rehabilitation (“CDCR”), PLUMMER (who at one time was housed
with DEMOLA in a CDCR prison), K. KING, and other coconspirators
acquired the PII, such as the names, dates of birth, and social
security numbers, of individuals, including identity theft
victims, who were not eligible for UI benefits because they were
employed, retired, or incarcerated.
10. For example, DEMOLA and PLUMMER solicited and obtained
PII from inmates who were incarcerated at CDCR institutions.
DEMOLA also obtained PII for CDCR inmates and their visitors
from Coconspirator 1, a CDCR employee who accessed CDCR
databases for this unauthorized purpose, and disseminated the
PII of the identity theft victims to other defendants. At the
same time, K. KING, in concert with C. JOHNSON, acquired the PII
of victims who were employed, retired, and in some cases CDCR
3
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inmates, and maintained that victim PII in notebooks (“K. KING’s
ledger”) and other locations.
11. The defendants and their coconspirators then used the
victims’ PII to submit fraudulent online applications to EDD for
UI benefits, including for benefits intended for individuals who
were unemployed because of the COVID-19 pandemic (collectively
the “fraudulent EDD applications”). On the fraudulent EDD
applications, the defendants and their coconspirators assumed
the victims’ identities and provided materially false
information to EDD, including that the victims were unemployed
as a direct result of the COVID-19 pandemic. The defendants and
their coconspirators also submitted fraudulent EDD applications
using their own PII.
12. By submitting the fraudulent EDD applications, the
defendants and their coconspirators caused EDD to (a) transmit
emails related to the fraudulent EDD applications to the account
email addresses, (b) authorize pandemic benefits to be provided
to individuals who were ineligible for pandemic benefits because
they were employed, retired, or incarcerated, including the
victims, the defendants, and the defendants’ coconspirators, and
(c) EDD debit cards to be mailed to the account mailing
addresses, which the defendants (including MARTIN) and their
coconspirators controlled.
13. After EDD approved the fraudulent EDD applications and
disbursed the pandemic benefits funds to the EDD debit accounts,
and Bank of America issued the EDD debit cards linked to those
accounts, PLUMMER, K. KING, C. JOHNSON, J. JOHNSON, F. KING,
4
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MITCHELL, DAVIS, P. JOHNSON, PACE, MARTIN, ROBERTSON, and WADE
assumed the identities of the EDD account holders and used the
corresponding EDD debit cards to make fraudulent cash
withdrawals of pandemic benefits from automated teller machines
(“ATMs”) in Los Angeles, Riverside, and San Bernardino Counties,
including at ATMs that Bank of America, Wells Fargo, and
JPMorgan Chase (“Chase”) operated.
14. Through emails and phone calls, DEMOLA instructed
other defendants to falsely certify that, among other things,
the holders of the fraudulent EDD debit accounts, including the
victims, the defendants, and the defendants’ coconspirators,
continued to be eligible to receive pandemic benefits. PLUMMER,
K. KING, MITCHELL, C. JOHNSON, P. JOHNSON, PACE, and other
coconspirators used cell phones to access the fraudulent EDD
debit accounts and falsely certify that the account holders
continued to be eligible to receive pandemic benefits.
STATEMENT OF PROBABLE CAUSE
15. Based on my review of law enforcement reports and
records, third-party records, government records, information
from law enforcement databases, digital evidence, conversations
with other law enforcement personnel, and my own knowledge of
this case, I know the following:
a. The EDD Unemployment Insurance Program
16. EDD administers UI benefits for residents of
California, including Pandemic Unemployment Assistance benefits
to individuals who are unemployed because of the COVID-19
pandemic (“pandemic benefits”). To qualify for UI benefits,
5
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including pandemic benefits, a California resident has to submit
to EDD an application for the benefits, provide EDD with PII,
(including the applicant’s name, date of birth, and social
security number), and certify to EDD under the penalties of
perjury that the COVID-19 pandemic had directly and adversely
affected the applicant’s employment.
17. Applications for UI benefits, including pandemic
benefits, can be submitted to EDD online. An individual who
applies online for benefits has to provide EDD with an email
address (“account email address”) in addition to the applicant’s
regular mailing address (“account mailing address”). Individuals
who are employed, retired, or incarcerated are not eligible for
UI benefits, including pandemic benefits.
18. After a person submits an application for UI benefits,
including pandemic benefits, EDD transmits an email to the
account email address provided on the application confirming the
submission of the application and, thereafter, sends
correspondences related to the application and the UI benefits
to the account email address. Once EDD approves the application
and grants UI benefits to the applicant, EDD creates a debit
account (“EDD debit account”) with Bank of America. A debit card
linked to the EDD debit account will then be mailed to the
account mailing address.
19. EDD then normally deposits UI benefits, including
pandemic benefits, to the EDD debit account. The debit card can
be used to withdraw the benefits from the EDD debit account
using ATMs, including ATMs that Bank of America, Wells Fargo
6
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Bank, and Chase, operate. Once approved for pandemic benefits,
the recipient of the benefits is required to periodically
recertify under the penalties of perjury that, among other
things, the recipient is unemployed due to the COVID-19 pandemic
and therefore remains eligible to receive pandemic benefits.
b. The IPD Accounts
20. On September 6, 2020, K. KING and C. JOHNSON were
arrested in Inglewood, California, with a large cache of
evidence related to the fraudulent EDD scheme described in this
affidavit (the “IPD arrest”).
21. According to the Inglewood Police Department (“IPD”)
incident report, on September 6, 2020, IPD Officers Ciauri and
Salinas were in full uniform in an unmarked Dodge Charger when
they saw a black Range Rover driving in the opposite direction
with no front license plate, in violation of California Vehicle
Code § 5200. The officers made a U-turn and conducted a traffic
stop of the Range Rover, and encountered K. KING in the driver’s
seat and C. JOHNSON in the passenger seat.
22. When Officer Ciauri told K. KING the reason for the
stop and asked for identification, K. KING produced a California
identification card and said that she did not have her license
and was on probation. Contemporaneously, C. JOHNSON provided
Officer Salinas with a photographic copy of his California
identification card and said he did not have the actual ID on
him. C. JOHNSON also told the officer that he was on probation
for accessory to murder. The officers then ran K. KING and C.
JOHNSON through an IPD database and found that both were on
7
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post-conviction court supervision, K. KING for burglary and C.
JOHNSON for accessory to murder, with “anywhere, anytime” search
conditions. Based on this information, the officers searched the
Range Rover and found the following evidence:
a. K. KING’s wallet between the driver’s seat and
center console (the “wallet”). Inside the wallet, officers found
an EDD card in K. KING’s name, four EDD cards issued to CMG, SM,
RJW, and SRS, two index cards with handwritten victim PII
profiles (including names, dates of birth, and social security
numbers) for JS and SNW, eight ATM receipts corresponding to the
EDD cards, and $550 in cash. 1 The receipts were for $1,000
withdrawals at Wells Fargo ATMs. Four of the receipts were for
withdrawals made with the CMG and SM cards.
b. A black Android and black Verizon Motorola phone
in the center consul, a red iPhone on the passenger seat, and a
blue iPhone in the car. As described below, officers also found
a gold Samsung phone in C. JOHNSON’s backpack.
c. A blue Tahari handbag on the passenger
floorboard. Inside the bag officers found $25,180 in one bundle
of cash, $950 in another bundle of cash, eight receipts for
$1,000 ATM withdrawals from several different EDD accounts on
1 Unless stated otherwise, individuals identified with
initials are victims whose PII was used to fraudulently obtain
UI benefits from EDD, the term “account” refers to a fraudulent
EDD account, “card” refers to an EDD debit card, and “use” of a
card refers to a fraudulent ATM withdrawal.
8
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September 4 through 6, 2020, and a parking stub for the Los
Angeles International Airport (“LAX”) Holiday Inn. 2
d. C. JOHNSON’s black Dolce and Gabbana backpack
(the “D&C backpack”). In the backpack officers found C.
JOHNSON’s work ID (bearing his name and photograph), a gold
Samsung cell phone (which was one of the five phones described
above), $11,961 in cash, an EDD card issued to MP, EDD mail
addressed to ARC, 3 an ATM receipt, a Polymer80 sticker, and a
hotel room card holder bearing the handwritten number 834.
e. A Fendi backpack, believed to be K. KING’s, on
the driver’s side of the rear cargo area of the vehicle. Inside
the backpack officers found two notebooks with handwriting that
appears to match the handwriting on the index cards found in K.
KING’s wallet (collectively “K. KING’s ledger”), and a receipt
for the LAX Holiday Inn. The backpack also contained a sanitary
pad, and opened and unopened mail addressed to EDD victims at a
particular address on West Florence Avenue in Los Angeles, an
apartment complex with outside mailboxes that I believe the
defendants used to receive EDD cards and mail.
23. The ledger contained 98 victim PII profiles with
notations reflecting payments and account statuses. All 98
profiles from K. KING’s ledger were used to apply for EDD
benefits, though EDD only issued cards corresponding to 82 of
the profiles.
2 Unless stated otherwise, all cities described in this
affidavit are in California.
3 Travel records show that ARC left the United States
approximately eight years ago and has not returned.
9
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24. During the Range Rover search, the officers asked C.
JOHNSON whether he and K. KING were staying at the LAX Holiday
Inn, and C. JOHNSON responded that they had stayed there but
recently moved to a nearby Hilton Hotel (“LAX Hilton”). K. KING
and C. JOHNSON were then arrested on state charges related to
the stolen identities and mail. Incident to arrest, on C.
JOHNSON’s person, officers found $2,465 in cash and a Holiday
Inn Express room key.
25. The officers then requested the help of IPD Officers
Lee and Vega, who went to the LAX Hilton and asked the front
desk whether K. KING or C. JOHNSON were guests. The front desk
employee said that a particular room was registered in K. KING’s
name, though the room was vacant. The officers next went to the
LAX Holiday Inn, where the front desk employee confirmed that
Room 834 was rented to K. KING and currently occupied. The
officers then conducted a probation compliance check of Room 834
and found a Polymer80 ghost gun with an empty 17-round magazine
in the center nightstand between the two beds, a Tommy Hilfiger
bag containing an EDD card issued to victim SW and seven
receipts reflecting $1,000 ATM withdrawals, a black leather
purse containing EDD mail issued to JS, ODS, and SNW (all of
whom were in K. KING’s ledger), and four additional receipts
reflecting withdrawals from Wells Fargo ATMs.
26. The following chart summarizes the evidence found in
K. KING and C. JOHNSON’s possession during the September 6, 2020
arrest. In the chart, PII stands for “PII profile,” “M” denotes
EDD mail issued to the victim, “C” denotes a fraudulent EDD card
10
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issued to the victim, and “CR” denotes a fraudulent EDD card and
corresponding ATM withdrawal receipt. The EDD accounts
corresponding to the evidence seized from K. KING and C. JOHNSON
during the September 6, 2020 arrest are referred to in the
remainder of this affidavit as the “IPD accounts.”
Victim Ledger Fendi Bag Wallet D&C Backpack Room 834
AGW PII
ARC M
AS PII
AJS PII
AMS PII
BJS PII M
BDW PII
CSW PII
CF PII
CS PII
CVS PII
CSL PII
CMG CR
CHW PII
DLS PII M
D.Sko. PII
DMS PII
DSS PII
D.Ske. PII
D.Fo. PII
DW PII
DES PII
DJW PII
D.Sla. PII
DJS PII M
FRS PII
FGS PII
FMS PII
F.Sl. PII
FCW PII
GMS PII
11
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GCS PII
GBS PII
G.Si. PII
GWW PII
HFS PII
HAC PII
JW PII
JES PII
JMS PII
JSM PII
JL PII
J.Si. PII
JW PII
JSS PII
J.Sil. PII
JCS PII
JJS PII
J.Wi. PII
JWJ PII
JS PII PII M
JHW PII
JMD PII
JDW PII
K.Se. PII
LAW PII
L.Wi. PII
LO PII
LJW PII
LMS PII
LJB PII
L.Si. PII
MJW PII M
MP CR
MRS PII
MES PII
MAW PII M
MFS PII
MS PII
MWS PII
12
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NTS PII
NL PII
OWW PII
ODS PII M
PDW PII
PMS PII
PHS PII
PGW PII
RFS PII
RS PII
RYS PII
REW PII
RJW PII M C
RLS PII M
RMW PII M
RLW PII
RJS PII
SMS PII
SM CR
SW PII
SRS PII M C
SNW PII PII M
SS PII
SLS PII
TDS PII
TAW PII
WJS PII M
27. Notably, at least 10 of the defendants, including
PLUMMER, K. KING, C. JOHNSON, J. JOHNSON, F. KING, MITCHELL,
DAVIS, P. JOHNSON, PACE, and WADE, were captured on ATM
surveillance video using the fraudulent IPD accounts. For
example, as described above, the PII for PGW, FMS, D.Fo., and
NTS, were found in K. KING’s ledger, and EDD cards issued to CMG
and MP (along with corresponding ATM receipts) were found in the
Range Rover. ATM surveillance photographs depict:
13
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a. K. KING making fraudulent withdrawals using the
PGW card.
b. PLUMMER and MITCHELL making fraudulent
withdrawals using the FMS cards.
c. F. KING making fraudulent withdrawals using the
D.Fo. card.
d. P. JOHNSON making fraudulent withdrawals using
the SM card.
e. WADE making fraudulent withdrawals using the NTS
card.
f. C. JOHNSON and J. JOHNSON making fraudulent
withdrawals using the CMG card.
g. PLUMMER, C. JOHNSON, J. JOHNSON, and DAVIS making
fraudulent withdrawals using the MP card.
28. On October 16, 2020, in MJ 20-5008, Magistrate Judge
Oliver issued a federal warrant to search the five cell phones
from the Range Rover. Agents successfully extracted three of the
phones. The Android and Motorola phones from the center console
of the Range Rover and K. KING’s iPhone contained evidence that
the phones were used to access dozens of fraudulent EDD
accounts, including those associated with the PII found in the
ledger, Range Rover, and Room 834. 4 For example, extracts from
the Android and Motorola cell phones show that the phones were
The iPhone I identify as K. KING’s was routinely used to
4
access the Gmail account khashandaking@gmail.com.
14
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used to access the WS and AS accounts, both of whom appear in K.
KING’s ledger, depicted as follows:
d. ATM Photographs
29. Following the September 6, 2020 IPD arrest, I obtained
from Bank of America more than 1,000 ATM photographs of the
transactions conducted with the IPD accounts and accounts linked
via phone analysis (described below). The ATM photographs are
digitally stamped with dates, times, and locations.
30. Those Bank of America ATM photographs show PLUMMER, C.
JOHNSON, J. JOHNSON, F. KING, MITCHELL, DAVIS, P. JOHNSON, PACE,
ROBERTSON, and WADE making withdrawals using EDD cards in
victims’ names using the IPD accounts tied to K. KING and C.
JOHNSON.
31. I also acquired photographs from Wells Fargo of the
fraudulent ATM withdrawals that were made using the IPD accounts
for the time period between August 22,2020 and October 3, 2020.
The photographs show K. KING, C. JOHNSON, ROBERTSON, and others
making the withdrawals using the fraudulent IPD accounts.
15
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32. I describe the ATM photographs of the defendants
making fraudulent withdrawals more fully at the end of this
affidavit.
d. Phone Link Analysis
33. During the investigation, I obtained records showing
that certain phone numbers were used to call Bank of America to
access the fraudulent EDD accounts, that is, change account
information, recertify EDD eligibility (which EDD requires every
two weeks), and conduct other account functions on the
fraudulent EDD accounts. Those records show that phones
subscribed to in the names of PLUMMER, MITCHELL, K. KING, C.
JOHNSON, P. JOHNSON, and PACE were used to access dozens of
fraudulent EDD accounts. For example:
a. PLUMMER was the subscriber of phone number 323-
713-5679 (“PLUMMER’s 5679 number”). This number was used to
access at least 15 EDD accounts, including those of PLUMMER, and
inmates AMP and SMR, who were previously housed with both DEMOLA
and PLUMMER in a CDCR prison. 5
b. PLUMMER and MITCHELL’s relative was the
subscriber of the number 323-270-9079 (“the 9079 number”). 6 That
number was used to access at least seven EDD accounts.
c. MITCHELL was the subscriber of the phone number
323-456-6874 (“MITCHELL’s 6874 number”), which was used to
5 DEMOLA is serving a life-sentence in the CDCR system for
first-degree murder. PLUMMER was serving a sentence in the CDCR
system and was housed with DEMOLA until she was paroled on July
8, 2020.
6 PLUMMER listed this individual as a particular relative on
her United States passport application.
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access at least 20 EDD accounts, including those of DEMOLA and
SMR.
d. K. KING was the subscriber of phone number 323-
532-5345, which was used to access at least 16 EDD accounts,
mostly corresponding to the PII found in her ledger.
e. C. JOHNSON was the subscriber of phone number
323-641-2036, which was used to access at least seven EDD
accounts, mostly corresponding to the PII found in K. KING’s
ledger.
f. P. JOHNSON was the subscriber of the phone number
424-310-8249 (“P. JOHNSON’s 8249 number”), which was used to
access at least nine EDD accounts, including those in the names
of AJS, BJS, DLS, JJW, JS, MM, ODS, SNW, and WJS, all of whom
appeared in K. KING’s ledger. K. KING also appears on Wells
Fargo surveillance using the JJW, ODS, and WJS cards.
g. PACE was the subscriber of the phone number 323-
809-6628 (“PACE’s 6628 number”). This number was used to access
at least three EDD accounts in the names of FMS, LS, and MDJ.
e. CDCR Inmate Interviews
34. In 2021, I and other agents interviewed DEMOLA, DAVIS,
and several victims whose identities were used in the scheme,
all of whom were incarcerated in CDCR prisons, and all of whom
were issued fraudulent cards that PLUMMER, MITCHELL, J. JOHNSON,
DAVIS, and ROBERTSON used to withdraw EDD funds. The interviews
were audio-recorded, and before each interview, the inmates
waived their Miranda rights. I have summarized those interviews
as follows.
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35. On January 6, 2021, agents interviewed Witness 1, 7 who
denied giving anyone her PII or authorizing anyone to use her
identity to apply for EDD benefits. Witness 1 stated that
someone asked her to deposit $50 into DEMOLA’s prison account
because DEMOLA owed restitution. Witness 1 otherwise denied
knowing K. KING, C. JOHNSON, or MITCHELL. On January 20, 2021,
agents interviewed Witness 1 again. On this occasion Witness 1
stated that MITCHELL gave her the $50 to deposit into DEMOLA’s
account and that she had been friends with DEMOLA for a long
time. Witness 1 also stated that she knew PLUMMER because they
were in the same housing unit at one point and were friends
until PLUMMER stole personal items from Witness 1’s cell.
According to Witness 1, everyone in their prison unit knew
PLUMMER as “LG.” Witness 1 told agents that PLUMMER was DEMOLA’s
closest friend until PLUMMER was paroled, who was released
because she was pregnant.
36. On January 6, 2021, agents interviewed Witness 2, who
said that she never applied for EDD benefits because her
earliest possible release date was in 2029. When asked why she
allowed others to apply for benefits using her identity, Witness
2 initially stated that she had not done so, then admitted that
in exchange for $6,000 she provided her PII to a female inmate
who had been paroled a few months earlier, who I believe to be
7 As stated above, throughout this affidavit, I use initials
to refer to victims whose identities were used in the scheme.
However, to mitigate witness safety and intimidation concerns,
when describing law enforcement interviews, I refer to witnesses
by number.
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PLUMMER. Witness 2 said she could not remember the inmate’s
name, but added that this was a “one-time thing” and “it sounded
good, and I gave her my information like an idiot.” Witness 2
told agents that she never received the promised money. Witness
2 also stated that she gave her PII to a woman named “LG”
(PLUMMER’s nickname).
37. On January 21, 2021, agents interviewed Witness 2
again. On this occasion Witness 2 said that she had asked other
inmates in her unit about LG and that one inmate referred to her
as “Carleisha,” which is PLUMMER’s first name. Witness 2 also
said that LG was best friends with DEMOLA and that LG always
talked about DEMOLA. This time Witness 2 admitted that PLUMMER
asked her if she wanted to make money from the EDD scheme, and
told Witness 2 that all she needed was Witness 2’s social
security number and date of birth, and that PLUMMER would “take
care of the rest.” Witness 2 agreed and told PLUMMER “as long as
I get my money, I’m not tripping.” According to Witness 2,
PLUMMER was supposed to deposit the money into Witness 2’s
prison account, but never did, and Witness 2 never heard from
PLUMMER again.
38. On January 6, 2021, agents interviewed Witness 3, who
said that Witness 3 was her cellmate and that a black, pregnant
female inmate who she knew as LG approached Witness 3 about
participating in the EDD scheme. Witness 3 agreed because she
had no money in her prison account and provided her “social
security number and information” to PLUMMER, who she referred to
as LG. PLUMMER agreed to give Witness 3 $11,000 and told Witness
19
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3 that she needed an outside address where EDD would send the
card. Witness 3 gave PLUMMER her sister’s address, and PLUMMER
said that Witness 3’s sister would receive an $11,000 check in
the near future. Sometime later, Witness 3’s sister told Witness
3 that an EDD card arrived and asked Witness 3 how she could get
unemployment if she was “locked up.” Witness 3 told her sister
that someone, referring to PLUMMER, was “doing something for
her,” and the sister activated the card, but later told Witness
3 that it was declined at a store. This is when Witness 3
realized that PLUMMER tricked her, though she knew all along
that her conduct was illegal.
39. On May 24, 2021, agents spoke with DEMOLA. During this
interview, DEMOLA stated that if she and a particular
coconspirator got charged, she would take responsibility for the
whole scheme. DEMOLA also said she knew “it was over” and that
she would get charged.
40. On May 18, 2021, agents interviewed DAVIS, who was
incarcerated at a different CDCR prison for a recent parole
violation. One day later, DAVIS called PLUMMER from jail on a
recorded line and said that federal agents had interviewed her.
During the call, PLUMMER asked DAVIS what charges would be filed
and who the agents thought was involved in the scheme. PLUMMER
then told DAVIS not to contact her again at PLUMMER’s 5679
number 8 and said that she would “get rid of” that phone. PLUMMER
8 As described above, PLUMMER used this phone to access EDD
accounts.
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also told DAVIS to only communicate with PLUMMER through an
intermediary.
f. Recorded Inmate Communications
41. During the investigation, I obtained emails from
DEMOLA’s prison account. Several of the emails are between
DEMOLA and an email account in the name of JB (the “JB
account”). 9 I believe that PLUMMER used the JB account. In prison
emails I reviewed, the user of the JB account is referred to as
“Carleisha” or “LG,” being PLUMMER’s first name and nickname.
Moreover, on July 28, 2020, the day before PLUMMER was paroled
and released from CDCR custody, DEMOLA wrote the following email
to the JB account in which she referred to the recipient as a
woman, said “tomorrow is your big day” and that she would miss
her, and made references to “cards” that PLUMMER would handle. 10
hey friend, tomorrow is your big day. I just wanted to say
goodbye for now, I love you and so proud of the woman you
are. you are a great mom and beautiful friend, I miss you
already. I tested negative for the covid. me and like 12-15
others, that’s all that was left. God had me because I was
around the prison. I want u to get my cards from my man and
for u to handle it because I just dont know what is going
on with my stuff. we will talk about it. so if u can change
it to resend to u that would be great. love u. me and josh
talked today, he said we are back together. he is crazy.
love u friend, can’t wait to talk to u. goodnight and know
I am with u.
42. In other emails, DEMOLA sent usernames, passwords,
card names, victims’ names, and account phone numbers to PLUMMER
9 JB was a male victim of the EDD fraud, and at the time of
the email communications between PLUMMER and DEMOLA, had been an
inmate at Salinas Valley State Prison for several years.
10Inmates are warned that their emails are monitored when
they log onto their prison email accounts.
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at the JB email address. For instance, on July 30, 2020, DEMOLA
sent PLUMMER the following email about DF, who I confirmed to be
an identity theft victim. DEMOLA also mentions MDS, another
identity theft victim whose fraudulent EDD account PLUMMER
accessed, further establishing that PLUMMER used the JB email
account.
hey friend so glad to talk to u. I gave my best friend your
number so she will get in contact with u. I cant wait to
bug u tomorrow. so I got some people I need u to contact
about my commutation and that can help. I am sending their
birthday so u can send them a card and contact them. also
please tell the barber to contact me on this jpay and give
him my info. Natalie DEMOLA x12907. and tell him to put
minutes on his phone so I can call and let him know i sent
my package list. [Redacted EDD account information,
including information related to the DF and MDS accounts] 11.
check and change to u let me know if u get this.
43. Then, on August 2, 2020, DEMOLA sent J. JOHNSON the
following email where DEMOLA expressed disappointment in J.
JOHNSON, saying that her EDD mail was not going to the right
place, which DEMOLA identified as Coconspirator 2’s address in
Hillsboro, North Dakota. In the same email, DEMOLA tells J.
JOHNSON that he should give “the cards” to Carleisha, which
again is PLUMMER’s first name:
hey there, I don’t know what is going on with u but just
know u r in my prayers. I have been thinking of u and
actually very dissapointed in u. I have not heard from u to
know that u r OK or not, u don’t pick up my calls, and my
mail have not got to where it needs to. I don’t get it and
thought you were more responsible and communicate. and u
know how it is to be locked up and have no one and have to
depend on others. u just said I could do that with u and
depend on u but with this situation your actions have not
shown that. what is going on with u? just be straight
11Bracketed text denotes redactions and changes made to
protect victim PII and EDD account information.
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forward with me and don’t forget how it felt to be locked
up and where I am coming from. I know u may not respond and
if so, that is fucked up and u should not treat people like
that. but if u do respond just be honest with me like u
said u would. and please get my mail to where I told u.
[Coconspirator 2]
[Address in Hillsboro, North Dakota]
please be a man of your word like I believed you were. when
u see carliesha, just give her the cards because I think
this is too much on u. take care of yourself, I hope to
hear back, but by the looks of it, I may not and I still
wish u the best.
44. On August 2, 2020, DEMOLA sent PLUMMER another email
at the JB account with more account information and instructions
on what to do with the EDD applications and cards. Notably,
DEMOLA’s email makes reference to PO Box 144 in Yucaipa,
California (“PO Box 144”), which MARTIN used to collect EDD mail
(as described below), victim DF, “Niddy” (which is J. JOHNSON’s
nickname), and victim AA (an account PLUMMER accessed
telephonically accessed):
I don’t mean to keep reminding u, but can u please get on
it and tell me what is done once u do it.
1) call and say u did not receive it. ask for balance, and
shut it off and say u just changed the address and will
wait for next week to resend it, but shut it off now for
your safety for all of these
[Redacted EDD account information]
this is the one I think niddy messed up:
questions: senior prom theme, candy
favorite high school sport, swim
team u want to lose, Lakers
favorite pet name, lily
[Redacted EDD account information, including AA account
information]
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Dominique martin
[Redacted EDD account information]
P.O. box 144
yucaipa ca. 92399
2) call and change pin
[DF] and [MDS], you got the info already
3) cert
[Redacted EDD account information, including DF account
information]
45. In this above email, DEMOLA says that “Niddy messed
up” with an account. The evidence shows that Niddy is J.
JOHNSON, whose first name is James. DEMOLA initially
communicates with Niddy while he uses the account under the name
Anthony Johnson. Then, DEMOLA starts communicating with an
account in the name JAMES JOHNSON, then Niddy Johnson, and
finally Big Dawg Niddy, where DEMOLA repeatedly calls the
recipient “James” and says that she removed the other accounts
from her prison email contact list. Moreover, J. JOHNSON, using
the Big Dawg Niddy account, sent photographs of himself to
DEMOLA, depicted below:
46. In addition to DEMOLA’s incriminating references to
PLUMMER about Niddy, DEMOLA also communicates with Niddy, or J.
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JOHNSON, directly about the EDD scheme. For example, on July 22,
2020, J. JOHNSON, using the Niddy Johnson account, emailed the
following to DEMOLA in which he says that he activated a card
loaded with $12,000:
thank u so bby 4 ur email listen bae the card 4 Andrew came
2day bby can I plz activate it an take a rack 2night I
really need it bby ill still stack 4nu an won’t burn the
card lmk if its good yes just one, then stop, reminder its
not all mine. wait til we can talk. ok bby i got u thank u
im doing it rn whats the birthday cuz I activated but it
did not let me set a pin but its 12000 on the card I need
the birhtday an the sports team bby asap
47. DEMOLA also gave EDD fraud instructions to PLUMMER and
J. JOHNSON over recorded prison phone lines. During the calls,
DEMOLA, PLUMMER, and J. JOHNSON at times openly discuss the
creation of EDD accounts, recertifying EDD eligibility, and
others aspects of the scheme. 12
48. Moreover, F. KING made one recorded call to an
incarcerated male relative where she said “I got this new thing
where I can make you make some change . . . everybody doing it .
. . the EDD thing.”
g. Coconspirator 1
49. Between December 2020 and January 2021, CDCR’s
Investigative Services Unit (“ISU”) received information from a
complainant that Coconspirator 1, an employee at the prison, was
providing inmate PII to DEMOLA in furtherance of the EDD scheme.
According to the complainant, the agreement was that DEMOLA
would pay Coconspirator 1 through a cash payment app 50 percent
12Each call begins with a warning that the call is
monitored.
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of DEMOLA’s proceeds from the EDD scheme. The complainant stated
that she saw DEMOLA walk out of Coconspirator 1’s office with a
spreadsheet of PII, and when she asked DEMOLA where she got the
spreadsheet, DEMOLA responded that she received it from
Coconspirator 1.
50. In March 2021, I obtained Coconspirator 1’s CDCR
database access records, which showed that Coconspirator 1
accessed information, including PII, on hundreds of female
inmates, 42 male inmates (despite the fact that Coconspirator 1
worked in a women’s prison), and those inmates’ approved
visitors.
51. The PII Coconspirator 1 accessed included names,
social security numbers, and dates of birth. In total, during an
eight-month period between April and December 2020,
Coconspirator 1 ran 711 inmates and visitor profiles. More than
250 of those names were used to apply for EDD. Records show the
following connections, among others, between Coconspirator 1 and
the photographed ATM transactions associated with the scheme.
52. MITCHELL’s 6874 phone was used to access several EDD
accounts, including the account in DEMOLA’s name. At least five
cards that MITCHELL accessed using her 6874 phone are linked to
Coconspirator 1 and other coconspirators, including the
fraudulent cards issued to AAM, DPR, REAT, SMA, and TKJ, as
follows.
53. AAM was a female inmate who was not under
Coconspirator 1’s direct supervision. On June 22, 2020,
Coconspirator 1 checked AAM’s PII using the CDCR database. Four
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days later, an EDD application was filed in AAM’s name. ATM
photographs show MITCHELL, ROBERTSON, and PLUMMER using the AAM
card as follows:
a. MITCHELL used the AAM card on July 20, 2020 to
withdraw $1,000 from an ATM near Los Angeles Street and Alameda
Street in Los Angeles.
b. ROBERTSON used the AAM card on August 8, 2020 to
withdraw $1,000 at an ATM at Imperial Highway and Paramount
Boulevard in Downey.
c. PLUMMER used the AAM card on October 10, 2020 to
withdraw $600 at an ATM near 57th Street and Crenshaw Boulevard
in Los Angeles.
54. DPR was a female inmate under Coconspirator 1’s
supervision. Coconspirator 1 accessed her PII on May 4, May 11,
and June 16, 2020. Then, on June 27, 2020, an EDD application
was filed in DPR’s name. As described below, DPR stated in an
interview that she never applied for EDD and had not given
anyone her PII. ATM photographs show MITCHELL and ROBERTSON
using the DPR card as follows:
a. MITCHELL used the DPR card on July 20, 2020 to
withdraw $1,000 from an ATM near Los Angeles Street and Alameda
Street in Walnut Park.
b. ROBERTSON used the DPR card on August 7, 2020 to
withdraw $1,000 from an ATM near Imperial Highway and Paramount
Boulevard in Downey.
55. REAT was a female inmate at the women’s prison, though
she was not under Coconspirator 1’s supervision. Coconspirator 1
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accessed REAT’s PII on April 3, 2020. On June 28, 2020, an EDD
application was filed in REAT’s name. ATM photographs show
MITCHELL and ROBERTSON using the REAT card as follows:
c. MITCHELL used the REAT card on July 9, 2020 to
withdraw $1,000 from an ATM in San Diego, on July 14, 2020 to
withdraw $1,000 from an ATM near North Gardena Avenue in
Gardena, and on July 20, 2020 to withdraw $1,000 from an ATM
near Los Angeles Street and Alameda in Walnut Park.
d. ROBERTSON used the card on August 7, 2020 to
withdraw $1,000 from an ATM near Imperial Highway and Paramount
Boulevard in Downey.
56. SMA was a female inmate at the women’s prison, though
not under Coconspirator 1’s supervision. Coconspirator 1
accessed SMA’s information on May 6, 2020. On June 16, 2020, an
application was filed in SMA’s name. The next day Coconspirator
1 again checked SMA’s profile. ATM photographs show MITCHELL
using the SMA card on July 9, 2020 to withdraw $1,000 from an
ATM in San Diego, on July 14, 2020 to withdraw $100 from an ATM
on Main Street in Gardena, on July 15, 2020 to withdraw $1,000
from an ATM in Victorville, and on July 20, 2020 to withdraw
$1000 from an ATM on Los Angeles Street and Alameda Street in
Walnut Park.
57. Moreover, PLUMMER’s 5679 phone and a prepaid phone
with the number 323-473-6951 (a phone for which PLUMMER paid)
accessed the EDD accounts of DF and TKJ, among others.
Coconspirator 1 used the CDCR database to access both inmates’
PII, and ATM photographs show that J. JOHNSON and DAVIS
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subsequently used the fraudulent EDD cards issued to those
inmates.
58. DF, a female inmate at the women’s prison, was only
briefly under Coconspirator 1’s supervision from August 14 to
19, 2020. On May 12, 13, 14, and 18, 2020, Coconspirator 1
accessed DF’s PII. On June 30, 2020, an EDD application was
filed in DF’s name. ATM photographs show that J. JOHNSON
repeatedly used this card. For example, ATM photographs show
that J. JOHNSON used the DF card on July 11, 12, 13, 16, and 17,
2020, each time to make a $1,000 withdrawal from an ATM in
Wilmington. Then, on July 18, 2020, J. JOHNSON used the DF card
to withdraw $80 from an ATM in Wilmington.
59. TKJ, a female inmate at the women’s prison, was never
under Coconspirator 1’s supervision. Nonetheless, Coconspirator
1 ran TKJ’s information on June 11, 2020. Later that day an EDD
application was filed in TKJ’s name. ATM surveillance recorded
DAVIS using the TKJ card on August 6, 2020 to withdraw $500 from
an ATM in El Segundo.
h. Dominique Martin
60. During the investigation, I discovered emails between
DEMOLA and a particular email address that I refer to in this
affidavit as the “LVM account.” I identified the user of the LVM
account as MARTIN.
61. On April 11, 2020, DEMOLA wrote to the LVM account
“hey cousin, just wanted to check in on you and Lisa. hey Lisa!
I miss you and please let mike know I have not been able to call
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because we are on lockdown. OK, I love u both, email back when u
can. good night.”
62. Several months later, on July 7, 2020, DEMOLA received
an email from the LVM account that “Dominique” (MARTIN’s first
name) signed and that read “Hey I need you to call me ASAP I
need all the information about my case you did for me reach out
love you Dominique.”
63. Moreover, records show that MARTIN was married to a
woman whose initials are LVM, whose name appears in the LVM
account address, and who lived a particular address on Beech
Avenue in Yucaipa, California (the “Beech Avenue residence”).
64. On August 2, 2020, DEMOLA emailed PLUMMER at the JB
email address. In the email to PLUMMER, DEMOLA refers to MARTIN
by full name and PII, and refers to PO Box 144 in Yucaipa,
California.
65. On August 3, 2020, MARTIN, using the LVM account, sent
DEMOLA an email reflecting a falling out between the two. In the
email, MARTIN suggests that she provided PII that was used in
the EDD scheme to get EDD benefits, but that the addresses
associated with the EDD accounts changed, and that out of
frustration, MARTIN would go to law enforcement. The email read
as follows:
Hey for starters if you think I won’t blow this shit all
the way out the water I’m gonna say try me I got enough on
this shit to nail the coffin If you care about your future
for real run me ALL the information you came up on it’s
real convenient how everyone I sent you got approved but no
one got they cards checked myself all address changed for
real if you don’t find a way to run me my shit I’m spilling
it all for real run me at least $5000 seriously try me dude
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cause you handled all that Nd we still got all
thecorrespondents so.Gimme Chris shit at least you foul for
this but we all know how to play games we already called
looked into it and we got all the resources out here FIX IT
FOR REAL make your next move your best move cause I’m about
to blow this shit up”,” My next move is ISU know that this
chess not checkers boo”,” If we don’t get that by tomorrow
it’s OVER on GOD”,” You played the wrong people Natalie
you’ll be staying right where your at how’s your lawyer
going to get you out of this one
66. The next day DEMOLA responded, giving MARTIN
credentials to log into an EDD account and suggesting that the
card got sent to a PO Box where no one could sign for the
delivery:
[Redacted EDD account information] she gave me this info,
go on the site and then call bank. she said when its sent
to a po box and they send it priority it needs a signature
and gets sent back because po box, no one signs. so it sits
at the bank waiting to be called and resent. u will see no
foul play, like I said a while ago, I don’t want to do this
anymore and can’t, handle it yourself. and leave me alone.
67. On April 30, 2021, agents conducted an audio-recorded
interview of MARTIN, who waived her Miranda rights. MARTIN
admitted that she was married to and separated from LVM, that
her address was the Beech Avenue residence, that she had
received EDD mail, that she received an EDD card in the KSR’s
name, and that she used the KSR card to withdrawal between
$10,000 and $12,000 at a nearby Chase Bank branch.
68. MARTIN admitted that she used PO Box 144 to receive
EDD mail, which is the same address that DEMOLA gave PLUMMER in
the August 2, 2020 email described above. EDD records show that
the card issued to KSR was sent to the Beech Avenue residence
and that four fraudulent cards were sent to PO Box 144,
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including the MDS card that DEMOLA refers to in emails with
PLUMMER and the fraudulent EDD card issued to MARTIN.
69. Further, MARTIN admitted to previously living with LVM
at a particular address on Third Street in Yucaipa, California,
where EDD sent three additional fraudulent cards.
70. MARTIN also admitted to agents that she was married to
LVM and lived at the Beech Avenue address. EDD records show that
at least nine fraudulent EDD cards were sent to the Beech Avenue
address.
71. On May 11, 2021, with a task force officer and CDCR
officers, a parole search was conducted on MARTIN’s home. In the
home, agents found EDD correspondence to KSR, a tax document
containing victim PII, EDD mail and tax records to MM, and EDD
mail to LMVD and MAD.
72. During the encounter, agents interviewed a witness who
said that she had recently seen MARTIN dispose of additional EDD
mail.
i. Victim Interviews
73. During the investigation, I located numerous victims
whose identities were used to execute the EDD scheme. I
summarize those victim interviews as follows.
74. Witness 4 was an employed policy analyst based in
Northern California. Witness 4 told agents that he had been an
identity theft victim in the past, and did not authorize anyone
to apply for EDD benefits in his name. During the IPD arrest,
Witness 4’s PII was found in K. KING’s ledger.
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75. Witness 5, a CDCR inmate, said he did not authorize
anyone to apply for EDD benefits while he was incarcerated. When
asked if anyone had his information, Witness 5 mentioned an ex-
girlfriend in Texas, but otherwise did not know how anyone used
his information to apply for EDD benefits. ATM photographs show
F. KING using the Witness 4 card to make fraudulent withdrawals.
Moreover, during the IPD arrest, Witness 4’s PII was found in K.
KING’s ledger.
76. Witness 6, a CDCR inmate in the women’s prison who had
been in custody for the previous seven years, began crying when
the interviewing detective told her why he was there. While
crying, Witness 6 said that she thought someone stole her
identity because she had applied for “stimulus payments” and did
not get anything. When the detective asked Witness 6 whether she
knew MITCHELL or ROBERTSON, Witness 6 said no. ATM photographs
show MITCHELL and ROBERTSON using the Witness 6 card to make
fraudulent withdrawals, and records show that MITCHELL’s phone
was used to access the Witness 6 account.
77. Witness 7 never applied for EDD employments or give
anyone permission to use his information. Witness 7 said that he
was ineligible for unemployment because he was retired. Witness
7 did not know F. KING, who used the EDD card in his name.
During the IPD arrest, Witness 7’s PII was found in K. KING’s
ledger.
78. Witness 8, an inmate in the CDCR system, said that he
did not apply for EDD benefits or authorize anyone to use his
PII. Witness 8 had only authorized his mother and cousin
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(neither of whom appear related to this case) to handle his
financial affairs. Witness 8 did not know MITCHELL and
ROBERTSON, who used the EDD card in his name. PLUMMER’s phone
was used to access the Witness 8 account.
79. Witness 9, who is 83 years old, said that he has never
lived in, or applied for benefits in, California. Witness 9 has
never allowed anyone to use his PII to apply for unemployment
benefits. When asked if he knew K. KING, who used the card in
his name, Witness 9 said “absolute not.” P. JOHNSON’s phone was
used to access the Witness 9 account. Moreover, during the IPD
arrest, Witness 9’s PII was found in K. KING’s ledger, and an
ATM receipt corresponding to the Witness 9 card was found in the
Range Rover with K. KING and C. JOHNSON.
80. Witness 10 told agents that he was retired and that he
never gave anyone permission to use his PII to apply for EDD
benefits. Witness 10 did not know K. KING, who used the card in
his name. Witness 10’s PII was also found in K. KING’s ledger,
K. KING’s phone was used to access the Witness 10 account, and
an ATM receipt corresponding to the Witness 10 card was found in
the Range Rover with K. KING and C. JOHNSON.
81. Witness 11, an inmate in the CDCR system, said that he
had been incarcerated for 15 years and was not familiar with EDD
benefits. Witness 11 said he did not know MITCHELL or PACE, who
used the EDD card in his name. PACE’s phone was used to access
the MDJ account.
82. Witness 12 was a CDCR inmate until April 2021, when he
was release on parole. Witness 12 said he “absolutely did not
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file for benefits” in 2020, and never gave anyone permission to
use his identity to apply for EDD benefits. Witness 12 had never
heard of J. JOHNSON, who used the card in his name. PLUMMER’s
phone was used to access the Witness 12 account, which is also
referenced in emails between DEMOLA and PLUMMER.
83. Witness 13 never applied for EDD employments or give
anyone permission to use his information, and was ineligible for
unemployment because he was incarcerated. ATM photographs show
PLUMMER, C. JOHNSON, J. JOHNSON, and DAVIS making fraudulent
withdrawals using the Witness 13 card, and PLUMMER’s phone was
used to access the account. Moreover, both the Witness 13 card
and a corresponding receipt were found in C. JOHNSON’s Dolce and
Cabana backpack during the IPD arrest.
84. Witness 14 was employed as a “handyman.” Witness 14
had applied online and by mail for EDD benefits on several
occasions, but never received a response. Otherwise, Witness 14
said that he did not authorize anyone to apply for EDD benefits
in his name, and did not know WADE, who used the EDD card in his
name. During the IPD arrest, Witness 14’s PII was found in K.
KING’s ledger.
85. Witness 15 told agents that he used to live in
California, but currently lives in Arizona and works as a
teacher. Witness 15 has never allowed anyone to use his PII. He
did not know K. KING, who used the card in his name. During the
IPD arrest, Witness 15’s PII was found in K. KING’s ledger, and
an ATM receipt corresponding to the Witness 15 card was found in
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the Range Rover with K. KING and C. JOHNSON. Moreover, K. KING’s
phone was used to access the Witness 15 account.
86. Witness 16 never applied for EDD employments or give
anyone permission to use his information. Witness 16 said that
he was ineligible for unemployment because he was retired.
During the IPD arrest, Witness 16’s PII was found in K. KING’s
ledger, EDD mail addressed to Witness 16 was found in the Range
Rover with K. KING and C. JOHNSON, and the Witness 16 card was
found in K. KING’s wallet.
87. Witness 17 never applied for EDD employments or give
anyone permission to use his information, and was ineligible for
unemployment because she was incarcerated and serving a 25-year
sentence for carjacking. ATM photographs show P. JOHNSON using
the Witness 17 card, which was found in K. KING’s wallet (along
with a corresponding ATM receipt) during the IPD arrest.
88. Witness 18 never applied for EDD employments or give
anyone permission to use his information. Witness 18 said that
he was ineligible for unemployment because he was employed.
During the IPD arrest, Witness 18’s PII was found in K. KING’s
ledger, EDD mail to Witness 18 was found in the Range Rover with
K. KING and C. JOHNSON, and the Witness 18 card was found in K.
KING’s wallet.
89. Witness 19, an inmate at the CDCR women’s prison, said
she did not apply or authorize anyone to apply for EDD benefits
using her PII. Witness 19 said she did not know DAVIS, who used
the EDD card in her name. PLUMMER’s phone was used to access the
Witness 19 account.
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j. Employment Records
90. For 22 selected victims, I obtained state employment
records to determine whether there was any indication from the
victim’s wage history that the victim worked in the profession
stated on the fraudulent application. 13 The victims for whom I
obtained wage records were KSR, MDS, DF, MDJ, KS, AAM, DMB, MP,
TRS, DDJ, SM, NMS, NTS, PGW, DSS, D.Fo., JJW, LS, RJ, AMS, FS,
and ARC. I chose to acquire the wage records for these specific
victims because ATM photographs collectively show each defendant
other than DEMOLA and MARTIN using the fraudulent EDD cards
issued to these victims, MARTIN admitted to using the card
issued to KSR, and DEMOLA references the MDS account in her
prison emails. The records further evidenced the fact that the
EDD applications were false.
91. For the years 2018 to 2021, of the foregoing victims,
only five had wage histories. Those five victims were AMS, DSS,
MDS, FS, and MP. The records showed that AMS was employed during
that entire period as a legislative analyst. DSS earned
retirement benefits from the El Monte School District. MDS
worked briefly in 2020, though never as a childcare worker. The
only remaining victims were FS and MP, who in 2018 earned $162
and $97, respectively, though not for the professions listed on
the fraudulent applications filed with their identities.
13For example, the MDS application falsely represented to
EDD that MDS was a childcare worker, and the ARC application
falsely stated that ARC was a bricklayer.
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k. ATM Photograph Analysis
92. As described above, I obtained more than 1,000 ATM
photographs from Bank of America and Wells Fargo showing
PLUMMER, K. KING, C. JOHNSON, J. JOHNSON, F. KING, MITCHELL,
DAVIS, P. JOHNSON, PACE, ROBERTSON, and WADE conducting
fraudulent transactions with fraudulent EDD debit cards.
93. To determine the specific defendants depicted in the
ATM photographs, I used known photographs of the defendants
(including Department of Motor Vehicle (“DMV”) and booking
photographs) and the defendants’ unique physical
characteristics.
94. With respect to the ATM photographs, I summarize
certain findings as follows.
95. PLUMMER was recorded on ATM surveillance footage
conducting dozens of fraudulent EDD transactions using cards
issued to victims, DEMOLA, and herself. In terms of unique
characteristics, PLUMMER has a bird tattoo on her chest. For two
examples, the following photographs show PLUMMER on August 24,
2020 using the NMS card (left) and on October 13, 2020 (right)
using the TRS card to make fraudulent EDD withdrawals.
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96. Wells Fargo ATM surveillance cameras recorded K. KING
using cards issued to several victims, including PGW, JJW, and
L.Si. K. KING has a cross tattoo on her forehead between her
eyes, making her easily identifiable. For example, a booking
photograph of K. KING (left) and an ATM photograph of K. KING
using the PGW card on September 5, 2020 (right) appear as
follows:
97. C. JOHNSON was recorded on ATM surveillance footage
conducting fraudulent transactions using a number of EDD cards,
including those issued to MP and ARC. C. JOHNSON has an “all-
star” tattoo on his right shoulder, along with several
identifiable tattoos on his neck, arms and chest. The following
images are a DMV photograph of C. JOHNSON (left), and ATM
photographs that depict C. JOHNSON using the MP card on
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September 1, 2020 (center) and the ARC card on September 27,
2020 (right).
98. J. JOHNSON was recorded on ATM surveillance footage
conducting fraudulent transactions using a number of EDD cards,
including those issued to DF and MDS. J. JOHNSON has unique
tattoos on his face above both eyes, a symbol tattoo between his
eyebrows, and tattoos on his neck and chest. The following
images are a known booking photograph of J. JOHNSON (left), and
ATM photographs that depict J. JOHNSON using the MDS card on
July 9, 2020 (center) and the DRF card on July 25, 2020 (right).
99. F. KING was recorded on ATM surveillance conducting
fraudulent transactions using EDD cards issued to numerous
victims (including DSS, RJ, D.Fo., and TAW), along with the card
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issued to K. KING. Moreover, F. KING has a unique tattoo above
her right eye, a red heart tattoo on her chest, lettered tattoos
(including the word “love”) on her chest, and lettered tattoos
on her arms. The following images are a DMV photograph of F.
KING (left), and ATM photographs that depict F. KING using the
DSS card on September 9, 2020 (center) and the RJ card on
September 23, 2020 (right).
100. MITCHELL was recorded on ATM surveillance footage
conducting dozens of fraudulent EDD transactions using cards
issued to victims, along with a card issued to PLUMMER. MITCHELL
has star tattoos on her right chest, lettered tattoos on both
forearms, and a tattoo on her left shoulder. The following
images are a DMV photograph of MITCHELL (left), and ATM
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photographs that depict MITCHELL using the MDJ card on June 27,
2020 (center) and the SMR card on July 8, 2020 (right).
101. DAVIS was recorded on ATM surveillance footage
conducting fraudulent transactions with the cards issued to
numerous victims, including DMB, MP, AMP, TRS, ITC, and TKJ.
DAVIS haw a crown tattoo on his right arm and unique tattoos on
his chest. The following images are a known booking photograph
of DAVIS (left), and ATM photographs that depict DAVIS using the
TRS card on August 2, 2020 (center) and the DMB card on August
6, 2020 (right).
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102. P. JOHNSON, among other things, was recorded on ATM
surveillance footage using the SM card several times in August
2020. P. JOHNSON has a piercing below her bottom lip and above
her left eye, along with unique tattoos on her chest and right
arm. The following imagines are a booking photograph of P.
JOHNSON (left), and ATM photographs that show P. JOHNSON using
the SM card on August 13, 2020 (center and right).
103. Moreover, P. JOHNSON drove a vehicle bearing license
plate 8DLN623 when conducting fraudulent EDD activity. Records
show that this vehicle was registered to P. JOHNSON.
104. PACE, among other things, was recorded on ATM
surveillance footage using the MDJ card on several occasions
between August and October 2020. PACE has lettered tattoos on
her right arm. The following images are a DMV photograph of PACE
(left), and ATM photographs that depict PACE using the MDJ card
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on August 23, 2020 (center) and the MDJ card on October 12, 2020
(right).
105. ROBERTSON was recorded on ATM surveillance footage
conducting fraudulent transactions with cards issued to several
victims (including JB, DDJ, KS, MLL, REAT, DPR, and AAM), along
with the card issued to DEMOLA. Notably, on August 7, 2020,
ROBERTSON was recorded on ATM surveillance fraudulently using
nine separate EDD cards on in a single day. ROBERTSON has a
unique crown tattoo on the middle of her chest. The following
images are a known booking photograph of ROBERTSON (left), and
ATM photographs that depict ROBERTSON using the REAT card on
August 7, 2020 (center) and the DPB card on August 13, 2020.
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106. WADE was recorded on ATM surveillance conducting
numerous fraudulent EDD transactions. WADE has unique tattoos on
her back. The following are WADE’s DMV photograph and ATM
photographs of WADE using the NTS card to fraudulent withdraw
EDD funds from the NTS cards in 11 separate transactions between
August 31, 2020 and September 26, 2020. With one exception, WADE
withdrew $1,000 in all of the foregoing transactions. As
described above, NTS told investigators that he did not know
WADE.
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107. In total, the defendants and their coconspirators
opened hundreds of fraudulent EDD accounts and cost the EDD
program millions of dollars.
GROUNDS FOR SEALING
108. Reasonable cause exists to seal the applications,
warrants, and warrant returns associated with this affidavit, as
well as to seal this affidavit itself. This investigation is
ongoing, and to this point, has remained covert. There is reason
to believe that failing to seal will result in (1) endangering
the life or physical safety of an individual, (2) flight from
prosecution, (3) destruction or alteration of evidence, (4)
intimidation of potential witnesses, (5) otherwise seriously
jeopardizing the investigation, or (6) unduly delaying
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CONCLUSION
109. For the foregoing reasons, there is probable cause to
issue the requested complaints and arrest warrants.
Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1 by
27th day of
telephone on this _____
April
__________, 2022.
THE HONORABLE Gail J. Standish
UNITED STATES MAGISTRATE JUDGE
47
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