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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.

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 — 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/, SHA-256 85dbfd221105ec19d63a89c9f45416825a3b8bf7e7a9f6044f4fc55213c16d17.

Full text

          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



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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




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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,

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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


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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


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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.

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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 11 of 49 Page ID #:11



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.
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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

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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


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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:


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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.

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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.




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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.


                                    17
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 20 of 49 Page ID #:20



     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.

                                    18
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 21 of 49 Page ID #:21



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
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 22 of 49 Page ID #:22



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.

                                    20
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 23 of 49 Page ID #:23



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.
                                    21
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 24 of 49 Page ID #:24



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.
                                    22
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 25 of 49 Page ID #:25



     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]

                                    23
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 26 of 49 Page ID #:26




     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.


                                    24
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 27 of 49 Page ID #:27



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.

                                    25
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 28 of 49 Page ID #:28



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

                                    26
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 29 of 49 Page ID #:29



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

                                    27
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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

                                    28
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 31 of 49 Page ID #:31



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



                                    29
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 32 of 49 Page ID #:32



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


                                    30
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 33 of 49 Page ID #:33



     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,


                                    31
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 34 of 49 Page ID #:34



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.



                                    32
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 35 of 49 Page ID #:35



     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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 36 of 49 Page ID #:36



(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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 37 of 49 Page ID #:37



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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 38 of 49 Page ID #:38



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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 39 of 49 Page ID #:39



     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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 40 of 49 Page ID #:40



     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.




                                    38
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 41 of 49 Page ID #:41



     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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 42 of 49 Page ID #:42



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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 43 of 49 Page ID #:43



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




                                    41
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 44 of 49 Page ID #:44



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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 45 of 49 Page ID #:45



     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




                                    43
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 46 of 49 Page ID #:46



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.




                                    44
Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 47 of 49 Page ID #:47



        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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 48 of 49 Page ID #:48




     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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Case 2:22-cr-00205-JFW Document 1 Filed 04/27/22 Page 49 of 49 Page ID #:49



                               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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