Indictment — United States v. Kristerpher Turner et al. (Central District of California, Document 1)
Summary
This is an indictment in the Central District of California, CR No. 2:25-CR-00462-CVD, United States of America against Kristerpher Turner, Toriano Knox, Kenya Jones and Joyce Johnson, marked UNDER SEAL and dated 6/11/2025. The cover lists conspiracy to commit mail fraud, mail fraud, conspiracy to submit false, fictitious or fraudulent claims, attempt to kill a witness, a firearm charge under 18 U.S.C. § 924(c)(1)(A) and criminal forfeiture. Count One, against all defendants, alleges a conspiracy from no later than in or around June 2022 until at least in or around December 2024 to commit mail fraud. It describes use of TaxBandits to submit Forms 941 and 944 seeking Coronavirus Response Credits for businesses that paid no sick and family wage credits.
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“Indictment — United States v. Kristerpher Turner et al. (Central District of California, Document 1).”
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Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 1 of 34 Page ID #:1
1
2 6/11/2025
3
4
5
6 UNDER SEAL
7
8 UNITED STATES DISTRICT COURT
9 FOR THE CENTRAL DISTRICT OF CALIFORNIA
10 March 2025 Grand Jury
11 UNITED STATES OF AMERICA, CR No. 2:25-CR-00462-CVD
12 Plaintiff, I N D I C T M E N T
13 v. [18 U.S.C. § 1349: Conspiracy to
Commit Mail Fraud; 18 U.S.C.
14 KRISTERPHER TURNER, § 1341: Mail Fraud; 18 U.S.C.
aka Kris Turner, § 286: Conspiracy To Submit False,
15 aka Red, Fictious, or Fraudulent Claims; 18
aka Red Boy, U.S.C. § 1512(a)(1)(C): Attempt to
16 aka Bullet, Kill a Witness; 18 U.S.C.
TORIANO KNOX, § 924(c)(1)(A)(ii), (iii):
17 aka Scooby, Possess, Use, Carry, Brandish, and
aka Dwight, Discharge a Firearm in Furtherance
18 KENYA JONES, of, and During and in Relation to,
aka Kenya Emua Jones, a Crime of Violence; 18 U.S.C.
19 aka Kenya Hunt, § 981(a)(1)(C), 18 U.S.C.
JOYCE JOHNSON, § 924(d)(1) and 28 U.S.C.
20 aka Ms. Jay, § 2461(c): Criminal Forfeiture]
21 Defendants.
22
23 The Grand Jury charges:
24 COUNT ONE
25 [18 U.S.C. § 1349]
26 [ALL DEFENDANTS]
27 A. INTRODUCTORY ALLEGATIONS
28 At times relevant to this Indictment:
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 2 of 34 Page ID #:2
1 THE DEFENDANTS
2 1. Defendant KRISTERPHER TURNER, also known as (aka) Kris
3 Turner, Red, Red Boy, and Bullet, was a resident of Harbor
4 City, California. Defendant TURNER was the owner, sole proprietor,
5 manager, or de facto owner of multiple companies, which he maintained
6 for the purpose of committing fraud against the United States,
7 including Mark Sandridge Auto Body, LLC; Turner Auto Shop LLC; Kris
8 Turner Enterprise LLC; and Doan Transportation LLC. Defendant TURNER
9 also maintained or had control over bank accounts established for
10 each of these companies. For tax years 2020 through 2022, none of
11 the companies had substantial business operations, nor did they have
12 any employees other than defendant TURNER or his wife. In fact, none
13 of the four companies filed incorporation paperwork with the
14 California Secretary of State until October 2022, at the earliest.
15 2. Defendant TORIANO KNOX, aka Scooby and Dwight, was a
16 resident of Los Angeles, California. Defendant KNOX was the owner,
17 sole proprietor, and manager of Knox Lawn Service LLC. Defendant
18 KNOX maintained and controlled bank accounts established for Knox
19 Lawn Service. For tax years 2020 through 2022, the company did not
20 have substantial business operations, nor did it have employees other
21 than defendant KNOX. In fact, Knox Lawn Service did not file
22 incorporation paperwork with the California Secretary of State until
23 November 2022.
24 3. Defendant KENYA JONES, aka Kenya Emua Jones and Kenya
25 Hunt, was a resident of Compton, California. Defendant JONES was
26 the owner, sole proprietor, manager, or de facto owner of multiple
27 companies, including K.M.J. Innovation LLC (also known as KMJ
28 Innovation), KMJ Freight LLC, and Famtastic Katering LLC. Defendant
2
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 3 of 34 Page ID #:3
1 JONES also maintained or had control over bank accounts established
2 for each of these companies. For tax years 2020 through 2022, none
3 of the companies had substantial business operations or employees
4 other than defendant JONES or her husband.
5 4. Defendant JOYCE JOHNSON, aka Ms. Jay, was a resident of
6 Victorville, California. Defendant JOHNSON was the owner, sole
7 proprietor, and manager of a company named Jays Mobile Cleaning
8 Service LLC. Defendant JOHNSON maintained and controlled bank
9 accounts established for Jays Mobile Cleaning Service. For tax
10 years 2020 through 2022, the company did not have substantial
11 business operations or employees other than defendant JOHNSON. In
12 fact, no incorporation paperwork for Jays Mobile Cleaning Service
13 was filed with the California Secretary of State until December 2022.
14 THE CORONAVIRUS RESPONSE CREDITS
15 5. The Internal Revenue Service (IRS) was an agency of the
16 United States responsible for collecting taxes and administering the
17 Internal Revenue Code.
18 6. To help alleviate the impact of COVID-19, the Family First
19 Coronavirus Response Act (Coronavirus Response Act) authorized tax
20 credits that would reimburse businesses for the wages paid to
21 employees who could not work because of the pandemic. Specifically,
22 the Coronavirus Response Act and its amendments authorized the IRS to
23 give a credit against employment taxes to reimburse businesses for
24 the wages paid to employees who were on sick or family leave and
25 could not work because of COVID-19, also known as the paid sick and
26 family leave credit (the Coronavirus Response Credit). The credit
27 equaled the wages the business paid to employees during the eligible
28 period of sick or family leave, subject to a maximum amount.
3
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 4 of 34 Page ID #:4
1 7. A taxpayer could, on behalf of her business, request the
2 Coronavirus Response credit on an IRS Form 941 (Form 941), also
3 known as the Employers Quarterly Federal Tax Return. The Form 941
4 required the taxpayer to truthfully state, among other things, the
5 number of employees, the businesss quarterly wages, and the
6 Coronavirus Response Credit wage amount claimed for the quarter
7 reported. The self-reported Coronavirus Response Credit would be
8 used, in conjunction with other information from the taxpayer, to
9 calculate the refund, or overpayment, that the taxpayer was
10 requesting from the IRS. Using IRS Form 941, the taxpayer could
11 either request that the IRS carry over any refunds to the next
12 quarter or pay the refunds to the taxpayer which the IRS would issue
13 in the form of United States Treasury Checks.
14 8. Similarly, a taxpayer could also request the Coronavirus
15 Response credit on an IRS Form 944 (Form 944), also known as the
16 Employers Annual Federal Tax Return. The Form 944 required the
17 taxpayer to truthfully state, among other things, the refundable
18 portion of the Coronavirus Response Credit for the tax year claimed
19 by the business. Like refunds or overpayments requested on Form
20 941s, the IRS would issue refunds requested on Form 944s in the form
21 of United States Treasury Checks.
22 9. To submit either a Form 941 or a Form 944, a taxpayer was
23 required to obtain from the IRS an Employment Identification Number,
24 or EIN, for the business, and to have included the EIN on each
25 filing.
26 10. Forms 941 and 944 had to be submitted online, including
27 through commercially available tax preparation services, like
28 TaxBandits, which could be used to file corporate tax returns online.
4
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 5 of 34 Page ID #:5
1 11. After it accepted a Form 941 or Form 944, and the IRS
2 determined that a tax refund was owed, the IRS would cause the United
3 States Department of the Treasury to issue a Treasury Check addressed
4 to the business containing the amount of the refund. The Treasury
5 Check would be mailed via the United States mail from one of two
6 locations, including Ogden, Utah, to the mailing address that the
7 business owner provided on the EIN for the business.
8 B. THE OBJECT OF THE CONSPIRACY
9 12. Beginning no later than in or around June 2022 and
10 continuing until at least in or around December 2024, in Los Angeles
11 County, within the Central District of California, and elsewhere,
12 defendants TURNER, KNOX, JONES, and JOHNSON conspired with one
13 another and with others known and unknown to the Grand Jury to commit
14 mail fraud, in violation of Title 18, United States Code, Section
15 1341.
16 C. THE MANNER AND MEANS OF THE CONSPIRACY
17 13. The object of the conspiracy was to be carried out, and was
18 carried out, in substance, as follows:
19 a. Defendant TURNER would coordinate a tax fraud scheme
20 whereby he and his co-conspirators would use TaxBandits to submit
21 fraudulent Forms 941 and 944 to the IRS to request tax refunds and
22 Coronavirus Response Credits for businesses, including bogus
23 companies, that did not, in fact, pay any sick and family wage
24 credits to any employees at any time. Defendant TURNER and his co-
25 conspirators would submit these fraudulent filings on behalf of their
26 own purported businesses, but also on behalf of others recruited to
27 the scheme (the fraud clients).
28
5
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 6 of 34 Page ID #:6
1 b. Defendant TURNER would direct and manage recruiters,
2 including defendant KNOX, defendant JONES, and Co-Conspirator 1, to
3 recruit these fraud clients. In particular, defendant KNOX would
4 recruit various romantic partners, including defendant JONES,
5 defendant JOHNSON, and others, including another romantic partner,
6 (KNOX Recruit 1,), and that romantic partners friend (KNOX
7 Recruit 2), to the fraud. Additionally, defendant JONES, after being
8 recruited by defendant KNOX, would recruit her friends and family to
9 the fraud (the JONES Recruits), resulting in false Form 941s being
10 submitted in the names of at least ten businesses.
11 c. Recruiters like defendants KNOX and JONES would
12 solicit fraud clients to join the scheme. Most fraud clients would
13 provide their personal identifying information, including their
14 names, dates of birth, social security numbers, and addresses, so
15 that the co-conspirators, including defendant TURNER, could use that
16 information to establish fake businesses and file fraudulent tax
17 filings on behalf of those businesses. Other fraud clients would
18 provide information about preexisting businesses that were ineligible
19 to receive Coronavirus Response Credits so that the co-conspirators,
20 including defendant TURNER, could use that information to file
21 fraudulent tax filings on behalf of those businesses.
22 d. Defendant TURNER and his co-conspirators would create
23 the appearance of legitimacy for their own and their fraud clients
24 fake businesses by applying to the IRS for EINs and to the California
25 Secretary of State for incorporation paperwork for the businesses.
26 e. Defendant TURNER would charge a processing fee of
27 approximately $1,050 to establish EINs and file incorporation
28 paperwork for shell companies with the California Secretary of State
6
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 7 of 34 Page ID #:7
1 in order to create a paper record for fake businesses used in the
2 conspiracy. In some instances, recruiters, like defendants JONES and
3 KNOX, would facilitate the transfer of the processing fee from their
4 fraud clients to defendant TURNER.
5 f. To ensure that they and/or their fraud clients would
6 receive the Treasury Checks that would be issued in the names of the
7 fake or unqualified businesses, for each business, defendants TURNER,
8 KNOX, JONES, and JOHNSON would use or cause to be used mailing
9 addresses to which they or their fraud clients had access.
10 Defendants TURNER, KNOX, JONES, and JOHNSON knew that, by doing so,
11 they would cause the IRS, through the Department of the Treasury, to
12 mail any Treasury Checks to the businesses at those mailing
13 addresses, thereby enabling them or their fraud clients to take
14 possession of the Treasury Checks so mailed.
15 g. Fraud participants, like defendants TURNER, JONES, and
16 JOHNSON and the JONES Recruits, would receive Treasury Checks in the
17 mail as a result of the conspiracys fraudulent tax filings and would
18 attempt to deposit those Treasury Checks in business accounts opened
19 in the name of the fake businesses at various banks.
20 h. For each fraud client that obtained Treasury Checks
21 through this conspiracy, defendant TURNER would charge a percentage
22 of the fraud proceeds that amounted to somewhere between 20% to 40%
23 of funds received.
24 i. Defendant TURNER would direct fraud clients and his
25 recruiters to pay a portion of the fraud proceeds to defendant TURNER
26 personally or to entities controlled by him, or his co-conspirators,
27 as kickbacks, including through cashiers checks, CashApp, Zelle, or
28 cash.
7
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1 j. In addition to defendant TURNERs portion, the
2 recruiter who brought the fraud client to defendant TURNER would
3 often receive a portion of the fraud proceeds paid out to the fraud
4 client.
5 k. Because the fake businesses were entirely fabricated,
6 and the genuine businesses were ineligible to receive the Coronavirus
7 Response Credits claimed on their fraudulent tax filings, fraud
8 clients would not be familiar with the details of the businesses they
9 purportedly owned and controlled and would frequently contact
10 defendant TURNER for information about those businesses in order to
11 supply that information to the IRS or banks who requested details
12 about the businesses.
13 l. Defendant TURNER would maintain records to document
14 the fraudulent filings he facilitated for each fraud client,
15 including the EIN, the date of incorporation, the purported business
16 address, and the claimed Coronavirus Response Credit for each quarter
17 for which Form 941s were filed, and would sometimes send such
18 documentation to fraud clients who needed such business details to
19 respond to bank or IRS inquiries.
20 14. In total, between in or around June 2020 and in or around
21 December 2024, defendants TURNER, KNOX, JONES, and JOHNSON, together
22 with their co-conspirators, submitted and caused the submission of
23 fraudulent Forms 941 and 944 for at least 148 companies, seeking a
24 total of approximately $247,956,938 in tax refunds to which they were
25 not entitled. In reliance on the fraudulent Forms 941 and 944, and
26 the false statements therein, the IRS issued Treasury Checks in the
27 total amount of at least approximately $93,036,164.
28
8
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 9 of 34 Page ID #:9
1 a. In particular, the fraudulent Forms 941 and 944 for
2 the four companies that defendant TURNER owned or controlled sought a
3 total of approximately $7,784,685 in tax refunds. In reliance on
4 those fraudulent Forms 941 and 944, and the false statements therein,
5 the IRS issued Treasury Checks in the total amount of $3,288,332.48.
6 b. The fraudulent Form 941s for the company that
7 defendant KNOX owned or controlled sought a total of $962,438.53 in
8 tax refunds.
9 c. The fraudulent Form 941s for the companies that
10 defendant JONES owned or controlled sought a total of $5,064,284.49
11 in tax refunds. In reliance on those fraudulent Form 941s, the IRS
12 issued Treasury Checks in the total amount of $1,655,939.23.
13 d. The fraudulent Form 941s for the company that
14 defendant JOHNSON owned or controlled sought a total of $883,810.84
15 in tax refunds. In reliance on those fraudulent Form 941s, the IRS
16 issued Treasury Checks in the total amount of $883,810.84.
17 D. OVERT ACTS
18 15. In furtherance of the conspiracy and to accomplish its
19 object, defendants TURNER, KNOX, JONES, and JOHNSON, together with
20 others known and unknown to the Grand Jury, on or about the dates set
21 forth below, committed and caused to be committed the following overt
22 acts, among others, in the Central District of California, and
23 elsewhere:
24 Defendant TURNER Filed Fraudulent Tax Returns for His Fake Businesses
25 Overt Act No. 1: On October 15, 2022, defendant TURNER,
26 together with other co-conspirators, caused to be submitted to the
27 IRS, via TaxBandits, one of five false Form 941s for defendant
28 TURNERs company, Mark Sandridge Auto Body, for Q1 2021 through Q1
9
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 10 of 34 Page ID #:10
1 2022, which falsely represented that, for Q1 2021, the business was
2 owed a tax refund of $407,017.01 due to Coronavirus Response Credits
3 for sick and family leave wages purportedly paid out to employees
4 during that quarter.
5 Overt Act No. 2: On October 28, 2022, defendant TURNER,
6 together with other co-conspirators, caused to be submitted to the
7 IRS, via TaxBandits, one of seven false Form 941s for defendant
8 TURNERs company, Kris Turner Enterprise, for Q2 2020 through Q4
9 2021, which falsely represented that, for Q4 2021, the business was
10 owed a tax refund of $68,729.67 due to Coronavirus Response Credits
11 for sick and family leave wages purportedly paid out to employees
12 during that quarter.
13 Overt Act No. 3: On January 12, 2023, after having received
14 notice from the IRS that his Form 941s for Mark Sandridge Auto Body
15 for the four quarters in 2021 were flagged for further inquiry,
16 defendant TURNER, together with other co-conspirators, caused to be
17 submitted to the IRS, via TaxBandits, a false Form 944 for Mark
18 Sandridge Auto Body that falsely represented that, for tax year 2021,
19 the business was owed a federal tax refund of $595,547.29 due to
20 Coronavirus Response Credits for sick and family leave wages
21 purportedly paid out to employees for that tax year.
22 Overt Act No. 4: On February 14, 2023, as a result of the
23 Form 944 described in Overt Act No. 3, defendant TURNER, together
24 with other co-conspirators, fraudulently caused a Treasury Check
25 addressed to Mark Sandridge Auto Body in the amount of $528,254.29 to
26 be placed in the U.S. Mail and mailed to an address in Los Angeles
27 County accessible to or controlled by defendant TURNER.
28
10
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 11 of 34 Page ID #:11
1 Overt Act No. 5: On February 16, 2023, defendant TURNER,
2 together with other co-conspirators, caused to be submitted to the
3 IRS, via TaxBandits, one of seven false Form 941s for defendants
4 company, Doan Transportation, for Q2 2020 through Q4 2021, which
5 falsely represented that, for Q2 2020, the business was owed a
6 federal tax refund of $297,015.97 due to Coronavirus Response Credits
7 for sick and family leave wages purportedly paid out to employees
8 during that quarter.
9 Overt Act No. 6: On February 18 and 19, 2023, defendant
10 TURNER, together with other co-conspirators, caused to be submitted
11 to the IRS, via TaxBandits, one of nine false Form 941s for his
12 company, Turner Auto Shop, for Q2 2020 through Q2 2021, which falsely
13 represented that, for Q4 2020, the business was owed a federal tax
14 refund of $293,972.89 due to Coronavirus Response Credits for sick
15 and family leave wages purportedly paid out to employees during that
16 quarter.
17 Overt Act No. 7: On March 21, 2023, as a result of the Form
18 941 described in Overt Act No. 6, defendant TURNER, together with
19 other co-conspirators, fraudulently caused a Treasury Check addressed
20 to Turner Auto Shop, totaling $283,775.42, to be placed in the U.S.
21 Mail and mailed to an address in Los Angeles County accessible to or
22 controlled by defendant TURNER.
23 Defendant TURNER Conspires With Others to Recruit Fraud Clients to
24 File False Claims and Get Kickbacks
25 Overt Act No. 8: On October 3, 2022, defendant TURNER sent a
26 recruitment text message that explained to potential fraud clients
27 that his scheme involved form 941s, required the fraud clients to
28 have a sole membership, and to pay a non refundable app fee
11
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 12 of 34 Page ID #:12
1 upfront, and cautioned that the fraud clients shouldnt ask me a
2 ton of questions either bc this money is FREE MONEY.
3 Overt Act No. 9: On May 18, 2023, defendant TURNER texted a
4 fraud client (Fraud Client 1) his fee structure for the fraud:
5 specifically, (1) that that if the fraud client already had a
6 business with an EIN, then the application fee was $800, (2) that if
7 the fraud client did not have a business, defendant would charge
8 $1,050 and require the fraud client to provide her name, address,
9 phone number, and social security number, and (3) in either event,
10 that defendant TURNERs kickback would be 40% of any refunds
11 obtained.
12 Overt Act No. 10: On May 26, 2023, in response to text
13 messages from a fraud client (Fraud Client 2) requesting
14 information to relay to the bank about her fake business, including
15 the number of employees; annual gross sales; and reported date,
16 month, and year, defendant TURNER supplied the information that he
17 helped fabricate for that business, responding: 15 employees in 2019
18 and now you have 5 employees, 300k in annual sales, and a reported
19 date of January 2023.
20 Overt Act No. 11: On July 4, 2023, in response from a text
21 message from another fraud client (Fraud Client 3) advising that
22 Fraud Client 3 had received fraud proceeds and inquiring, Whats the
23 company name I should have the cashier check made out too? [sic]
24 defendant TURNER responded, Mark SandRidge Auto Body . . . $21590.00
25 . . . Cash $5,000.
26 Overt Act No. 12: On July 18, 2023, in response to text
27 messages from a fraud client (Fraud Client 4) asking defendant
28 TURNER to Remind me the address for Turner autoshop . . . I will
12
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 13 of 34 Page ID #:13
1 send $25k a day to get payments caught up, defendant TURNER
2 responded: Just send 25k a week and Ill grab 5k in cash from you a
3 week. Dont want them to see you pay me every day and Ill get 2
4 more accounts for you.
5 Defendant KNOX Joins Scheme and Files False Claims for Knox Lawn
6 Service
7 Overt Act No. 13: On or about October 25, 2022, defendants
8 TURNER and KNOX, together with other co-conspirators, caused to be
9 submitted to the IRS, via TaxBandits, one of nine false Form 941s for
10 defendant KNOXs company, Knox Lawn Service, for Q2 2020 through Q2
11 2022, which falsely represented that, for Q2 2020, the business was
12 owed a tax refund of $172,162.60 due to Coronavirus Response Credits
13 for sick and family leave wages purportedly paid out to employees
14 during that quarter.
15 Overt Act No. 14: On December 2, 2022, defendants TURNER and
16 KNOX, together with other co-conspirators, caused to be filed with
17 the California Secretary of State a Statement of Information on
18 behalf of Knox Lawn Service, which listed defendant KNOX as its CEO.
19 Overt Act No. 15: On December 2, 2022, defendant KNOX paid
20 defendant TURNER $350 for facilitating defendant KNOXs fraudulent
21 tax filings.
22 Defendant KNOX Becomes a Recruiter for Defendant TURNER and Recruits
23 Defendant JOHNSON
24 Overt Act No. 16: On or about January 18, 2023, defendants
25 TURNER, KNOX, and JOHNSON, together with other co-conspirators,
26 caused to be submitted to the IRS, via TaxBandits, one of nine false
27 Form 941s for defendant JOHNSONs company, Jays Mobile Cleaning
28 Service, for Q2 2020 through Q2 2022, which falsely represented that,
13
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1 for Q4 2020, the company was owed a tax refund of $272,246.65 due to
2 Coronavirus Response credits for sick and family leave wages that the
3 company purportedly paid out to employees during that quarter.
4 Overt Act No. 17: On January 19, 2023, defendant JOHNSON
5 transferred $300 to defendant TURNER for facilitating defendant
6 JOHNSONs fraudulent tax filings.
7 Overt Act No. 18: On February 28, 2023, as a result of the
8 Form 941 described in Overt Act No. 16, defendants TURNER, KNOX, and
9 JOHNSON, together with other co-conspirators, fraudulently caused a
10 Treasury Check addressed to Jays Mobile Cleaning Service for
11 $253,358.97, to be placed in the U.S. Mail and mailed to an address
12 in Los Angeles County that defendant JOHNSON had access to or
13 controlled.
14 Overt Act No. 19: On or about April 8, 2023, defendant JOHNSON
15 deposited fraudulent proceeds described in Overt Act No. 18, into a
16 bank account she established for Jays Mobile Cleaning Services.
17 Overt Act No. 20: Between January 19, 2023 and May 9, 2023,
18 defendant JOHNSON distributed or caused to be distributed
19 approximately $262,158.75 to defendant TURNER and $69,931 to
20 defendant KNOX as their respective cuts of the proceeds.
21 Overt Act No. 21: On May 24, 2023, defendant JOHNSON sent text
22 messages to defendant TURNER requesting he provide her paperwork for
23 Jays Mobile Cleaning Services and asking him to call her back
24 because the bank had questioned the validity of defendant JOHNSONs
25 business and put a hold on her account, preventing her from making
26 any withdrawals of her fraudulent proceeds.
27
28
14
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1 Overt Act No. 22: On May 24, 2023, when defendant TURNER did
2 not pick up defendant JOHNSONs call, defendant KNOX texted defendant
3 TURNER that he should Hit jay.
4 Defendant KNOX Recruits KNOX Recruit 1
5 Overt Act No. 23: On April 17, 2023, defendant KNOX
6 transferred defendant TURNER the $1,050 processing fee to set up a
7 fake company in the name of KNOX Recruit 1.
8 Overt Act No. 24: On or aboutApril 25, 2023, defendants
9 TURNER, KNOX, and KNOX Recruit 1, together with other co-
10 conspirators, caused to be submitted to the IRS, via TaxBandits, one
11 of nine false Form 941s for KNOX Recruit 1s company for Q2 2020
12 through Q2 2022, which falsely represented that, for Q3 2020, the
13 business was owed a tax refund of $283,001.12 due to Coronavirus
14 Response Credits for sick and family leave wages paid out to
15 employees during that quarter.
16 Overt Act No. 25: On April 27, 2023, defendant TURNER used
17 his credit card to pay the California Secretary of State to file a
18 Statement of Information for KNOX Recruit 1s fake company.
19 Overt Act No. 26: On May 22, 2023, KNOX Recruit 1 calculated a
20 40% kickback fee based on her anticipated refund amounts from the IRS
21 for her fraudulent business, which she discussed over a phone call
22 with defendant KNOX.
23 Overt Act No. 27: On May 22, 2023, after speaking with KNOX
24 Recruit 1, defendant KNOX texted defendant TURNER that [KNOX Recruit
25 1] got amounts in the mail should be soon.
26
27
28
15
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 16 of 34 Page ID #:16
1 Defendant KNOX Recruits KNOX Recruit 2
2 Overt Act No. 28: On May 2, 2023, KNOX Recruit 1 texted
3 defendant KNOX the name, Social Security Number, date of birth, and
4 business name used by KNOX Recruit 2.
5 Overt Act No. 29: On May 2, 2023, in response to the text
6 message described in Overt Act No. 28, after defendant KNOX texted
7 KNOX Recruit 1 Do she know percentage referring to the kickbacks
8 that KNOX Recruit 2 would owe, KNOX Recruit 1 responded, Yup . . .
9 She does have tax questions eventually.
10 Overt Act No. 30: On or about May 17, 2023, defendants TURNER,
11 KNOX, and KNOX Recruit 2, together with other co-conspirators, caused
12 to be submitted to the IRS, via TaxBandits, one of eight false Form
13 941s for KNOX Recruit 2s company for Q2 2020 through Q1 2022, which
14 falsely represented that, for Q2 2020, the business was owed a tax
15 refund of $299,228.05 due to Coronavirus Response Credits for sick
16 and family leave wages purportedly paid out to employees during that
17 quarter.
18 Overt Act No. 31: On May 20, 2023, one day after defendant
19 TURNER texted defendant KNOX that he needed to pick up paper work
20 for KNOX Recruit 2s company, defendant KNOX asked to meet with
21 defendant TURNER at a commercial complex in Gardena, California,
22 where defendant JONES leased a unit.
23 Overt Act No. 32: On August 3, 2023, KNOX Recruit 2 texted
24 defendant TURNER, here are the docs I received, and sent defendant
25 TURNER photos of IRS letters addressed to KNOX Recruit 2s business.
26 Defendant KNOX Recruits Defendant JONES to the Scheme, Who Uses Three
27 Unqualified Businesses To File False Tax Returns
28
16
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 17 of 34 Page ID #:17
1 Overt Act No. 33: On October 24, 2022, defendants TURNER,
2 JONES, and KNOX, together with other co-conspirators, caused to be
3 submitted to the IRS, via TaxBandits, one of eight false Form 941s
4 for defendant JONESs company, KMJ Freight, for Q2 2020 through Q1
5 2022, which falsely represented that, for Q2 2020, the business was
6 owed a tax refund of $353,670, due to Coronavirus Response Credits
7 for sick and family leave wages purportedly paid out to employees
8 during that quarter.
9 Overt Act No. 34: On October 26, 2022, defendants TURNER,
10 JONES, and KNOX, together with other co-conspirators, caused to be
11 submitted to the IRS, via TaxBandits, one of nine false Form 941s for
12 defendant JONESs company, Famtastic Katering, for Q2 2020 through Q2
13 2022, which falsely represented that, for Q2 2020, the business was
14 owed a tax refund of $214,597, due to Coronavirus Response Credits
15 for sick and family leave wages purportedly paid out to employees
16 during that quarter.
17 Overt Act No. 35: On February 14, 2023, defendants TURNER,
18 JONES, and KNOX, together with other co-conspirators, caused to be
19 submitted to the IRS, via TaxBandits, one of eight false Form 941s
20 for defendant JONESs company, KMJ Innovation, for Q2 2020 through Q1
21 2022, which falsely represented that for Q3 2020, the business was
22 owed a tax refund of $305,041.66, due to Coronavirus Response Credits
23 for sick and family leave wages that the company purportedly paid out
24 to employees during that quarter.
25 Overt Act No. 36: On March 28, 2023, as a result of the Form
26 941s described in Overt Act No. 35, defendants TURNER, KNOX, and
27 JONES, together with other co-conspirators, fraudulently caused a
28 Treasury Check addressed to KMJ Innovation, totaling $294,460.23 to
17
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 18 of 34 Page ID #:18
1 be placed in the U.S. Mail and mailed to an address in Los Angeles
2 County that defendant JONES had access to or controlled.
3 Overt Act No. 37: On April 8, 2023, defendant JONES paid a
4 portion of the fraudulent refunds received from the IRS to defendant
5 TURNER by causing the issuance of a cashiers check for $94,000 for
6 the benefit of defendant TURNER.
7 Overt Act No. 38: On April 8, 2023, defendant JONES paid a
8 portion of the fraudulent refunds received from the IRS to defendant
9 KNOX by causing the issuance of a cashiers check in defendant KNOXs
10 name for $63,000.
11 Overt Act No. 39: On April 24, 2023, defendant JONES paid a
12 portion of the fraudulent refunds received from the IRS to defendant
13 TURNER by causing the issuance of a cashiers check for $62,000 for
14 the benefit of defendant TURNER.
15 Overt Act No. 40: On April 24, 2023, defendant JONES paid a
16 portion of the fraudulent refunds received from the IRS to defendant
17 KNOX by causing the issuance of a cashiers check for $31,000 to Knox
18 Lawn Service.
19 Overt Act No. 41: On April 24, 2023, defendant JONES paid a
20 portion of the fraudulent refunds received from the IRS to defendant
21 KNOX by causing the issuance of a cashiers check for $31,000 to
22 defendant KNOX.
23 Overt Act No. 42: On January 24, 2024, defendant JONES used
24 TaxBandits to access tax filing records for KMJ Freight.
25 Defendant JONES Becomes a Recruiter for Defendant TURNER and Recruits
26 Multiple Friends and Family Members to the Fraud
27 Overt Act No. 43: On May 16, 2023, the same day that defendant
28 JONES texted defendant TURNER to ask what name u want on this check
18
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 19 of 34 Page ID #:19
1 . . . 95k, defendant JONES caused the issuance of a cashiers check
2 for $95,000 for the benefit of defendant TURNER, addressed to Kris
3 Turner Enterprise.
4 Overt Act No. 44: On May 18, 2023, defendant JONES caused the
5 issuance of a cashiers check for $89,500 for the benefit of
6 defendant TURNER, addressed to the name of a business controlled by a
7 co-conspirator (TURNER Nominee Business 1).
8 Overt Act No. 45: On May 19, 2023, over text message,
9 defendant TURNER sent defendant JONES a photograph of a notebook page
10 that listed the names of the ten JONES Recruits and the dates that
11 false Form 941s were submitted for each of those businesses, and
12 stated that they were All the ones we did.
13 Overt Act No. 46: On May 19, 2023, defendant TURNER advised
14 defendant JONES over text that she owed processing fees for JONES
15 Recruit 9 and JONES Recruit 10, as well as fees to pay the Secretary
16 of State filing fees for JONES Recruit 3 and JONES Recruit 9.
17 Overt Act No. 47: On June 3, 2023, defendant JONES sent a text
18 message to defendant TURNER, stating: Im gonna need how many
19 employees for each quarter for all my folks, referring to the ten
20 JONES Recruits, People have been getting asked that information I
21 heard.
22 Overt Act No. 48: On June 5, 2023, defendant JONES texted
23 defendant TURNER: Hey I need a favor. Can you send me the PDF tax
24 identification form for [JONES Recruit 9 and JONES Recruit 1] . . . I
25 need to fix some things . . . Also need them numbers . . . . They
26 have an appointment at 11am.
27 Overt Act No. 49: On June 16, 2023, via text message,
28 defendant JONES informed defendant TURNER that bank accounts for the
19
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 20 of 34 Page ID #:20
1 JONES Recruits were being frozen: We got a issue . . . Another
2 account got closed . . . This shit is crazy . . . Fucking up my
3 plans..smh.
4 Overt Act No. 50: On July 15, 2023, in response to a text from
5 defendant JONES stating, Next week will have $48,445 off of $161,385
6 for you..From [Jones Recruit 1], defendant TURNER responded, Ok
7 cool thank you . . . Mark Sandridge Auto Body.
8 Overt Act No. 51: On July 26, 2023, defendant JONES caused the
9 issuance of a cashiers check for $48,445 for the benefit of
10 defendant TURNER, addressed to Mark Sandridge Auto Body.
11 Overt Act No. 52: On July 26, 2023, in response to a text from
12 defendant JONES asking, What another company name, defendant TURNER
13 texted the name of a business controlled by a co-conspirator (TURNER
14 Nominee Business 2).
15 Overt Act No. 53: On July 26, 2023, defendant JONES caused the
16 issuance of a cashiers check for $31,000 for the benefit of
17 defendant TURNER, addressed to TURNER Nominee Business 2.
18
19
20
21
22
23
24
25
26
27
28
20
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 21 of 34 Page ID #:21
1 COUNTS TWO THROUGH NINETEEN
2 [18 U.S.C. § 1341]
3 [ALL DEFENDANTS]
4 16. The Grand Jury realleges paragraphs 1 through 11 and 13
5 through 15 of this Indictment here.
6 A. THE SCHEME TO DEFRAUD
7 17. Beginning no later than June 2022 and continuing until at
8 least in or around December 2024 in Los Angeles County, within the
9 Central District of California, and elsewhere, defendants TURNER,
10 KNOX, JONES, and JOHNSON, together with others known and unknown to
11 the Grand Jury, knowingly and with intent to defraud, devised,
12 participated in, and executed a scheme to defraud the IRS and the
13 United States government as to material matters, and to obtain money
14 and property by means of material false and fraudulent pretenses,
15 representations, and promises.
16 18. The fraudulent scheme operated, in substance, as described
17 in paragraph 13 of this Indictment.
18 B. USE OF THE MAILS
19 19. On or about the dates set forth below, in Los Angeles
20 County, within the Central District of California, and elsewhere, for
21 the purpose of executing the above-described scheme to defraud, the
22 following defendants, aiding and abetting each other, for the purpose
23 of executing the above-described scheme to defraud, willfully caused
24 the following items to be placed in an authorized depository for mail
25 matter to be sent and delivered by the United States Postal Service,
26 according to the directions thereon:
27
28
21
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 22 of 34 Page ID #:22
1 COUNT DEFENDANT DATE ITEM MAILED
2 TWO TURNER 1/16/2023 A Treasury Check for
$260,275.39 addressed to
3 Turner Auto Shop, Kris Turner
Sole Mbr, sent by U.S. Mail
4
from the Department of the
5 Treasury to 250 E Sepulveda
Blvd Ste 1147, Carson, CA
6 90745.
THREE TURNER 1/16/2023 A Treasury Check for
7 $250,389.41 addressed to
Turner Auto Shop, Kris Turner
8
Sole Mbr, sent by U.S. Mail
9 from the Department of the
Treasury to 250 E Sepulveda
10 Blvd Ste 1147, Carson, CA
90745.
11 FOUR TURNER 1/16/2023 A Treasury Check for
$250,389.41 addressed to
12
Turner Auto Shop, Kris Turner
13 Sole Mbr, sent by U.S. Mail
from the Department of the
14 Treasury to 250 E Sepulveda
Blvd Ste 1147, Carson, CA
15 90745.
FIVE TURNER 1/16/2023 A Treasury Check for
16
$242,520.33 addressed to
17 Turner Auto Shop, Kris Turner
Sole Mbr, sent by U.S. Mail
18 from the Department of the
Treasury to 250 E Sepulveda
19 Blvd Ste 1147, Carson, CA
90745.
20 SIX TURNER 2/14/2023 A Treasury Check for
21 $528,254.29 addressed to Mark
Sandridge Auto Body LLC,
22 Kristerpher G Turner Sole
Mbr, sent by U.S. Mail from
23 the Department of the
Treasury to 8704 S. Sepulveda
24 Boulevard 1056, Westchester,
25 CA 90045.
26
27
28
22
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 23 of 34 Page ID #:23
1 COUNT DEFENDANT DATE ITEM MAILED
2 SEVEN TURNER, 2/16/2023 A Treasury Check for
$249,046.89 addressed to
3 KNOX, Joyce M Johnson, Jays Mobile
Cleaning Service, sent by
4 JOHNSON
U.S. Mail from the Department
5 of the Treasury to 12215
Shadow Dr., Victorville,
6 California.
EIGHT TURNER, 2/16/2023 A Treasury Check for
7 $212,181.06 addressed to
KNOX, Joyce M Johnson, Jays Mobile
8
Cleaning Service, sent by
JOHNSON
9 U.S. Mail from the Department
of the Treasury to 12215
10 Shadow Dr., Victorville,
California.
11 NINE TURNER, 2/16/2023 A Treasury Check for
$169,223.92 addressed to
12 KNOX, Joyce M Johnson, Jays Mobile
13 Cleaning Service, sent by
JOHNSON
U.S. Mail from the Department
14 of the Treasury to 12215
Shadow Dr., Victorville,
15 California.
TEN TURNER 3/21/2023 A Treasury Check for
16
$283,775.42 addressed to
17 Turner Auto Shop, Kris Turner
Sole Mbr, sent by U.S. Mail
18 from the Department of the
Treasury to 250 E Sepulveda
19 Blvd Ste 1147, Carson, CA
90745.
20 ELEVEN TURNER 3/21/2023 A Treasury Check for
21 $283,775.42 addressed to
Turner Auto Shop, Kris Turner
22 Sole Mbr, sent by U.S. Mail
from the Department of the
23 Treasury to 250 E Sepulveda
Blvd Ste 1147, Carson, CA
24 90745.
25
26
27
28
23
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 24 of 34 Page ID #:24
1 COUNT DEFENDANT DATE ITEM MAILED
2 TWELVE TURNER 3/21/2023 A Treasury Check for
$284,975.16 addressed to
3 Turner Auto Shop, Kris Turner
Sole Mbr, sent by U.S. Mail
4
from the Department of the
5 Treasury to 250 E Sepulveda
Blvd Ste 1147, Carson, CA
6 90745.
THIRTEEN TURNER, 2/28/2023 A Treasury Check for
7 $253,358.97 addressed to
KNOX, Joyce M Johnson, Jays Mobile
8
Cleaning Service, sent by
JOHNSON
9 U.S. Mail from the Department
of the Treasury to 12215
10 Shadow Dr., Victorville,
California.
11 FOURTEEN TURNER, 3/28/2023 A Treasury Check for
$294,460.23 addressed to KMJ
12 KNOX, Innovation LLC, sent by U.S.
13 Mail from the Department of
JONES
the Treasury to 1702 W 137th
14 Street, Compton, California
90222.
15 FIFTEEN TURNER, 3/28/2023 A Treasury Check for
$305,041.66 addressed to KMJ
16 KNOX, Innovation LLC, sent by U.S.
17 Mail from the Department of
JONES
the Treasury to 1702 W 137th
18 Street, Compton, California
90222.
19 SIXTEEN TURNER, 3/28/2023 A Treasury Check for
$284,936.93 addressed to KMJ
20 KNOX, Innovation LLC, sent by U.S.
21 Mail from the Department of
JONES
the Treasury to 1702 W 137th
22 Street, Compton, California
90222.
23 SEVENTEEN TURNER, 3/28/2023 A Treasury Check for
$274,537.33 addressed to KMJ
24 KNOX, Innovation LLC, sent by U.S.
25 Mail from the Department of
JONES
the Treasury to 1702 W 137th
26 Street, Compton, California
90222.
27
28
24
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 25 of 34 Page ID #:25
1 COUNT DEFENDANT DATE ITEM MAILED
2 EIGHTEEN TURNER, 3/28/2023 A Treasury Check for
$274,537.33 addressed to KMJ
3 KNOX, Innovation LLC, sent by U.S.
Mail from the Department of
4 JONES
the Treasury to 1702 W 137th
5 Street, Compton, California
90222.
6 NINETEEN TURNER, 3/28/2023 A Treasury Check for
$222,435.75 addressed to KMJ
7 KNOX, Innovation LLC, sent by U.S.
Mail from the Department of
8 JONES
the Treasury to 1702 W 137th
9 Street, Compton, California
90222.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
25
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 26 of 34 Page ID #:26
1 COUNT TWENTY
2 [18 U.S.C. § 286]
3 [ALL DEFENDANTS]
4 20. The Grand Jury realleges paragraphs 1 through 11 and 13
5 through 15 of this Indictment here.
6 A. OBJECT OF THE CONSPIRACY
7 21. Beginning no later than in or around June 2022 and
8 continuing until at least in or around December 2024, in Los Angeles
9 County, within the Central District of California, and elsewhere,
10 defendants TURNER, KNOX, JONES, and JOHNSON, knowingly and unlawfully
11 agreed, combined, and conspired with each other, and with others
12 known and unknown to the Grand Jury, to defraud the United States and
13 the IRS by obtaining and aiding to obtain the payment of false,
14 fictitious, and fraudulent claims, specifically, the filing of false
15 federal tax returns containing fraudulent claims for tax refunds
16 based upon false and fictitious amounts of paid sick and family leave
17 claimed to have been paid, reported on false Form 941s and Form 944s,
18 that defendants caused to be filed with the IRS.
19 B. MANNER AND MEANS OF THE CONSPIRACY
20 22. The object of the conspiracy was to be carried out, and was
21 carried out, in substance, as alleged in paragraph 13 of this
22 Indictment.
23 C. OVERT ACTS
24 23. In furtherance of the conspiracy and to accomplish its
25 object, defendants TURNER, KNOX, JONES, and JOHNSON, together with
26 others known and unknown to the Grand Jury, committed and caused to
27 be committed the overt acts set forth in paragraph 15 of this
28
26
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 27 of 34 Page ID #:27
1 Indictment, among others, in the Central District of California, and
2 elsewhere, on or about the dates set forth therein.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
27
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 28 of 34 Page ID #:28
1 COUNT TWENTY-ONE
2 [18 U.S.C. §§ 1512(a)(1)(C); 2]
3 [DEFENDANTS KNOX AND JONES]
4 24. The Grand Jury realleges paragraphs 1 through 11 and 13
5 through 15 of this Indictment here.
6 25. On or about August 29, 2023, in Los Angeles County, within
7 the Central District of California, defendants KNOX and JONES, and
8 others known and unknown to the Grand Jury, including Co-Conspirator
9 2, and Co-Conspirator 3, each aiding and abetting each other,
10 attempted to kill, and willfully caused an attempt to kill, another
11 person, namely, Kristerpher Turner, with intent to prevent the
12 communication by any person to a law enforcement officer relating to
13 the commission or possible commission of at least one Federal
14 offense, including conspiracy to commit mail fraud, in violation of
15 Title 18, United States Code, Section 1349, mail fraud, in violation
16 of Title 18, United States Code, Section 1341, and conspiracy to
17 submit false, fictitious, or fraudulent claims, in violation of Title
18 18, United States Code, Section 286, as charged in Counts One through
19 Twenty of this Indictment.
20
21
22
23
24
25
26
27
28
28
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 29 of 34 Page ID #:29
1 COUNT TWENTY-TWO
2 [18 U.S.C. §§ 924(c)(1)(A); 2]
3 [DEFENDANTS KNOX AND JONES]
4 26. The Grand Jury realleges paragraphs 1 through 11 and 13
5 through 15 of this Indictment here.
6 27. On or about August 29, 2023, in Los Angeles County, within
7 the Central District of California, defendants KNOX and JONES, along
8 with Co-Conspirator 2, and Co-Conspirator 3, each aiding and abetting
9 each other, willfully caused the knowing use and carrying of a
10 firearm during and in relation to, and the possession of a firearm in
11 furtherance of, a crime of violence, namely, attempt to kill a
12 witness, in violation of Title 18, United States Code, Section
13 1512(a)(1)(C), as charged in Count Twenty-One of this Indictment,
14 and, in so doing, willfully caused the brandishing and discharge of
15 the firearm.
16
17
18
19
20
21
22
23
24
25
26
27
28
29
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 30 of 34 Page ID #:30
1 FORFEITURE ALLEGATION ONE
2 [18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]
3 28. Pursuant to Rule 32.2 of the Federal Rules of Criminal
4 Procedure, notice is hereby given that the United States of America
5 will seek forfeiture as part of any sentence, pursuant to Title 18,
6 United States Code, Section 981(a)(1)(C) and Title 28, United States
7 Code, Section 2461(c), in the event of any defendants conviction of
8 the offenses set forth in any of Counts One through Nineteen or
9 Twenty-One of this Indictment.
10 29. Any defendant so convicted shall forfeit to the United
11 States of America the following property:
12 (a) all right, title, and interest in any and all
13 property, real or personal, constituting, or derived from, any
14 proceeds traceable to the offenses, including but not limited to the
15 following:
16 $32,998.61 in Bank Funds seized from a JPMorgan Chase
17 Bank account ending in 2106;
18 $305,691.81 in Bank Funds seized from a JPMorgan Chase
19 Bank account ending in 7887;
20 $72,165.66 in Bank Funds seized from a JPMorgan Chase
21 Bank account ending in 9018;
22 $282,657.34 in Bank Funds seized from a JPMorgan Chase
23 Bank account ending in 8809;
24 $50,000.00 in Bank Funds seized from a JPMorgan Chase
25 Bank account ending in 3902;
26 $944,663.80 in Bank Funds seized from a JPMorgan Chase
27 Bank account ending in 5359;
28 $65,646.60 in Bank Funds seized from a JPMorgan Chase
30
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 31 of 34 Page ID #:31
1 Bank account ending in 8997;
2 $150,000.00 in Bank Funds seized from a JPMorgan Chase
3 Bank account ending in 0244;
4 $249,490.30 in Bank Funds seized from a JPMorgan Chase
5 Bank account ending in 2589;
6 $440,606.40 in Bank Funds seized from a JPMorgan Chase
7 Bank account ending in 6008;
8 $250,000.00 in Bank Funds seized from a JPMorgan Chase
9 Bank account ending in 4220;
10 $130,206.20 in Bank Funds seized from a JPMorgan Chase
11 Bank account ending in 8352;
12 $42,599.76 in Bank Funds seized from a JPMorgan Chase
13 Bank account ending in 3315;
14 $100,000.00 in Bank Funds seized from a JPMorgan Chase
15 Bank account ending in 8379;
16 $20,000.00 in Bank Funds seized from a JPMorgan Chase
17 Bank account ending in 1036;
18 $334,219.59 in Bank Funds seized from a JPMorgan Chase
19 Bank account ending in 6885;
20 Real property commonly known as 1119 S Orange Dr, Los
21 Angeles, CA 90019 (APN 5084-020-013); and
22 Real property commonly known as 5631 Marburn Ave, Los
23 Angeles, CA 90043 (APN 5008-011-012).
24 (b) To the extent such property is not available for
25 forfeiture, a sum of money equal to the total value of the property
26 described in subparagraph (a).
27 3. Pursuant to Title 21, United States Code, Section 853(p),
28 as incorporated by Title 28, United States Code, Section 2461(c), any
31
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 32 of 34 Page ID #:32
1 defendant if so convicted shall forfeit substitute property, up to
2 the value of the property described in the preceding paragraph if, as
3 the result of any act or omission of said defendant, the property
4 described in the preceding paragraph or any portion thereof (a)
5 cannot be located upon the exercise of due diligence; (b) has been
6 transferred, sold to, or deposited with a third party; (c) has been
7 placed beyond the jurisdiction of the court; (d) has been
8 substantially diminished in value; or (e) has been commingled with
9 other property that cannot be divided without difficulty.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
32
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 33 of 34 Page ID #:33
1 FORFEITURE ALLEGATION TWO
2 [18 U.S.C. § 924(d)(1) and 28 U.S.C. § 2461(c)]
3 30. Pursuant to Rule 32.2 of the Federal Rules of Criminal
4 Procedure, notice is hereby given that the United States of America
5 will seek forfeiture as part of any sentence, pursuant to Title 18,
6 United States Code, Section 924(d)(1), and Title 28, United States
7 Code, Section 2461(c), in the event of any defendants conviction of
8 the offense set forth in Count Twenty-Two of this Indictment.
9 31. Any defendant so convicted shall forfeit to the United
10 States of America the following:
11 (a) All right, title, and interest in any firearm or
12 ammunition involved in or used in any such offense; and
13 (b) To the extent such property is not available for
14 forfeiture, a sum of money equal to the total value of the property
15 described in subparagraph (a).
16 32. Pursuant to Title 21, United States Code, Section 853(p),
17 as incorporated by Title 28, United States Code, Section 2461(c), the
18 convicted defendant shall forfeit substitute property, up to the
19 value of the property described in the preceding paragraph if, as the
20 result of any act or omission of said defendant, the property
21 described in the preceding paragraph or any portion thereof (a)
22 cannot be located upon the exercise of due diligence; (b) has been
23 transferred, sold to, or deposited with a third party; (c) has been
24 placed beyond the jurisdiction of the court; (d) has been
25 //
26 //
27
28
33
Case 2:25-cr-00462-CV Document 1 Filed 06/11/25 Page 34 of 34 Page ID #:34
1 substantially diminished in value; or (e) has been commingled with
2 other property that cannot be divided without difficulty.
3
4 A TRUE BILL
5
6
Foreperson
7
8 BILAL A. ESSAYLI
United States Attorney
9
10
11 CHRISTINA T. SHAY
Assistant United States Attorney
12 Chief, Criminal Division
13 KRISTEN A. WILLIAMS
Assistant United States Attorney
14 Chief, Major Frauds Section
15 JOSHUA O. MAUSNER
Assistant United States Attorney
16 Chief, Violent and Organized
Crimes Section
17
KEVIN BUTLER
18 Assistant United States Attorney
Deputy Chief, Violent and
19 Organized Crimes Section
20 KEVIN REIDY
HAOXIAOHAN CAI
21 Assistant United States Attorneys
Major Frauds Section
22
23
24
25
26
27
28
34
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