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Home Source documents Indictment — United States v. Kristerpher Turner et al. (Central District of California, Document 1)

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).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-25-cr-00462-dkt-1-c-d-cal-82f31defd7/, SHA-256 db0143a0f7e76ce2654dab077c3e4cc2f4a793054ad71092d6b9a31283a6ff3f.

Full text

     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
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 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 Jay’s Mobile Cleaning

 8   Service LLC.   Defendant JOHNSON maintained and controlled bank

 9   accounts established for Jay’s 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 Jay’s 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
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 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 Employer’s Quarterly Federal Tax Return.             The Form 941

 4   required the taxpayer to truthfully state, among other things, the

 5   number of employees, the business’s 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   Employer’s 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
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 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
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 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 partner’s 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
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 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 conspiracy’s 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 TURNER’s 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
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 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   TURNER’s 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   TURNER’s 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 defendant’s

 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 shouldn’t “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 TURNER’s 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, “What’s 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
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 1   send $25k a day to get payments caught up,” defendant TURNER

 2   responded: “Just send 25k a week and I’ll grab 5k in cash from you a

 3   week.     Don’t want them to see you pay me every day and I’ll 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 KNOX’s 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 KNOX’s 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 JOHNSON’s company, Jay’s 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   JOHNSON’s 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 Jay’s 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 Jay’s 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   Jay’s Mobile Cleaning Services and asking him to call her back

24   because the bank had questioned the validity of defendant JOHNSON’s

25   business and put a hold on her account, preventing her from making

26   any withdrawals of her fraudulent proceeds.

27

28

                                             14
     Case 2:25-cr-00462-CV   Document 1   Filed 06/11/25   Page 15 of 34 Page ID #:15



 1         Overt Act No. 22:      On May 24, 2023, when defendant TURNER did

 2   not pick up defendant JOHNSON’s 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 1’s 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 1’s 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 2’s 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 2’s 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 2’s 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 JONES’s 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 JONES’s 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 JONES’s 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 cashier’s 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 cashier’s check in defendant KNOX’s

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 cashier’s 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 cashier’s 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 cashier’s 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 cashier’s 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 cashier’s 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: “I’m 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 cashier’s 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 cashier’s 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 defendant’s 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 defendant’s 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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