Criminal Complaint — Mag. No. 21-13255 (LDW) (D.N.J.)
Summary
In this criminal complaint (D.N.J., Mag. No. 21-13255), sworn by telephone before Hon. Leda Dunn Wettre, Department of Labor Office of Inspector General Special Agent Bladimir Daza charges Khaori Monroe, a USPS letter carrier in Newark, with wire fraud against the State of California from about July 2020 through October 2020. A California unemployment debit card ending in 0880, issued on a fraudulent application in the name of Individual 1 and mailed to a New Jersey residence, was funded with approximately $18,000, all debited between August 4, 2020 and September 10, 2020. A phone number subscribed to by Monroe was used to call a bank about two other fraudulently issued cards funded with approximately $31,000. In an April 7, 2021 interview, Monroe identified himself in three ATM photographs and stated that the 0880 Card had been taken by Monroe from a second USPS location in Newark.
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UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA Hon. Leda Dunn Wettre
V. Mag. No. 21-13255 (LDW)
KHAORIMONROE CRIMINAL COMPLAINT
I, Bladimir Daza, being duly sworn, state the following is true and correct to
the best of my knowledge and belief:
SEE ATTACHMENT A
I further state that I am a Special Agent with the U.S. Department of Labor,
Office of Inspector General, and that this complaint is based ·on the following facts:
SEE ATTACHMENT B
continued on the attached page and made a part hereof.
Special Agent Bladimir Daza
U.S. Department of Labor
Office of Inspector General
*Special Agent Daza attested to this
Complaint by telephone pursuant to FRCP
4. l(b)(2)(A).
Sworn to and subscribed via telephone, NEW JERSEY
this 30th day of August, 2021 State
HONORABLE LEDA DUNN WETIRE
UNITED STATES MAGISTRATE JUDGE Signature of Judicial Officer
ATTACHMENT A
· (Wire Fraud)
From in or around July 2020 through in or around October 2020, in
Essex County, in the District of New Jersey and elsewhere, defendant
KHAORI MONROE
knowingly and intentionally devised and intended to devise a scheme and artifice
to defraud the State of California and others, and to obtain money and property
by means of materially false and fraudulent pretenses, representations, and
promises, and, for the purpose of executing and attempting to execute such
scheme and artifice to defraud, did transmit and cause to be transmitted by
means of wire communications in interstate and foreign commerce, certain
writings, signs, signals, pictures, and sounds, to wit, a wire transmission sent
on or about August 18, 2020, from a location inside of New Jersey to a location
outside.
In violation of Title 18, United States Code, Sections 1343 and 2 .
1
ATTACHMENT B
I, Bladimir Daza, a Special Agent with the U.S. Department of Labor,
Office of Inspector General ("DOL-OIG"), having personally participated in an
investigation of the conduct of defendant KHAORI MONROE ("MONROE"), and
having spoken with other law enforcement officers and individuals and
reviewed documents, have knowledge of the following facts. Because this
Complaint is submitted for the limited purpose of establishing probable cause,
I have not included all facts known to me concerning this investigation. The
contents of documents and the actions, statements, and conversations of
individuals referenced below are provided in substance and in part, unless
otherwise indicated.
1. At all times relevant to this Complaint, MONROE was employed as
a letter carrier at a USPS location in Newark, New Jersey.
2. On March 27, 2020, the Coronavirus Aid, Relief, and Economic
Security Act "CARES Act" was signed into law. The CARES Act created a new
temporary federal unemployment insurance program called Pandemic
Unemployment Assistance ("PUA"). PUA provides unemployment insurance
benefits ("UIBs") for individuals who are not eligible for other types of
unemployment (e.g., self-employed, independent contractors, gig economy
workers). The CARES Act also created a new temporary federal program called
Federal Pandemic Unemployment Assistance that provides an additional $600
weekly benefit to those eligible for PUA and regular UIBs. Unemployment
Insurance ("UI") is a state-federal program that provides unemployment
insurance benefits ("UIBs") to eligible workers.
3. On or about July 13, 2021, an application was made for UIBs in
the name of Individual 1 to the State of California. In response, the State of
California caused a debit card with a number ending in 0880 (the "0880
Card") to be issued and sent by United States mail to a residence in New
Jersey (the "Residence"). The State of California caused the 0880 Card to be
funded with approximately $18,000. The investigation has determined that the
application was fraudulent and that Individual 1 did not make the above-
referenced application.
4. Between on or about August 4, 2020, and September 10, 2020,
approximately $18,000 was debited from the 0880 Card.
5. A telephone number ending in 8646 (the "Telephone Number") was
used to call an issuing bank concerning two other debit cards that the
investigation has determined were issued in response to fraudulent
applications. Records obtained during the inve stigation demonstrate that the
Telephone Number wa s subscribed to by defendant MONROE during this time.
Records obtained during the investigation further reveal that: (a) the two d ebit
2
cards were funded with a combined total of approximately $31,000; and (b)
approximately $6,000 in total was withdrawn in combination from the two
debit cards.
6. On or about April 7, 2021, defendant MONROE was interviewed by
law enforcement officers (the "April 7, 2021 Interview"). During the April 7,
2021 Interview, MONROE identified himself in three photographs. The
photographs each depict an individual making a transaction at an ATM· in New
Jersey. Bank records reveal that in or around the time of the photographs,
withdrawals were made from the ATMs using the 0880 Card. The investigation
has revealed that these ATM withdrawals, which occurred on or about August
18, 2020, and August 21, 2020, each caused a wire communication from a
location inside of New Jersey to a location outside of New Jersey.
7. Defendant MONROE stated during the April 7, 2021 Interview, in
substance and in part, that he took 0880 Card from a second and separate
USPS location in Newark, New Jersey.
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- usao-nj-media-1164271-monroe-complaint-mag-21-13255.pdf
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