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Indictment — United States v. Natalie Le Demola et al., Central District of California (Document 17)

Summary

A grand jury indictment in United States v. Natalie Le Demola et al., No. 2:22-cr-00205-JFW, in the U.S. District Court for the Central District of California, filed May 12, 2022 as Document 17. It charges defendants including Carleisha Neosha Plummer and Amber Jane Wade under 18 U.S.C. § 1349, 18 U.S.C. § 1344(2), 18 U.S.C. § 1028A(a)(1) and 18 U.S.C. § 982. Count One charges a conspiracy running from in or around June 2020 to at least in or around April 2021 to obtain pandemic unemployment benefits from the California Employment Development Department with fraudulent applications. The indictment alleges that defendants obtained personal identifying information of inmates at the California Department of Corrections and Rehabilitation and withdrew benefits from EDD debit cards at ATMs. It closes with forfeiture allegations and is signed by the foreperson as a true bill.

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Cite this document

“Indictment — United States v. Natalie Le Demola et al., Central District of California (Document 17).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-2-22-cr-00205-dkt-17-c-d-cal-f1c58eabf2/, SHA-256 96ec2004e81ddc5bcf13615b22b3addd51e733f13dc3452f1fc2e955ac682cde.

Full text

     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 1 of 38 Page ID #:81


                                                                      5/12/2022
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                                                                        VAM

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 8                           UNITED STATES DISTRICT COURT

 9                    FOR THE CENTRAL DISTRICT OF CALIFORNIA

10                              March 2022 Grand Jury
11   UNITED STATES OF AMERICA,               CR   2:22-cr-00205-JFW

12             Plaintiff,                    I N D I C T M E N T
13             v.                            [18 U.S.C. § 1349: Conspiracy to
                                             Commit Wire Fraud and Bank Fraud;
14   NATALIE LE DEMOLA,                      18 U.S.C. § 1344(2): Bank Fraud;
     CARLEISHA NEOSHA PLUMMER,               18 U.S.C. § 1028A(a)(1):
15     aka “LG,”                             Aggravated Identity Theft;
     KHANSHANDA EUGENA KING,                 18 U.S.C. § 982: Criminal
16     aka “Cassandra King,”                 Forfeiture]
     CLESHAY JOHNSON II,
17   JAMES ANTONIO JOHNSON,
       aka “Niddy Johnson,”
18     aka “Big Dawg Niddy,”
       aka “Niddy,”
19   FELICITE ALEISHA KING,
     SHAFEQUAH LYNETE MITCHELL,
20   LORESHA SHAMONE DAVIS,
     PORSHA LATRICE JOHNSON,
21   DONISHA LASHAWN PACE,
     DOMINIQUE CHARMONE MARTIN,
22   MYKARA DESTINY ROBERTSON, and
     AMBER JANE WADE,
23
               Defendants.
24

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     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 2 of 38 Page ID #:82



 1        The Grand Jury charges:

 2                                     COUNT ONE

 3                                [18 U.S.C. § 1349]

 4                                 [ALL DEFENDANTS]

 5        INTRODUCTORY ALLEGATIONS
 6        At times relevant to this Indictment:
 7        1.    The California Employment Development Department (“EDD”)
 8   administered unemployment insurance (“UI”) benefits for residents of
 9   California, including Pandemic Unemployment Assistance benefits to
10   individuals who were unemployed because of the COVID-19 pandemic
11   (“pandemic benefits”).
12        2.    To qualify for UI benefits, including pandemic benefits, a
13   California resident had to submit to EDD an application for the
14   benefits; provide EDD with personal identifying information (“PII”),
15   including the applicant’s name, date of birth, and social security
16   number; and certify to EDD under the penalties of perjury that the
17   COVID-19 pandemic had directly and adversely affected the applicant’s
18   employment.
19        3.    Applications for UI benefits, including pandemic benefits,
20   could be submitted to EDD online. An individual who applied online
21   for benefits would provide EDD with an email address (“account email
22   address”) in addition to the applicant’s physical mailing address
23   (“account mailing address”).
24        4.    Individuals who were employed, retired, or incarcerated
25   were not eligible for UI benefits, including pandemic benefits.
26        5.    After a person submitted an application for UI benefits,
27   including pandemic benefits, EDD would transmit an email to the
28   account email address confirming the submission of the application

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     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 3 of 38 Page ID #:83



 1   and, thereafter, would send correspondences related to the

 2   application and the UI benefits, including pandemic benefits, to the

 3   account email address.

 4        6.    Once EDD approved the application and granted pandemic

 5   benefits to the applicant, EDD would create a debit account (“EDD

 6   debit account”) with Bank of America, NA (“Bank of America”). A debit

 7   card linked to the EDD debit account would then be mailed to the

 8   account mailing address.

 9        7.    EDD would deposit UI benefits, including pandemic benefits,

10   to the EDD debit account. The debit card could then be used to

11   withdraw the benefits from the EDD debit account using automated

12   teller machines (“ATMs”), including ATMs that Bank of America, Wells

13   Fargo Bank, NA (“Wells Fargo”), and JPMorgan Chase Bank, NA

14   (“Chase”), operated.

15        8.    Once approved for pandemic benefits, the recipient of the

16   benefits would be required to periodically recertify under the

17   penalties of perjury that, among other things, the recipient was

18   unemployed due to the COVID-19 pandemic and therefore remained

19   eligible to receive pandemic benefits.

20        9.    Bank of America, Wells Fargo, and Chase were financial

21   institutions that were insured by the Federal Deposit Insurance

22   Company.

23        THE OBJECTS OF THE CONSPIRACY
24        10.   Beginning no later than in or around June 2020 and
25   continuing until at least in or around April 2021, in Los Angeles,
26   Riverside, Ventura, and San Bernardino Counties, within the Central
27   District of California, and elsewhere, defendants NATALIE LE DEMOLA
28   (“DEMOLA”), CARLEISHA NEOSHA PLUMMER, also known as (“aka”) “LG”

                                            3
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 4 of 38 Page ID #:84



 1   (“PLUMMER”), KHANSHANDA EUGENA KING, aka “Cassandra King”

 2   (“K. KING”), CLESHAY JOHNSON II (“C. JOHNSON”), JAMES ANTONIO

 3   JOHNSON, aka “Niddy Johnson,” aka “Big Dawg Niddy,” aka “Niddy”

 4   (“J. JOHNSON”), FELICITE ALEISHA KING (“F. KING”), SHAFEQUAH LYNETE

 5   MITCHELL (“MITCHELL”), LORESHA SHAMONE DAVIS (“DAVIS”), PORSHA

 6   LATRICE JOHNSON (“P. JOHNSON”), DONISHA LASHAWN PACE (“PACE”),

 7   DOMINIQUE CHARMONE MARTIN (“MARTIN”), MYKARA DESTINY ROBERTSON

 8   (“ROBERTSON”), and AMBER JANE WADE (“WADE”), conspired with one

 9   another, and with others known and unknown to the Grand Jury, to

10   commit: (a) wire fraud, in violation of Title 18, United States Code,

11   Section 1343; and (b) bank fraud, in violation of Title 18, United

12   States Code, Section 1344(2).

13        MANNER AND MEANS OF THE CONSPIRACY
14        11.   The objects of the conspiracy were carried out, and were to
15   be carried out, in substance, as follows:
16              a.         Defendants DEMOLA, PLUMMER, and K. KING, and other
17   coconspirators, would acquire the PII, such as the names, dates of
18   birth, and social security numbers, of individuals, including
19   identity theft victims, who were not eligible for UI benefits,
20   including pandemic benefits, because they were employed, retired, or
21   incarcerated. For example:
22                    i.        Defendants DEMOLA and PLUMMER would solicit and
23   obtain PII from inmates who were incarcerated at institutions within
24   the California Department of Corrections and Rehabilitation (“CDCR”).
25                   ii.        Defendant DEMOLA would obtain PII for CDCR
26   inmates and their visitors from an associate who would access CDCR
27   databases for this unauthorized purpose, and then disseminate the PII
28   of the identity theft victims to other defendants and coconspirators.

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 1               iii.           Defendant K. KING, in concert with defendant

 2   C. JOHNSON, would acquire the PII of victims who were employed,

 3   retired, and in some cases CDCR inmates, and maintain that victim PII

 4   in notebooks (“defendant K. KING’s notebooks”) and other locations.

 5              b.         Coconspirators would use the victims’ PII to submit

 6   fraudulent online applications to EDD, for UI benefits, including

 7   pandemic benefits (the “fraudulent EDD applications”).

 8              c.         Coconspirators would assume the victims’ identities

 9   and provide materially false information to EDD on the fraudulent EDD

10   applications, including that the victims were unemployed as a direct

11   result of the COVID-19 pandemic. For example, defendants and their

12   coconspirators would submit fraudulent EDD applications on which they

13   provided materially false information using the identities of victims

14   K.S.R., M.D.S., D.F., M.D.J., K.S., A.A.M., D.M.B., M.P., T.R.S.,

15   D.D.J., S.M., N.M.S., N.T.S., P.G.W., D.S.S., D.Fo., J.J.W., L.Si.,

16   R.J., A.M.S., F.S., and A.R.C., among other victims.

17              d.         Coconspirators would also submit fraudulent EDD

18   applications using PII belonging to coconspirators, including the PII

19   belonging to defendants DEMOLA, PLUMMER, and K. KING, and on those

20   applications, provide information they knew to be false that was also

21   material, including that they were unemployed as a direct result of

22   the COVID-19 pandemic.

23              e.         By submitting the fraudulent EDD applications,

24   coconspirators would cause EDD to:

25                    i.        Transmit emails that were related to the

26   fraudulent EDD applications to the account email addresses;

27                   ii.        Authorize pandemic benefits to be provided to

28   individuals who were ineligible for pandemic benefits because they
                                              5
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 6 of 38 Page ID #:86



 1   were employed, retired, or incarcerated, including the identity theft

 2   victims, defendants, and defendants’ coconspirators; and

 3               iii.        Cause EDD debit cards, that is, debit cards

 4   linked to the EDD debit accounts at Bank of America, to be mailed to

 5   the account mailing addresses, which defendants, including defendant

 6   MARTIN, and defendants’ coconspirators controlled.

 7              f.      After EDD approved the fraudulent EDD applications and

 8   disbursed the pandemic benefits funds to the EDD debit accounts, and

 9   Bank of America issued the EDD debit cards linked to those accounts,

10   defendants PLUMMER, K. KING, C. JOHNSON, J. JOHNSON, F. KING,

11   MITCHELL, DAVIS, P. JOHNSON, PACE, MARTIN, ROBERTSON, and WADE, and

12   their coconspirators, would fraudulently assume the identities of the

13   EDD debit account holders and use the corresponding EDD debit cards

14   to make fraudulent cash withdrawals of pandemic benefits, knowing

15   that they were not entitled to the withdrawals, from ATMs in Los

16   Angeles, Riverside, and San Bernardino Counties, including at ATMs

17   that Bank of America, Wells Fargo, and Chase operated.

18              g.      From Corona, California, through emails that generated

19   interstate wire signals and through phone calls, defendant DEMOLA

20   would instruct defendants, including defendants PLUMMER and

21   J. JOHNSON, to falsely certify that, among other things, the holders

22   of the fraudulent EDD debit accounts, including the victims,

23   defendants, and defendants’ coconspirators, continued to be eligible

24   to receive pandemic benefits.

25              h.      Defendants PLUMMER, K. KING, MITCHELL, C. JOHNSON,

26   P. JOHNSON, and PACE, and other coconspirators, would use cell phones

27   to access the fraudulent EDD debit accounts and falsely certify that

28   the account holders, including the victims, defendants, and
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 1   defendants’ coconspirators, continued to be eligible to receive

 2   pandemic benefits.

 3        OVERT ACTS
 4        12.   In furtherance of the conspiracy, and to accomplish its
 5   objects, defendants DEMOLA, PLUMMER, K. KING, C. JOHNSON, J. JOHNSON,
 6   F. KING, MITCHELL, DAVIS, P. JOHNSON, PACE, MARTIN, ROBERTSON, and
 7   WADE, and others known and unknown to the Grand Jury, committed and
 8   willfully caused others to commit, on or about the dates set forth
 9   below, the following overt acts, among others, within the Central
10   District of California, and elsewhere:
11        Overt Act No. 1:       On April 3, 2020, Coconspirator 1 accessed
12   the PII of victim R.E.A.T., an inmate within the CDCR prison system,
13   using a CDCR database.
14        Overt Act No. 2:       On May 6, 2020, Coconspirator 1 accessed the
15   PII of victim S.M.A., an inmate within the CDCR prison system, using
16   a CDCR database.
17        Overt Act No. 3:       On May 12, 2020, Coconspirator 1 accessed
18   the PII of victim D.F., an inmate within the CDCR prison system,
19   using a CDCR database.
20        Overt Act No. 4:       On May 13, 2020, Coconspirator 1 accessed
21   the PII of victim D.F., an inmate within the CDCR prison system,
22   using a CDCR database.
23        Overt Act No. 5:       On May 14, 2020, Coconspirator 1 accessed
24   the PII of victim D.F., an inmate within the CDCR prison system,
25   using a CDCR database.
26        Overt Act No. 6:       On May 18, 2020, Coconspirator 1 accessed
27   the PII of victim D.F., an inmate within the CDCR prison system,
28   using a CDCR database.

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 1        Overt Act No. 7:       On an unknown date, defendant DEMOLA

 2   received from a coconspirator PII of inmates within the CDCR prison

 3   system.

 4        Overt Act No. 8:       On June 6, 2020, coconspirators

 5   electronically filed an application for pandemic assistance benefits
 6   in the name of defendant PLUMMER, which was approved.
 7        Overt Act No. 9:       On June 6, 2020, coconspirators
 8   electronically filed an application for pandemic assistance benefits
 9   in the name of defendant DEMOLA, which was approved.
10        Overt Act No. 10:      On June 10, 2020, coconspirators
11   electronically filed an application for pandemic assistance benefits
12   in the name of victim M.D.J., an inmate within the CDCR prison
13   system, which was approved.
14        Overt Act No. 11:      On June 10, 2020, coconspirators
15   electronically filed an application for pandemic assistance benefits
16   in the name of victim L.S., an inmate within the CDCR prison system,
17   which was approved.
18        Overt Act No. 12:      On June 11, 2020, Coconspirator 1 accessed
19   the PII of victim T.K.J., an inmate within the CDCR prison system,
20   from an internal CDCR database.
21        Overt Act No. 13:      On June 11, 2020, coconspirators
22   electronically filed an application for pandemic assistance benefits
23   in the name of victim T.K.J., an inmate within the CDCR prison
24   system, which was approved.
25        Overt Act No. 14:      On June 11, 2020, coconspirators
26   electronically filed an application for pandemic assistance benefits
27   in the name of victim M.L.L., an inmate within the CDCR prison
28   system, which was approved.
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 1        Overt Act No. 15:      On June 12, 2020, coconspirators

 2   electronically filed an application for pandemic assistance in the

 3   name of victim J.B., an inmate within the CDCR prison system, which

 4   was approved.

 5        Overt Act No. 16:      On or before June 16, 2020, defendant

 6   PLUMMER approached A.M.P. and asked her for her PII, which A.M.P.
 7   provided.
 8        Overt Act No. 17:      On or before June 16, 2020, defendant
 9   PLUMMER approached S.M.R. and asked her for her PII, which S.M.R.
10   provided.
11        Overt Act No. 18:      On June 16, 2020, coconspirators
12   electronically filed an application for pandemic assistance in the
13   name of A.M.P., an inmate within the CDCR prison system, which was
14   approved.
15        Overt Act No. 19:      On June 16, 2020, coconspirators
16   electronically filed an application for pandemic assistance in the
17   name of victim S.M.R., an inmate within the CDCR prison system, which
18   was approved.
19        Overt Act No. 20:      On June 16, 2020, coconspirators
20   electronically filed an application for pandemic assistance in the
21   name of victim S.M.A., an inmate within the CDCR prison system, which
22   was approved.
23        Overt Act No. 21:      On June 16, 2020, Coconspirator 1 accessed
24   the PII of victim D.P.R., an inmate within the CDCR prison system,
25   using a CDCR database.
26        Overt Act No. 22:      On June 19, 2020, coconspirators
27   electronically filed an application for pandemic assistance benefits
28   in the name of defendant K. KING, which was approved.
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 1        Overt Act No. 23:       On June 22, 2020, Coconspirator 1 accessed

 2   the PII of victim A.A.M., an inmate within the CDCR prison system,

 3   using a CDCR database.

 4        Overt Act No. 24:       On June 23, 2020, coconspirators

 5   electronically filed an application for pandemic assistance benefits
 6   in the name of victim M.D.S., an inmate within the CDCR prison
 7   system, which was approved.
 8        Overt Act No. 25:       On June 24, 2020, coconspirators
 9   electronically filed an application for pandemic assistance benefits
10   in the name of victim M.C.B., an inmate within the CDCR prison
11   system, which was approved.
12        Overt Act No. 26:       On June 24, 2020, coconspirators
13   electronically filed an application for pandemic assistance benefits
14   in the name of victim D.D.J., which was approved.
15        Overt Act No. 27:       On June 24, 2020, defendant MARTIN, using an
16   EDD debit card ending in 9975, issued in the name of victim K.S.R.,
17   withdrew $503 from a Chase ATM in Yucaipa, California.
18        Overt Act No. 28:       On June 27, 2020, defendant MITCHELL, using
19   an EDD debit card ending in 0868, issued in the name of victim
20   M.D.J., withdrew $1,000 from a Bank of America ATM in Los Angeles,
21   California.
22        Overt Act No. 29:       On June 27, 2020, coconspirators
23   electronically applied for pandemic assistance benefits in the name
24   of victim D.P.R., which was approved.
25        Overt Act No. 30:       On June 28, 2020, coconspirators
26   electronically applied for pandemic assistance benefits in the name
27   of victim A.A.M., which was approved.
28
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 1        Overt Act No. 31:       On June 28, 2020, coconspirators

 2   electronically applied for pandemic assistance benefits in the name

 3   of victim K.S., which was approved.

 4        Overt Act No. 32:       On June 28, 2020, coconspirators

 5   electronically applied for pandemic assistance benefits in the name
 6   of victim R.E.A.T., which was approved.
 7        Overt Act No. 33:       On June 30, 2020, coconspirators
 8   electronically applied for pandemic assistance benefits in the name
 9   of victim D.F., an inmate within the CDCR prison system, which was
10   approved.
11        Overt Act No. 34:       On July 6, 2020, coconspirators
12   electronically applied for pandemic assistance benefits in the name
13   of victim D.P.B., which was approved.
14        Overt Act No. 35:       On July 9, 2020, defendant MITCHELL, using
15   an EDD debit card ending in 0868, issued in the name of victim M.D.J.
16   withdrew $1,000 from a Bank of America ATM in Lakewood, California.
17        Overt Act No. 36:       On July 9, 2020, defendant MITCHELL, using
18   an EDD debit card ending in 0736, issued in the name of victim L.S.,
19   withdrew $1,000 from a Bank of America ATM in Lakewood, California.
20        Overt Act No. 37:       On July 9, 2020, defendant MITCHELL, using
21   an EDD debit card ending in 1414, issued in the name of defendant
22   PLUMMER, withdrew $1,000 from a Bank of America ATM in Lakewood,
23   California.
24        Overt Act No. 38:       On July 10, 2020, defendant J. JOHNSON,
25   using an EDD debit card ending in 1940, issued in the name of victim
26   M.D.S., withdrew $1,000 from a Bank of America ATM in Wilmington,
27   California.
28
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 1        Overt Act No. 39:       On July 11, 2020, defendant F. KING called

 2   an inmate within the CDCR prison system and asked that inmate if he

 3   wanted to be a part of the EDD fraud scheme, saying, “I got this new

 4   thing where I can make you make some change . . . everybody doin’ it

 5   . . . the EDD thing.”

 6        Overt Act No. 40:       On July 11, 2020, defendant J. JOHNSON,

 7   using an EDD debit card ending in 1940, issued in the name of victim
 8   M.D.S., withdrew $1,000 from a Bank of America ATM in Wilmington,
 9   California.
10        Overt Act No. 41:       On July 11, 2020, defendant J. JOHNSON,
11   using an EDD debit card ending in 6137, issued in the name of victim
12   D.F., withdrew $1,000 from a Bank of America ATM in Wilmington,
13   California.
14        Overt Act No. 42:       On July 12, 2020, defendant J. JOHNSON,
15   using an EDD debit card ending in 1940, issued in the name of victim
16   M.D.S., withdrew $1,000 from a Bank of America ATM in Wilmington,
17   California.
18        Overt Act No. 43:       On July 12, 2020, defendant J. JOHNSON,
19   using an EDD debit card ending in 6137, issued in the name of victim
20   D.F., withdrew $1,000 from a Bank of America ATM in Wilmington,
21   California.
22        Overt Act No. 44:       On July 13, 2020, defendant J. JOHNSON,
23   using an EDD debit card ending in 6137, issued in the name of victim
24   D.F., withdrew $1,000 from a Bank of America ATM in Wilmington,
25   California.
26        Overt Act No. 45:       On July 13, 2020, coconspirators
27   electronically filed an application for pandemic assistance benefits
28   in the name of victim T.R.S., which was approved.
                                            12
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 1        Overt Act No. 46:       On July 13, 2020, coconspirators

 2   electronically filed an application for pandemic assistance benefits

 3   in the name of victim D.M.B., an inmate within the CDCR prison

 4   system, which was approved.

 5        Overt Act No. 47:       On July 14, 2020, defendant J. JOHNSON,

 6   using an EDD debit card ending in 1940, issued in the name of victim
 7   M.D.S., withdrew $1,000 from a Bank of America ATM in Wilmington,
 8   California.
 9        Overt Act No. 48:       On July 14, 2020, defendant MITCHELL, using
10   an EDD debit card ending in 9830, issued in the name of victim
11   S.M.R., withdrew $1,000 from a Bank of America ATM in Gardena,
12   California.
13        Overt Act No. 49:       On July 14, 2020, defendant MARTIN, using an
14   EDD debit card ending in 9975, issued in the name of victim K.S.R.,
15   withdrew $503 from a Chase Bank ATM in Yucaipa, California.
16        Overt Act No. 50:       On July 14, 2020, defendant MITCHELL, using
17   an EDD debit card ending in number 0868, issued in the name of victim
18   M.D.J., withdrew $1,000 from a Bank of America ATM in Gardena,
19   California.
20        Overt Act No. 51:       On July 14, 2020, defendant MITCHELL, using
21   an EDD debit card ending in number 8064, issued in the name of victim
22   K.S., withdrew $1,000 from a Bank of America ATM in Gardena,
23   California.
24        Overt Act No. 52:       On July 15, 2020, defendant MITCHELL, using
25   an EDD debit card ending in 1414, issued in the name of defendant
26   PLUMMER, withdrew $1,000 from a Bank of America ATM in Victorville,
27   California.
28
                                            13
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 1        Overt Act No. 53:       On July 15, 2020, coconspirators

 2   electronically filed an application for pandemic assistance benefits

 3   in the name of victim M.P., an inmate in the CDCR prison system,

 4   which was approved.

 5        Overt Act No. 54:       On July 15, 2020, defendant J. JOHNSON,

 6   using an EDD debit card ending in number 6137, issued in the name of
 7   victim D.F., withdrew $1,000 from a Bank of America ATM in Los
 8   Angeles, California.
 9        Overt Act No. 55:       On July 16, 2020, defendant J. JOHNSON,
10   using an EDD debit card ending in 6137, issued in the name of victim
11   D.F., withdrew $1,000 from a Bank of America ATM in Wilmington,
12   California.
13        Overt Act No. 56:       On July 16, 2020, defendant J. JOHNSON,
14   using an EDD debit card ending in 1940, issued in the name of victim
15   M.D.S., withdrew $1,000 from a Bank of America ATM in Wilmington,
16   California.
17        Overt Act No. 57:       On July 16, 2020, defendant F. KING, using
18   an EDD debit card ending in 8925, issued in the name of defendant
19   K. KING, withdrew $1,000 from a Bank of America ATM in Gardena,
20   California.
21        Overt Act No. 58:       On July 17, 2020, defendant J. JOHNSON,
22   using an EDD debit card ending in 6137, issued in the name of victim
23   D.F., withdrew $1,000 from a Bank of America ATM in Wilmington,
24   California.
25        Overt Act No. 59:       On July 17, 2020, defendant J. JOHNSON,
26   using an EDD debit card ending in 1940, issued in the name of victim
27   M.D.S., withdrew $1,000 from a Bank of America ATM in Wilmington,
28   California.
                                            14
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 15 of 38 Page ID #:95



 1        Overt Act No. 60:       On July 18, 2020, defendant J. JOHNSON,

 2   using an EDD debit card ending in 1940, issued in the name of victim

 3   M.D.S., withdrew $1,000 from a Bank of America ATM in Wilmington,

 4   California.

 5        Overt Act No. 61:       On July 20, 2020, defendant MITCHELL, using

 6   an EDD debit card ending in number 6350, issued in the name of victim
 7   A.A.M., withdrew $1,000 from a Bank of America ATM in Walnut Park,
 8   California.
 9        Overt Act No. 62:       On July 22, 2020, in an email exchange
10   between defendant J. JOHNSON and defendant DEMOLA regarding a new
11   application for pandemic assistance benefits, defendant J. JOHNSON
12   requested permission to withdraw money, defendant DEMOLA instructed
13   defendant J. JOHNSON on the amount of money to withdraw, and
14   defendant J. JOHNSON asked for instructions on how to set up account
15   security features.
16        Overt Act No. 63:       On July 24, 2020, defendant MITCHELL, using
17   an EDD debit card ending in 3349, issued in the name of victim
18   M.C.B., withdrew $1,000 from a Bank of America ATM in Torrance,
19   California.
20        Overt Act No. 64:       On July 25, 2020, coconspirators
21   electronically filed an application for pandemic assistance benefits
22   in the name of victim M.J.W., using PII in defendant K. KING’s
23   notebooks.
24        Overt Act No. 65:       On July 26, 2020, coconspirators
25   electronically filed an application for pandemic assistance benefits
26   in the name of victim M.Si., using PII in defendant K. KING’s
27   notebooks.
28
                                            15
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 16 of 38 Page ID #:96



 1        Overt Act No. 66:       On July 26, 2020, defendant DEMOLA emailed

 2   defendant PLUMMER several usernames and passwords for EDD debit

 3   accounts, including the account relating to victim D.F.

 4        Overt Act No. 67:       On July 27, 2020, defendant DEMOLA emailed

 5   defendant PLUMMER usernames and passwords for EDD debit accounts.
 6        Overt Act No. 68:       On July 30, 2020, defendant DEMOLA emailed
 7   defendant PLUMMER usernames and passwords for EDD debit accounts,
 8   including the accounts relating to victims D.F. and M.D.S.
 9        Overt Act No. 69:      On August 2, 2020, defendant DAVIS, using an
10   EDD debit card ending in 5658, issued in the name of victim A.M.P.,
11   withdrew $1,000 from a Bank of America ATM in Inglewood, California.
12        Overt Act No. 70:      On August 2, 2020, defendant DAVIS, using an
13   EDD debit card ending in 6256, issued in the name of victim T.R.S.,
14   withdrew $1,000 from a Bank of America ATM in Victorville,
15   California.
16        Overt Act No. 71:      On August 2, 2020, defendant DAVIS, using an
17   EDD debit card ending in 5325, issued in the name of victim D.M.B.,
18   withdrew $1,000 from a Bank of America ATM in Victorville,
19   California.
20        Overt Act No. 72:      On August 2, 2020, defendant DAVIS, using an
21   EDD debit card ending in 4935, issued in the name of victim M.P.,
22   withdrew $1,000 from a Bank of America ATM in Victorville,
23   California.
24        Overt Act No. 73:       On August 4, 2020, coconspirators
25   electronically filed an application for pandemic assistance benefits
26   in the name of victim S.M., an inmate in the CDCR prison system,
27   which was approved.
28
                                            16
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 17 of 38 Page ID #:97



 1        Overt Act No. 74:       On August 4, 2020, defendant DAVIS, using an

 2   EDD debit card ending in 4935, issued in the name of victim M.P.,

 3   withdrew $1,000 from a Bank of America ATM in Los Angeles,

 4   California.

 5        Overt Act No. 75:       On August 4, 2020, defendant DAVIS, using an

 6   EDD debit card ending in 4078, issued in the name of victim I.T.C.,
 7   withdrew $1,000 from a Bank of America ATM in Los Angeles,
 8   California.
 9        Overt Act No. 76:       On August 4, 2020, defendant DAVIS, using an
10   EDD debit card ending in 5325, issued in the name of victim D.M.B.,
11   withdrew $1,000 from a Bank of America ATM in Los Angeles,
12   California.
13        Overt Act No. 77:       On August 4, 2020, coconspirators
14   electronically filed an application for pandemic assistance benefits
15   in the name of victim C.M.G., an inmate within the CDCR prison
16   system, which was approved.
17        Overt Act No. 78:       On August 4, 2020, coconspirators
18   electronically filed an application for pandemic assistance benefits
19   in the name of victim R.J., an inmate within the CDCR prison system,
20   which was approved.
21        Overt Act No. 79:       On August 5, 2020, defendant DAVIS, using an
22   EDD debit card ending in 4935, issued in the name of victim M.P.,
23   withdrew $1,000 from a Bank of America ATM in Los Angeles,
24   California.
25        Overt Act No. 80:       On August 5, 2020, defendant DAVIS, using an
26   EDD debit card ending in 5325, issued in the name of victim D.M.B.,
27   withdrew $1,000 from a Bank of America ATM in Los Angeles,
28   California.
                                            17
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 18 of 38 Page ID #:98



 1        Overt Act No. 81:       On August 6, 2020, defendant DAVIS, using an

 2   EDD debit card ending in 6256, issued in the name of victim T.R.S.,

 3   withdrew $1,000 from a Bank of America ATM in El Segundo, California.

 4        Overt Act No. 82:       On August 6, 2020, defendant DAVIS using an

 5   EDD debit card ending in 6041, issued in the name of victim T.K.J.,
 6   withdrew $500 from a Bank of America ATM in El Segundo, California.
 7        Overt Act No. 83:       On August 6, 2020, defendant DAVIS, using an
 8   EDD debit card ending in 5325, issued in the name of victim D.M.B.,
 9   withdrew $1,000 from a Bank of America ATM in Los Angeles,
10   California.
11        Overt Act No. 84:       On August 7, 2020, defendant ROBERTSON,
12   using an EDD debit card ending in number 4502, issued in the name of
13   victim D.D.J., withdrew $1,000 from a Bank of America ATM in Downey,
14   California.
15        Overt Act No. 85:       On August 7, 2020, defendant ROBERTSON,
16   using an EDD debit card ending in number 6350, issued in the name of
17   victim A.A.M., withdrew $1,000 from a Bank of America ATM in Downey,
18   California.
19        Overt Act No. 86:       On August 7, 2020, defendant ROBERTSON,
20   using an EDD debit card ending in number 8064, issued in the name of
21   victim K.S., withdrew $1,000 from a Bank of America ATM in Downey,
22   California.
23        Overt Act No. 87:       On August 8, 2020, coconspirators
24   electronically filed an application for pandemic assistance benefits
25   in the name of victim R.M.W., using PII in defendant K. KING’s
26   notebooks.
27        Overt Act No. 88:       On August 8, 2020, defendant PLUMMER, using
28   an EDD debit card ending in 4078, issued in the name of victim
                                            18
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 19 of 38 Page ID #:99



 1   I.T.C., withdrew $1,000 from a Bank of America ATM in Los Angeles,

 2   California.

 3        Overt Act No. 89:       On August 9, 2020, coconspirators

 4   electronically filed an application for pandemic assistance benefits
 5   in the name of victim R.J.W., using PII in defendant K. KING’s
 6   notebooks.
 7        Overt Act No. 90:       On August 13, 2020, coconspirators
 8   electronically filed an application for pandemic assistance benefits
 9   in the name of victim S.R.S., using PII in defendant K. KING’s
10   notebooks.
11        Overt Act No. 91:       On August 13, 2020, coconspirators
12   electronically filed an application for pandemic assistance benefits
13   in the name of victim N.T.S., using PII in defendant K. KING’s
14   notebooks.
15        Overt Act No. 92:       On August 13, 2020, defendant P. JOHNSON,
16   using an EDD debit card ending in 5617, issued in the name of victim
17   S.M., withdrew $900 from a Bank of America ATM in Gardena,
18   California.
19        Overt Act No. 93:       On August 14, 2020, coconspirators
20   electronically filed an application for pandemic assistance benefits
21   in the name of victim D.S.S., which was approved.
22        Overt Act No. 94:       On August 15, 2020, coconspirators
23   electronically filed an application for pandemic assistance benefits
24   in the name of victim S.N.W., using PII in defendant K. KING’s
25   notebooks.
26        Overt Act No. 95:       On August 15, 2020, coconspirators
27   electronically filed an application for pandemic assistance benefits
28
                                            19
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 20 of 38 Page ID #:100



 1   in the name of victim J.S., using PII in defendant K. KING’s

 2   notebooks.

 3         Overt Act No. 96:      On August 16, 2020, defendant PLUMMER, using

 4   an EDD debit card ending in 1245, issued in the name of victim G.G.,
 5   withdrew $1,000 from a Bank of America ATM in Victorville,
 6   California.
 7         Overt Act No. 97:      On August 18, 2020, coconspirators
 8   electronically filed an application for pandemic assistance benefits
 9   in the name of victim O.D.S., using PII in defendant K. KING’s
10   notebooks.
11         Overt Act No. 98:      On August 18, 2020, defendant C. JOHNSON,
12   using an EDD debit card ending in 4935, issued in the name of victim
13   M.P., withdrew $500 from a Bank of America ATM in Hawthorne,
14   California.
15         Overt Act No. 99:      On August 18, 2020, coconspirators
16   electronically filed an application for pandemic assistance benefits
17   in the name of victim D.Fo., an inmate within the CDCR prison system,
18   which was approved.
19         Overt Act No. 100:     On August 18, 2020, coconspirators
20   electronically filed an application for pandemic assistance benefits
21   in the name of victim T.A.W., an inmate within the CDCR prison
22   system, which was approved.
23         Overt Act No. 101:     On August 20, 2020, defendant C. JOHNSON,
24   using an EDD debit card ending in 4935, issued in the name of victim
25   M.P., withdrew $1,000 from a Bank of America ATM in Hawthorne,
26   California.
27         Overt Act No. 102:     On or before August 20, 2020, defendants
28   PLUMMER and C. JOHNSON purchased from T-Mobile cell phones that
                                            20
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 21 of 38 Page ID #:101



 1   defendants used to store and access fraudulent EDD account

 2   information.

 3         Overt Act No. 103:     On August 21, 2020, coconspirators

 4   electronically filed an application for pandemic assistance benefits
 5   in the name of victim B.S., using PII in defendant K. KING’s
 6   notebooks.
 7         Overt Act No. 104:     On August 21, 2020, Coconspirator 2, using
 8   an EDD debit card ending in number 4935, issued in the name of victim
 9   M.P., withdrew $650 from a Bank of America ATM in Los Angeles,
10   California.
11         Overt Act No. 105:     On August 23, 2020, defendant PACE, using an
12   EDD debit card ending in 0241, a replacement card issued in the name
13   of victim M.D.J., withdrew $800 from a Bank of America ATM in Los
14   Angeles, California.
15         Overt Act No. 106:     On August 24, 2020, coconspirators
16   electronically filed an application for pandemic assistance benefits
17   in the name of victim D.L.S., using PII in defendant K. KING’s
18   notebooks.
19         Overt Act No. 107:     On August 24, 2020, defendant PLUMMER, using
20   an EDD debit card ending in number 3004, issued in the name of victim
21   N.M.S., withdrew $1,000 from a Bank of America ATM in Los Angeles,
22   California.
23         Overt Act No. 108:     On August 25, 2020, coconspirators
24   electronically filed an application for pandemic assistance benefits
25   in the name of victim R.L.S., using PII in defendant K. KING’s
26   notebooks.
27         Overt Act No. 109:     On August 25, 2020, defendant PLUMMER, using
28   an EDD debit card ending in 6256, issued in the name of victim
                                            21
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 22 of 38 Page ID #:102



 1   T.R.S., withdrew $1,000 from a Bank of America ATM in Apple Valley,

 2   California.

 3         Overt Act No. 110:     On August 26, 2020, coconspirators

 4   electronically filed an application for pandemic assistance benefits
 5   in the name of victim M.A.W., using PII in defendant K. KING’s
 6   notebooks.
 7         Overt Act No. 111:     On August 26, 2020, coconspirators
 8   electronically filed an application for pandemic assistance benefits
 9   in the name of victim D.J.S., using PII in defendant K. KING’s
10   notebooks.
11         Overt Act No. 112:     On August 26, 2020, coconspirators
12   electronically filed an application for pandemic assistance benefits
13   in the name of victim W.J.S., using PII in defendant K. KING’s
14   notebooks.
15         Overt Act No. 113:     On August 27, 2020, defendant F. KING, using
16   an EDD debit card ending in 6127, issued in the name of victim D.Fo.,
17   an inmate in the CDCR prison system, withdrew $1,000 from a Bank of
18   America ATM in Los Angeles, California.
19         Overt Act No. 114:     On August 31, 2020, defendant WADE, using an
20   EDD debit card ending in number 7456, issued in the name of victim
21   N.T.S., withdrew $1,000 from a Bank of America ATM in Palmdale,
22   California.
23         Overt Act No. 115:     On September 1, 2020, defendant C. JOHNSON,
24   using an EDD debit card ending in number 4935, issued in the name of
25   victim M.P., withdrew $1,000 from a Bank of America ATM in Los
26   Angeles, California.
27         Overt Act No. 116:     On September 2, 2020, defendant F. KING,
28   using an EDD debit card ending in 6127, issued in the name of victim
                                            22
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 23 of 38 Page ID #:103



 1   D.Fo., an inmate in the CDCR prison system, withdrew $1,000 from a

 2   Bank of America ATM in Bell, California.

 3         Overt Act No. 117:     On September 2, 2020, defendant F. KING,

 4   using an EDD debit card ending in 5884, issued in the name of victim
 5   T.A.W., withdrew $1,000 from a Bank of America ATM in South Gate,
 6   California.
 7         Overt Act No. 118:     On September 5, 2020, defendant K. KING,
 8   using an EDD debit card ending in number 5755, issued in the name of
 9   victim P.G.W., withdrew $1,003 from a Wells Fargo ATM in Los Angeles,
10   California.
11         Overt Act No. 119:     On September 6, 2020, defendant K. KING,
12   using an EDD debit card ending in number 9562, issued in the name of
13   victim J.J.W., withdrew $803 from a Wells Fargo ATM in Westchester,
14   California.
15         Overt Act No. 120:     On September 6, 2020, defendant K. KING,
16   using an EDD debit card ending in number 7371, issued in the name of
17   victim L.Si., withdrew $1,003 from a Wells Fargo ATM in Hawthorne,
18   California.
19         Overt Act No. 121:     On September 6, 2020, defendant F. KING,
20   using an EDD debit card ending in 1277, issued in the name of victim
21   D.S.S., withdrew $1,000 from a Bank of America ATM in Lakewood,
22   California.
23         Overt Act No. 122:     On September 6, 2020, Coconspirator 3, using
24   an EDD debit card ending in number 6127, issued in the name of victim
25   D.Fo., withdrew $1,000 from a Bank of America ATM in Lancaster,
26   California.
27         Overt Act No. 123:     On September 6, 2020, defendants K. KING and
28   C. JOHNSON possessed EDD mail addressed to victims, and EDD debit
                                            23
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 24 of 38 Page ID #:104



 1   cards issued to victims, including EDD debit cards issued in the

 2   names of victims S.M., C.M.G., R.J.W., S.R.S., and M.P.

 3         Overt Act No. 124:     On September 6, 2020, defendant K. KING and

 4   C. JOHNSON possessed two notebooks containing 98 PII profiles,
 5   including victims’ names, dates of birth, and social security
 6   numbers.
 7         Overt Act No. 125:     On September 6, 2020, defendants K. KING and
 8   C. JOHNSON possessed cell phones that they used to store fraudulent
 9   EDD pandemic benefits account information.
10         Overt Act No. 126:     On September 6, 2020, in a hotel room,
11   defendants K. KING and C. JOHNSON possessed EDD mail addressed to
12   victims and an EDD debit card in the name of victim S.W.
13         Overt Act No. 127:     On September 7, 2020, Coconspirator 3, using
14   an EDD debit card ending in number 6127, issued in the name of victim
15   D.Fo., withdrew $1,000 from a Bank of America ATM in Lancaster,
16   California.
17         Overt Act No. 128:     On September 7, 2020, defendant WADE using
18   an EDD debit card ending in number 7456, issued in the name of victim
19   N.T.S., withdrew $1,000 from a Bank of America ATM in Palmdale,
20   California.
21         Overt Act No. 129:     On September 9, 2020, defendant F. KING,
22   using an EDD debit card ending in number 1277, issued in the name of
23   victim D.S.S., withdrew $1,000 from a Bank of America ATM in Los
24   Angeles, California.
25         Overt Act No. 130:     On September 10, 2020, defendant F. KING,
26   using an EDD debit card ending in 5561, issued in the name of victim
27   R.J., withdrew $200 from a Bank of America ATM in Gardena,
28   California.
                                            24
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 25 of 38 Page ID #:105



 1         Overt Act No. 131:     On September 13, 2020, defendant F. KING,

 2   using an EDD debit card ending in 1277, issued in the name of victim

 3   D.S.S., withdrew $1,000 from a Bank of America ATM in Los Angeles,

 4   California.

 5         Overt Act No. 132:     On September 15, 2020, defendant C. JOHNSON,

 6   using an EDD debit card ending in 6078, issued in the name of victim
 7   A.R.C., withdrew $1,000 from a Bank of America ATM in Marina Del Rey,
 8   California.
 9         Overt Act No. 133:     On September 16, 2020, defendant C. JOHNSON,
10   using an EDD debit card ending in 6078, issued in the name of victim
11   A.R.C., withdrew $1,000 from a Bank of America ATM in Los Angeles,
12   California.
13         Overt Act No. 134:     On September 20, 2020, defendant F. KING,
14   using an EDD debit card ending in 6127, issued in the name of victim
15   D.Fo., withdrew $1,000 from a Bank of America ATM in Los Angeles,
16   California.
17         Overt Act No. 135:     On September 25, 2020, defendant WADE, using
18   an EDD debit card ending in number 7456, issued in the name of victim
19   N.T.S., withdrew $1,000 from a Bank of America ATM in Palmdale,
20   California.
21         Overt Act No. 136:     On September 27, 2020, defendant C. JOHNSON,
22   using an EDD debit card ending in 6078, issued in the name of victim
23   A.R.C., withdrew $1,000 from a Bank of America ATM in Los Angeles,
24   California.
25         Overt Act No. 137:     On October 5, 2020, defendant PLUMMER, using
26   an EDD debit card ending in 9830, issued in the name of victim
27   S.M.R., withdrew $320 from a Bank of America ATM in Apple Valley,
28   California.
                                            25
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 26 of 38 Page ID #:106



 1         Overt Act No. 138:     On October 7, 2020, Coconspirator 4, using

 2   an EDD debit card ending in number 8908, issued in the name of victim

 3   A.M.S., withdrew $900 from a Bank of America ATM in Van Nuys,

 4   California.

 5         Overt Act No. 139:     On October 11, 2020, defendant F. KING,

 6   using an EDD debit card ending in 5561, issued in the name of victim
 7   R.J., withdrew $360 from a Bank of America ATM in Los Angeles,
 8   California.
 9         Overt Act No. 140:     On October 12, 2020, defendant PACE, using
10   an EDD debit card ending in 0241, a replacement card issued in the
11   name of victim M.D.J., withdrew $1,000 from a Bank of America ATM in
12   Gardena, California.
13         Overt Act No. 141:     On October 12, 2020, defendant PLUMMER,
14   using an EDD debit card ending in number 6320, issued in the name of
15   victim F.S., withdrew $1,000 from a Bank of America ATM in
16   Victorville, California.
17         Overt Act No. 142:     On October 13, 2020, defendant PLUMMER,
18   using an EDD debit card ending in number 6256, issued in the name of
19   victim T.R.S., withdrew $900 from a Bank of America ATM in
20   Victorville, California.
21         Overt Act No. 143:     On October 14, 2020, Coconspirator 2, using
22   an EDD debit card ending in number 6078, issued in the name of victim
23   A.R.C., withdrew $500 from a Bank of America ATM in Los Angeles,
24   California.
25         Overt Act No. 144:     On October 16, 2020, defendant C. JOHNSON,
26   using an EDD debit card ending in 6078, issued in the name of victim
27   A.R.C., withdrew $1,000 from a Bank of America ATM in Los Angeles,
28   California.
                                            26
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 27 of 38 Page ID #:107



 1         Overt Act No. 145:     On October 16, 2020, defendant PLUMMER,

 2   using an EDD debit card ending in 8881, issued in the name of

 3   defendant DEMOLA, withdrew $1,000 from a Bank of America ATM in

 4   Victorville, California.

 5         Overt Act No. 146:     On October 23, 2020, defendant PLUMMER,

 6   using an EDD debit card ending in 8881, issued in the name of
 7   defendant DEMOLA, withdrew $880 from a Bank of America ATM in
 8   Victorville, California.
 9         Overt Act No. 147:     On October 27, 2020, Coconspirator 4, using
10   an EDD debit card ending in number 8908, issued in the name of victim
11   A.M.S., withdrew $900 from a Bank of America ATM in Van Nuys,
12   California.
13         Overt Act No. 148:     On November 7, 2020, Coconspirator 4, using
14   an EDD debit card ending in number 8908, issued in the name of victim
15   A.M.S., withdrew $900 from a Bank of America ATM in Van Nuys,
16   California.
17         Overt Act No. 149:     On December 22, 2020, defendant MARTIN
18   received EDD mail addressed to victim K.S.R.
19         Overt Act No. 150:     On April 12, 2021, defendant MARTIN received
20   EDD mail addressed to victim M.M.
21

22

23

24

25

26

27

28
                                            27
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 28 of 38 Page ID #:108



 1                           COUNTS TWO THROUGH THIRTY-TWO

 2                        [18 U.S.C. §§ 1344(2), 2(a), 2(b)]

 3                                  [ALL DEFENDANTS]

 4         13.   The Grand Jury re-alleges paragraphs 1 through 9, 11, and

 5   12 of this Indictment here.

 6   A.    THE SCHEME TO DEFRAUD

 7         14.   Beginning on a date unknown to the Grand Jury, but no later
 8   than in or around June 2020, and continuing until in or around April
 9   2021, in Los Angeles, Riverside, Ventura, and San Bernardino
10   Counties, within the Central District of California, and elsewhere,
11   defendants NATALIE LE DEMOLA (“DEMOLA”), CARLEISHA NEOSHA PLUMMER,
12   also known as (“aka”) “LG” (“PLUMMER”), KHANSHANDA EUGENA KING, aka
13   “Cassandra King” (“K. KING”), aka “Cassandra King,” CLESHAY JOHNSON
14   II (“C. JOHNSON”), JAMES ANTONIO JOHNSON, aka “Niddy Johnson,” aka
15   “Big Dawg Niddy,” aka “Niddy” (“J. JOHNSON”), FELICITE ALEISHA KING
16   (“F. KING”), SHAFEQUAH LYNETE MITCHELL (“MITCHELL”), LORESHA SHAMONE
17   DAVIS (“DAVIS”), PORSHA LATRICE JOHNSON (“P. JOHNSON”), DONISHA
18   LASHAWN PACE (“PACE”), DOMINIQUE CHARMONE MARTIN (“MARTIN”), MYKARA
19   DESTINY ROBERTSON (“ROBERTSON”), and AMBER JANE WADE (“WADE”),
20   together with others known and unknown to the Grand Jury, knowingly
21   and with intent to defraud, devised, participated in, and executed a
22   scheme to obtain moneys, funds, credits, assets, and other property
23   owned by and in the custody and control of federally-insured
24   financial institutions by means of material false and fraudulent
25   pretenses, representations, and promises, and the concealment of
26   material facts.
27         15.   The fraudulent scheme operated and was carried out, in
28   substance, as described in paragraph 11 of this Indictment.
                                            28
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 29 of 38 Page ID #:109



 1   B.      EXECUTIONS OF THE SCHEME

 2           16.   On or about the following dates, in Los Angeles, Riverside,

 3   Ventura, and San Bernardino Counties, within the Central District of

 4   California, and elsewhere, defendants DEMOLA, PLUMMER, K. KING,

 5   C. JOHNSON, J. JOHNSON, F. KING, MITCHELL, DAVIS, P. JOHNSON, PACE,

 6   MARTIN, ROBERTSON, and WADE, together with others known and unknown

 7   to the Grand Jury, aiding and abetting each other, committed and

 8   willfully caused others to commit the following acts, each of which

 9   constituted an execution of the fraudulent scheme:

10    COUNT            DEFENDANT(S)    DATE                ACT
11    TWO              MARTIN          June 24, 2020       Use of an EDD debit
                                                           card ending in 9975
12                                                         issued in the name of
                                                           K.S.R, at Chase to
13                                                         withdraw $503, in
                                                           Yucaipa, California.
14
      THREE            DEMOLA;         July 10, 2020       Use of an EDD debit
15                     J. JOHNSON;                         card ending in 1940,
                       MARTIN                              issued in the name of
16                                                         M.D.S., at Bank of
                                                           America to withdraw
17                                                         $1,000, in Wilmington,
                                                           California.
18
      FOUR             DEMOLA;         July 11, 2020       Use of an EDD debit
19                     J. JOHNSON                          card ending in 6137,
                                                           issued in the name of
20                                                         D.F., at Bank of
                                                           America to withdraw
21                                                         $1,000, in Wilmington,
                                                           California.
22
      FIVE             MITCHELL        July 14, 2020       Use of an EDD debit
23                                                         card ending in 0868,
                                                           issued in the name of
24                                                         M.D.J., at Bank of
                                                           America to withdraw
25                                                         $1,000, in Gardena,
                                                           California.
26

27

28
                                              29
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 30 of 38 Page ID #:110



 1    COUNT           DEFENDANT(S)     DATE                ACT
 2    SIX             MITCHELL         July 14, 2020       Use of an EDD debit
                                                           card ending in 8064,
 3                                                         issued in the name of
                                                           K.S., at Bank of
 4                                                         America to withdraw
                                                           $1,000, in Gardena,
 5                                                         California.
 6    SEVEN           DEMOLA;          July 15, 2020       Use of an EDD debit
                      J. JOHNSON                           card ending in 6137,
 7                                                         issued in the name of
                                                           D.F., at Bank of
 8                                                         America to withdraw
                                                           $1,000, in Wilmington,
 9                                                         California.
10    EIGHT           MITCHELL         July 20, 2020       Use of an EDD debit
                                                           card ending in 6350,
11                                                         issued in the name of
                                                           A.A.M., at Bank of
12                                                         America to withdraw
                                                           $1,000, in Walnut
13                                                         Park, California.
14    NINE            DAVIS            August 2, 2020      Use of an EDD debit
                                                           card ending in 5325,
15                                                         issued in the name of
                                                           D.M.B., at Bank of
16                                                         America to withdraw
                                                           $1,000, in
17                                                         Victorville,
                                                           California.
18

19    TEN             DAVIS            August 2, 2020      Use of an EDD debit
                                                           card ending in 4935,
20                                                         issued in the name of
                                                           M.P., at Bank of
21                                                         America to withdraw
                                                           $1,000, in
22                                                         Victorville,
                                                           California.
23
      ELEVEN          DAVIS            August 2, 2020      Use of an EDD debit
24                                                         card ending in 6256,
                                                           issued in the name of
25                                                         T.R.S., at Bank of
                                                           America to withdraw
26                                                         $1,000, in
                                                           Victorville,
27                                                         California.

28
                                              30
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 31 of 38 Page ID #:111



 1    COUNT           DEFENDANT(S)     DATE                ACT
 2    TWELVE          ROBERTSON        August 7, 2020      Use of an EDD debit
                                                           card ending in 4502,
 3                                                         issued in the name of
                                                           D.D.J., at Bank of
 4                                                         America to withdraw
                                                           $1,000, in Downey,
 5                                                         California.
 6    THIRTEEN        ROBERTSON        August 7, 2020      Use of an EDD debit
                                                           card ending in 6350,
 7                                                         issued in the name of
                                                           A.A.M., at Bank of
 8                                                         America to withdraw
                                                           $1,000, in Downey,
 9                                                         California.
10    FOURTEEN        ROBERTSON        August 7, 2020      Use of an EDD debit
                                                           card ending in 8064,
11                                                         issued in the name of
                                                           K.S., at Bank of
12                                                         America to withdraw
                                                           $1,000, in Downey,
13                                                         California.
14    FIFTEEN         P. JOHNSON       August 13, 2020     Use of an EDD debit
                                                           card ending in 5617,
15                                                         issued in the name of
                                                           S.M., at Bank of
16                                                         America to withdraw
                                                           $900, in Gardena,
17                                                         California.
18
      SIXTEEN         C. JOHNSON       August 18, 2020     Use of an EDD debit
19                                                         card ending in 4935,
                                                           issued in the name of
20                                                         M.P., at Bank of
                                                           America to withdraw
21                                                         $500, in Hawthorne,
                                                           California.
22
      SEVENTEEN       PACE             August 23, 2020     Use of an EDD debit
23                                                         card ending in 0241,
                                                           issued in the name of
24                                                         M.D.J., at Bank of
                                                           America to withdraw
25                                                         $800, in Los Angeles,
                                                           California.
26

27

28
                                              31
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 32 of 38 Page ID #:112



 1    COUNT           DEFENDANT(S)     DATE                ACT
 2    EIGHTEEN        PLUMMER          August 24, 2020     Use of an EDD debit
                                                           card ending in 3004,
 3                                                         issued in the name of
                                                           N.M.S., at Bank of
 4                                                         America to withdraw
                                                           $1,000, in Los
 5                                                         Angeles, California.
      NINETEEN        WADE             August 31, 2020     Use of an EDD debit
 6                                                         card ending in 7456,
                                                           issued in the name of
 7                                                         N.T.S., at Bank of
                                                           America to withdraw
 8                                                         $1,000, in Palmdale,
                                                           California.
 9
      TWENTY          C. JOHNSON       September 1,        Use of an EDD debit
10                                     2020                card ending in 4935,
                                                           issued in the name of
11                                                         M.P., at Bank of
                                                           America to withdraw
12                                                         $1,000, in Los
                                                           Angeles, California.
13
      TWENTY-ONE      K. KING          September 5,        Use of an EDD debit
14                                     2020                card ending in 5755,
                                                           issued in the name of
15                                                         P.G.W., at Wells Fargo
                                                           to withdraw $1,003, in
16                                                         Los Angeles,
                                                           California.
17

18    TWENTY-TWO      F. KING          September 6,        Use of an EDD debit
                                       2020                card ending in 1277,
19                                                         issued in the name of
                                                           D.S.S., at Bank of
20                                                         America to withdraw
                                                           $1,000, in Lakewood,
21                                                         California.

22    TWENTY-THREE    K. KING          September 6,        Use of an EDD debit
                                       2020                card ending in 9562,
23                                                         issued in the name of
                                                           J.J.W., at Wells Fargo
24                                                         to withdraw $803, in
                                                           Westchester,
25                                                         California.

26

27

28
                                              32
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 33 of 38 Page ID #:113



 1    COUNT           DEFENDANT(S)     DATE                ACT
 2    TWENTY-FOUR     K. KING          September 6,        Use of an EDD debit
                                       2020                card ending in 7371,
 3                                                         issued in the name of
                                                           L.Si., at Wells Fargo
 4                                                         to withdraw $1,003, in
                                                           Hawthorne, California.
 5
      TWENTY-FIVE     WADE             September 7,        Use of an EDD debit
 6                                     2020                card ending in 7456,
                                                           issued in the name of
 7                                                         N.T.S., at Bank of
                                                           America to withdraw
 8                                                         $1,000, in Palmdale,
                                                           California.
 9
      TWENTY-SIX      F. KING          September 9,        Use of an EDD debit
10                                     2020                card ending in 1277,
                                                           issued in the name of
11                                                         D.S.S., at Bank of
                                                           America to withdraw
12                                                         $1,000, in Los
                                                           Angeles, California.
13
      TWENTY-SEVEN    F. KING          September 10,       Use of an EDD debit
14                                     2020                card ending in 5561,
                                                           issued in the name of
15                                                         R.J., at Bank of
                                                           America to withdraw
16                                                         $1,000, in Gardena,
                                                           California.
17

18    TWENTY-EIGHT    WADE             September 25,       Use of an EDD debit
                                       2020                card ending in 7456,
19                                                         issued in the name of
                                                           N.T.S., at Bank of
20                                                         America to withdraw
                                                           $1,000, in Palmdale,
21                                                         California.

22    TWENTY-NINE     PLUMMER          October 12,         Use of an EDD debit
                                       2020                card ending in 6320,
23                                                         issued in the name of
                                                           F.S., at Bank of
24                                                         America to withdraw
                                                           $1,000, in
25                                                         Victorville,
                                                           California.
26

27

28
                                              33
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 34 of 38 Page ID #:114



 1    COUNT           DEFENDANT(S)     DATE                ACT
 2    THIRTY          PACE             October 12,         Use of an EDD debit
                                       2020                card ending in 0241,
 3                                                         issued in the name of
                                                           M.D.J., at Bank of
 4                                                         America to withdraw
                                                           $1,000, in Gardena,
 5                                                         California.
 6    THIRTY-ONE      PLUMMER          October 13,         Use of an EDD debit
                                       2020                card ending in 6256,
 7                                                         issued in the name of
                                                           T.R.S., at Bank of
 8                                                         America to withdraw
                                                           $900, in Victorville,
 9                                                         California.
10    THIRTY-TWO      C. JOHNSON       October 16,         Use of an EDD debit
                                       2020                card ending in 6078,
11                                                         issued in the name of
                                                           A.R.C., at Bank of
12                                                         America to withdraw
                                                           $1,000, in Los
13                                                         Angeles, California.
14

15

16

17

18

19

20

21

22

23

24

25

26

27

28
                                              34
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 35 of 38 Page ID #:115



 1                     COUNTS THIRTY-THREE THROUGH THIRTY-NINE

 2                         [18 U.S.C. §§ 1028A(a)(1), 2(b)]

 3    [DEFENDANTS DEMOLA, PLUMMER, K. KING, F. KING, MITCHELL, P. JOHNSON,

 4                                     AND MARTIN]

 5         17.   The Grand Jury re-alleges paragraphs 1 through 9 and 11 of

 6   this Indictment here.

 7         18.   Beginning no later than in or around June 2020, and

 8   continuing until in or around April 2021, in Los Angeles, Riverside,

 9   Ventura, and San Bernardino Counties, within the Central District of

10   California, and elsewhere, defendants NATALIE LE DEMOLA (“DEMOLA”),

11   CARLEISHA NEOSHA PLUMMER, also known as “LG” (“PLUMMER”), KHANSHANDA

12   EUGENA KING, aka “Cassandra King” (“K. KING”), FELICITE ALEISHA KING

13   (“F. KING”), SHAFEQUAH LYNETE MITCHELL (“MITCHELL”), PORSHA LATRICE

14   JOHNSON (“P. JOHNSON”), and DOMINIQUE CHARMONE MARTIN (“MARTIN”), on

15   or about the following dates, knowingly transferred, possessed, and

16   used, and willfully caused to be transferred, possessed, and used,

17   without lawful authority, means of identification that defendants

18   knew belonged to other persons, namely, the names and EDD Bank of

19   America account numbers of the individuals identified below, during

20   and in relation to conspiracy to commit wire fraud and bank fraud, a

21   felony violation of Title 18, United States Code, Section 1349, as

22   charged in Count One of this Indictment.

23    COUNT            DEFENDANT      DATE RANGE        MEANS OF IDENTIFICATION
24    THIRTY-THREE     DEMOLA         6/23/2020 to      Names and EDD Bank of
                                      7/18/2020         America account numbers
25                                                      in the names of M.D.S.
                                                        and D.F.
26

27

28
                                            35
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 36 of 38 Page ID #:116



 1    COUNT            DEFENDANT      DATE RANGE        MEANS OF IDENTIFICATION
 2    THIRTY-FOUR      PLUMMER        8/8/2020 to       Names and EDD Bank of
                                      10/23/2020        America account numbers
 3                                                      in the names of N.M.S.,
                                                        F.S., T.R.S., and
 4                                                      defendant DEMOLA
 5    THIRTY-FIVE      K. KING        9/4/2020 to       Names and EDD Bank of
                                      9/6/2020          America account numbers
 6                                                      in the names of P.G.W.,
                                                        J.J.W., and L.Si.
 7
      THIRTY-SIX       F. KING        7/16/2020 to      Names and EDD Bank of
 8                                    10/11/2020        America account numbers
                                                        in the names of D.S.S.,
 9                                                      R.J., and defendant K.
                                                        KING
10
      THIRTY-SEVEN     MITCHELL       6/27/2020 to      Names and EDD Bank of
11                                    7/20/20           America account numbers
                                                        in the names of M.D.J.,
12                                                      K.S., A.A.M., and
                                                        defendant PLUMMER
13

14    THIRTY-EIGHT     P. JOHNSON     7/23/2020 to      Names and EDD Bank of
                                      8/13/2020         America account numbers
15                                                      in the names of S.M. and
                                                        defendant K. KING
16
      THIRTY-NINE      MARTIN         6/24/2020 to      Names and EDD Bank of
17                                    7/14/2020         America account numbers
                                                        in the names of K.S.R.
18                                                      and M.D.S.

19

20

21

22

23

24

25

26

27

28
                                            36
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 37 of 38 Page ID #:117



 1                               FORFEITURE ALLEGATION

 2                                  [18 U.S.C. § 982]

 3         1.    Pursuant to Rule 32.2(a) 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 982(a)(2), in the event of any

 7   defendant’s conviction of the offenses set forth in any of Counts One

 8   through Thirty Nine of this Indictment.

 9         2.    Any defendant so convicted shall forfeit to the United

10   States of America the following:

11               (a) All right, title and interest in any and all property,

12   real or personal, constituting, or derived from, any proceeds

13   obtained, directly or indirectly, as a result of the offense; and

14               (b) To the extent such property is not available for

15   forfeiture, a sum of money equal to the total value of the property

16   described in subparagraph (a).

17         3.    Pursuant to Title 21, United States Code, Section 853(p),

18   as incorporated by Title 18, United States Code, Section 982(b), any

19   defendant so convicted shall forfeit substitute property, up to the

20   total value of the property described in the preceding paragraph if,

21   as the result of any act or omission of said defendant, the property

22   described in the preceding paragraph, or any portion thereof: (a)

23   cannot be located upon the exercise of due diligence; (b) has been

24   transferred, sold to or deposited with a third party; (c) has been

25   placed beyond the jurisdiction of the court; (d) has been

26   //

27   //

28   //
                                            37
     Case 2:22-cr-00205-JFW Document 17 Filed 05/12/22 Page 38 of 38 Page ID #:118



 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
                                                        /S/
                                                 Foreperson
 7

 8    TRACY L. WILKISON
      United States Attorney
 9

10

11    SCOTT M. GARRINGER
      Assistant United States Attorney
12    Chief, Criminal Division

13    JOSHUA O. MAUSNER
      Assistant United States Attorney
14    Deputy Chief, General Crimes
      Section
15
      GREGORY BERNSTEIN
16    Assistant United States Attorney
      Major Frauds Section
17

18

19

20

21

22

23

24

25

26

27

28

                                            38


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