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Indictment — United States v. Robert Campbell, Jr., et al., Central District of California (Document 1)

Summary

An indictment returned by the March 2022 Grand Jury in United States of America v. Robert Campbell, Jr., Regjinay Tate, Shelbi Dupree, Greg Henderson, Brandon Gully, Simone Gueringer, Dillon Roberts and Keith Burns, Case 5:22-cr-00150-JGB, in the U.S. District Court for the Central District of California, filed June 23, 2022 as Document 1. It cites 18 U.S.C. § 1349, 18 U.S.C. § 1341 and 18 U.S.C. § 1028A(a)(1), and Count One charges all defendants with conspiracy to commit mail fraud in relation to pandemic unemployment benefits. The grand jury alleges that the defendants obtained other people's identifying information and filed EDD applications for Pandemic Unemployment Assistance stating an annual income of $42,000 and false mailing addresses. It alleges approximately 174 fraudulent applications and losses of approximately $2,091,436.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Indictment — United States v. Robert Campbell, Jr., et al., Central District of California (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-5-22-cr-00150-dkt-1-c-d-cal-5b01fafb5d/, SHA-256 d796024d74fd462422dd737c72819c7011b05c263f1e80a8785d9cb38f88c47c.

Full text

      Case 5:22-cr-00150-JGB Document 1 Filed 06/23/22 Page 1 of 18 Page ID #:1




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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    5:22-cr-00150-JGB
12             Plaintiff,                    I N D I C T M E N T
13             v.                            [18 U.S.C. § 1349: Conspiracy to
                                             Commit Mail Fraud in Relation to
14   ROBERT CAMPBELL, JR.,                   Benefits Connected to
       aka “Jacques,”                        Presidentially Declared Emergency;
15   REGJINAY TATE,                          18 U.S.C. § 1341: Mail Fraud in
       aka “Reggie,”                         Relation to Benefits Connected to
16   SHELBI DUPREE,                          Presidentially Declared Emergency;
     GREG HENDERSON,                         18 U.S.C. § 1028A(a)(1):
17   BRANDON GULLY,                          Aggravated Identity Theft;
     SIMONE GUERINGER,                       18 U.S.C. § 982: Criminal
18   DILLON ROBERTS, and                     Forfeiture]
     KEITH BURNS,
19
               Defendants.
20

21        The Grand Jury charges:
22                                     COUNT ONE
23                                [18 U.S.C. § 1349]
24                                 [ALL DEFENDANTS]
25   A.   INTRODUCTORY ALLEGATIONS
26        At times relevant to this Indictment:
27

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      Case 5:22-cr-00150-JGB Document 1 Filed 06/23/22 Page 2 of 18 Page ID #:2




 1        1.   The California Employment Development Department (“EDD”)

 2   administered unemployment insurance (“UI”) benefits for residents of

 3   California, including Pandemic Unemployment Assistance benefits to

 4   individuals who were unemployed because of the COVID-19 pandemic

 5   (“pandemic benefits”).

 6        2.   On March 13, 2020, the President of the United States

 7   declared COVID-19 an emergency under the Robert T. Stafford Disaster

 8   Relief and Emergency Assistance Act.       As a result, Congress passed

 9   the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”),

10   which the President signed into law on March 27, 2020.

11        3.   The CARES Act established a new program -- Pandemic

12   Unemployment Assistance (“PUA”) -- to provide UI benefits during the

13   COVID-19 pandemic to people who did not qualify for regular UI

14   benefits, including business owners, self-employed workers,

15   independent contractors, and those with a limited work history, who

16   were out of business or had significantly reduced their services as a

17   direct result of the pandemic.      UI benefits provided under the PUA

18   program were sometimes referred to as PUA benefits.

19        4.   Under the PUA provisions of the CARES Act, a person who was

20   a business owner, self-employed worker, independent contractor, or

21   gig worker could qualify for PUA benefits administered by EDD if

22   he/she previously performed such work in California and was

23   unemployed, partially unemployed, unable to work, or unavailable to

24   work due to a COVID-19-related reason.

25        5.   A UI claimant could usually collect 26 weeks of regular

26   state UI benefits.    The CARES Act provided for additional Pandemic

27   Emergency Unemployment Compensation (“PEUC”), which provided up to 13

28   weeks of additional payments, for a total of 39 weeks of benefits.
                                     2
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 1   PEUC was available to persons who were fully or partially unemployed

 2   at any time between from March 29, 2020 through December 26, 2020.

 3   Persons with a regular UI claim, a PUA claim or a PEUC extension

 4   filed between March 29, 2020 and July 25, 2020, also received Federal

 5   Pandemic Unemployment Compensation (“FPUC”), which provided an extra

 6   $600 per week.

 7        6.   On August 8, 2020, after FPUC expired, the President signed

 8   a Presidential Memorandum authorizing FEMA to use disaster relief

 9   funds pursuant to Section 408 of the Stafford Act to provide

10   supplemental payments for lost wages to help ease the financial

11   burden on individuals who were unemployed as a result of COVID-19.

12   The “Lost Wages Assistance Program” (“LWAP”) served as a temporary

13   measure to provide an additional $300 per week via a total of $44

14   billion in FEMA funds.     The period of assistance for LWAP was August

15   1, 2020, to December 27, 2020, or termination of the program,

16   whichever was sooner.

17        7.   To qualify for UI benefits, including pandemic benefits, a

18   California resident had to submit to EDD an application for the

19   benefits; provide EDD with personal identifying information (“PII”),

20   including the applicant’s name, date of birth, and Social Security

21   Number; and certify to EDD under the penalties of perjury that the

22   COVID-19 pandemic had directly and adversely affected the applicant’s

23   employment.

24        8.   Persons applying for PUA benefits did not need to submit

25   any supporting documents to EDD with their applications.           Claimants

26   reported their total income for the 2019 calendar year on the

27   application.   The stated income was used to calculate the benefits to

28   be paid, which were at least $167 per week.
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 1        9.    Individuals who were employed, retired, or incarcerated

 2   were not eligible for UI benefits, including pandemic benefits.

 3        10.   Individuals whose claims were not based on California

 4   employment or residence were not eligible for California UI benefits.

 5        11.   Applications for UI benefits, including pandemic benefits,

 6   could be submitted to EDD online.       An individual who applied online

 7   for benefits would provide EDD with an email address (“account email

 8   address”) in addition to the applicant’s physical mailing address

 9   (“account mailing address”).

10        12.   After a person submitted an application for UI benefits,

11   including pandemic benefits, EDD would transmit an email to the

12   account email address confirming the submission of the application

13   and, thereafter, would send correspondence related to the application

14   and the UI benefits, including pandemic benefits, to the account

15   email address.

16        13.   Once approved for pandemic benefits, the recipient of the

17   benefits would be required to periodically recertify under the

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

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

20   eligible to receive pandemic benefits.

21        14.   Once EDD approved the application and granted pandemic

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

23   debit account”) with Bank of America, NA (“Bank of America” or

24   “BofA”).   A debit card linked to the EDD debit account would then be

25   mailed to the account mailing address.

26        15.   EDD would deposit UI benefits, including pandemic benefits,

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

28   withdraw the benefits from the EDD debit account using automated
                                     4
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 1   teller machines (“ATMs”), including ATMs that Bank of America, Wells

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

 3   operated.

 4   B.   OBJECT OF THE CONSPIRACY
 5        16.    Beginning no later than in or around March 2020 and

 6   continuing through at least in or around July 2021, in Los Angeles,

 7   Riverside, and San Bernardino Counties, within the Central District

 8   of California, and elsewhere, defendants ROBERT CAMPBELL, JR., also

 9   known as (“aka”) “Jacques,” REGJINAY TATE, aka “Reggie,” SHELBI

10   DUPREE, GREG HENDERSON, BRANDON GULLY, SIMONE GUERINGER, DILLON

11   ROBERTS, and KEITH BURNS conspired with one another, and with others

12   known and unknown to the Grand Jury, to commit mail fraud in relation

13   to and involving benefits authorized, transported, transmitted,

14   transferred, disbursed, and paid in connection with a presidentially

15   declared major disaster and emergency, namely, the COVID-19 pandemic,

16   in violation of Title 18, United States Code, Section 1341.

17   C.   MANNER AND MEANS OF THE CONSPIRACY
18        17.    The object of the conspiracy was carried out, and was to be

19   carried out, in substance, as follows:

20               a.   Defendants CAMPBELL, TATE, DUPREE, HENDERSON, GULLY,

21   GUERINGER, and ROBERTS, and others known and unknown to the Grand

22   Jury, would acquire the PII, such as the names, dates of birth, and

23   Social Security Numbers, of individuals ineligible for UI benefits

24   and pandemic benefits based on their residency, employment history,

25   and incarceration status.

26               b.   In some instances, to solicit the PII of potential EDD

27   claimants and to gain their trust, defendant TATE would brandish a

28   false credential purporting to establish her employment with EDD and
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 1   falsely claim to be offering assistance to claimants in that capacity

 2   in filing PUA claims.

 3             c.      Defendants CAMPBELL, TATE, DUPREE, HENDERSON, GULLY,

 4   GUERINGER, and ROBERTS, and others known and unknown to the Grand

 5   Jury, would exchange other individuals’ PII over electronic messaging

 6   services, including WhatsApp.

 7             d.      To induce BofA to issue debit cards on behalf of EDD

 8   and cause them to be mailed, defendant CAMPBELL, and others known and

 9   unknown to the Grand Jury, would make fraudulent online applications

10   to EDD for UI benefits, including pandemic benefits funded by LWAP,

11   in the names of those individuals (the “fraudulent EDD

12   applications”).    The fraudulent EDD applications would generally:

13                     i.    falsely state claimants’ prior annual income by

14   asserting an annual income of $42,000 for all claimants regardless of

15   their actual income;

16                     ii.   falsely state that the named claimants were

17   “Unemployed Self-employed Individual[s]” whose employment was

18   negatively affected because “Salons and barbershops closed due to

19   covid19,” when, in truth, the claimants had not worked in salons or

20   barbershops, nor had their employment status been altered by the

21   closure of salons or barbershops; and

22                     iii. falsely state claimants’ mailing addresses by

23   replacing claimants’ true mailing addresses with mailing addresses

24   associated with locations chosen and controlled by defendants

25   CAMPBELL, TATE, DUPREE, GULLY, GUERINGER, and BURNS.

26             e.      Defendants CAMPBELL, TATE, ROBERTS, and BURNS would

27   use the BofA debit cards issued in the names of other claimants in

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 1   response to the fraudulent EDD applications to withdraw funds at

 2   ATMs.

 3                 f.     Defendants ROBERTS and BURNS, along with others known

 4   and unknown to the Grand Jury, arranged for PUA benefits to be

 5   disbursed to claimants living outside California, including in Texas,

 6   by causing some of the fraudulent EDD applications to falsely state

 7   California addresses for such claimants and by causing BofA PUA ATM

 8   cards to be mailed to a Texas address controlled by defendant BURNS.

 9           18.   Through their conspiracy, defendants CAMPBELL, TATE,

10   DUPREE, HENDERSON, GULLY, GUERINGER, ROBERTS, and BURNS, and their

11   co-conspirators, caused approximately 174 fraudulent applications for

12   PUA benefits to be filed with EDD, resulting in at least

13   approximately 125 fraudulent PUA claims being paid to approximately

14   116 unique claimants, causing losses of approximately $2,091,436.

15   D.      OVERT ACTS

16           19.   In furtherance of the conspiracy, and to accomplish its

17   object, defendants CAMPBELL, TATE, DUPREE, HENDERSON, GULLY,

18   GUERINGER, ROBERTS, and BURNS, and others known and unknown to the

19   Grand Jury, committed and willfully caused others to commit, on or

20   about the dates set forth below, the following overt acts, among

21   others, within the Central District of California, and elsewhere:

22           Overt Act No. 1:       On July 2, 2020, defendant CAMPBELL, from

23   his home in Corona, California, caused an online UI application to be

24   filed with EDD in the name of victim-claimant A.W. that: (1) falsely

25   listed CAMPBELL’s mailing address in the place of victim A.W.’s out-

26   of-state mailing address; (2) falsely stated that victim A.W. had an

27   annual income of $42,000; and (3) falsely stated that victim A.W. was

28   unemployed because “salons and barbershops closed due to covid19.”
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 1        Overt Act No. 2:       On July 2, 2020, in an electronic

 2   communication, defendant TATE sent defendant CAMPBELL a message

 3   containing victim-claimant D.L.’s Social Security Number and

 4   birthdate.

 5        Overt Act No. 3:       On July 2, 2020, defendant CAMPBELL, from

 6   his home in Corona, California, caused an online UI application to be

 7   filed with EDD in the name of victim-claimant D.L. that: (1) listed a

 8   false mailing address for victim-claimant D.L.; (2) falsely stated

 9   that victim-claimant D.L. had an annual income of $42,000; and (3)

10   falsely stated that victim-claimant D.L. was unemployed because

11   “salons and barbershops closed due to covid19.”

12        Overt Act No. 4:       On July 15, 2020, in an electronic

13   communication, defendant HENDERSON sent defendant CAMPBELL a message

14   containing the PII (including the name, Social Security Number, and

15   birthdate) of L.J.H.

16        Overt Act No. 5:       On August 7, 2020, in an electronic

17   communication, defendant HENDERSON sent defendant CAMPBELL a message

18   containing the PII (including the name, Social Security Number, and

19   birthdate) of R.S.F.

20        Overt Act No. 6:       On August 13, 2020, in an electronic

21   communication, defendant ROBERTS sent defendant CAMPBELL a message

22   containing the PII (including the name and Social Security Number) of

23   Oregon resident M.R.R.

24        Overt Act No. 7:       On August 14, 2020, defendant CAMPBELL, from

25   his home in Corona, California, caused an online UI application to be

26   filed with EDD in the name of Oregon resident M.R.R. that:

27   (1) falsely stated M.R.R.’s mailing address; (2) falsely stated that

28   M.R.R. had an annual income of $42,000; and (3) falsely stated that
                                     8
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 1   M.R.R. was unemployed because “salons and barbershops closed due to

 2   covid19.”

 3        Overt Act No. 8:       On August 20, 2020, in an electronic

 4   communication, defendant ROBERTS sent defendant CAMPBELL a message

 5   containing the PII (including the name, birthdate, and Social

 6   Security Number) of claimant R.J., a Texas resident.

 7        Overt Act No. 9:       On August 20, 2020, in an electronic

 8   communication, defendant DUPREE sent defendant CAMPBELL a message

 9   containing the PII (including the Social Security Number and

10   birthdate) of J.H., a Texas resident.

11        Overt Act No. 10:      On August 21, 2020, in an electronic

12   communication, defendant CAMPBELL sent defendant DUPREE a message

13   containing an online EDD “confirmation” that the claim made on behalf

14   of J.H. had been “filed.”

15        Overt Act No. 11:      On August 23, 2020, in an electronic

16   communication, defendant CAMPBELL sent defendant ROBERTS a message

17   confirming that defendant CAMPBELL had filed an online UI application

18   with EDD in the name of defendant BURNS, which application: (1)

19   fraudulently replaced defendant BURNS’s true Texas mailing address

20   with defendant GULLY’s California mailing address; (2) falsely stated

21   that defendant BURNS had an annual income of $42,000 derived from his

22   “usual occupation” as a “barber”; and (3) falsely stated that

23   defendant BURNS but was unemployed because “salons and barbershops

24   closed due to covid19.”

25        Overt Act No. 12:      On August 31, 2020, in an electronic

26   communication, defendant CAMPBELL sent defendant GUERINGER a message

27   confirming that CAMPBELL had filed an online UI application with EDD

28   in the name of claimant K.B., which application: (1) stated a false
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 1   mailing address for K.B.; (2) falsely stated that K.B. had an annual

 2   income of $42,000; and (3) falsely stated that K.B. was unemployed

 3   because “salons and barbershops closed due to covid19.”

 4        Overt Act No. 13:      On September 2, 2020, in a series of

 5   electronic communications, defendants CAMPBELL and GUERINGER

 6   discussed passwords for the online EDD profiles of claimants K.B. and

 7   D.W., as well as the false listing of a coconspirator’s mailing

 8   address on both claimants’ applications.

 9        Overt Act No. 14:      On September 3, 2020, in a series of

10   electronic communications, defendant GULLY sent defendant CAMPBELL a

11   message containing the PII (including the name, Social Security

12   Number, and birthdate) of victim M.S.S. for the purpose of causing a

13   fraudulent EDD claim to be filed in M.S.S.’s name and remarked, “Aye

14   my BM [“baby mama”] is ah savage she got ah homeless man info,” to

15   which defendant CAMPBELL responded, “Hell yeah!!!”

16        Overt Act No. 15:      On September 4, 2020, in an electronic

17   communication, defendant CAMPBELL sent defendant GULLY the last four

18   digits of defendant BURNS’s Social Security Number in response to a

19   request from defendant GULLY.

20        Overt Act No. 16:      On October 16, 2020, defendant BURNS used a

21   BofA EDD benefits ATM card in the name of incarcerated Texas claimant

22   A.I. to withdraw $1,000 in cash at a BofA ATM in Humble, Texas.

23        Overt Act No. 17:      On January 11, 2021, in a series of

24   electronic communications, defendant DUPREE notified defendant

25   CAMPBELL that defendant DUPREE was required, in connection with a

26   fraudulent EDD application, to “sign in to something and . . .

27   verifys [sic] your identity,” to which defendant CAMPBELL responded,

28   “My homeboy said try Colorado cause they not doing that verify shit
                                     10
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 1   and it’s a sanction [sic] state so you can have the card delivered

 2   anywhere.”

 3        Overt Act No. 18:      On January 11, 2021, in a series of

 4   electronic communications, defendant DUPREE informed defendant

 5   CAMPBELL that the individuals whose PII defendant DUPREE was using to

 6   submit UI claims were unaware of defendant DUPREE’s use of their PII,

 7   to which defendant CAMPBELL responded, “Lol you’re a fucking crook.”

 8   Defendant DUPREE responded, “Lol haha.”

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

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 1                             COUNTS TWO THROUGH SEVEN

 2                            [18 U.S.C. §§ 1341, 2(a)]

 3                                 [ALL DEFENDANTS]

 4        20.     The Grand Jury realleges paragraphs 1 through 15 and 17 and

 5   18 of this Indictment here.

 6   A.   THE SCHEME TO DEFRAUD

 7        21.     Beginning no later than in or around March 2020 and

 8   continuing through at least in or around July 2021, in Los Angeles,

 9   Riverside, and San Bernardino Counties, within the Central District

10   of California, and elsewhere, defendants ROBERT CAMPBELL, JR., also

11   known as (“aka”) “Jacques,” REGJINAY TATE, aka “Reggie,” SHELBI

12   DUPREE, GREG HENDERSON, BRANDON GULLY, SIMONE GUERINGER, DILLON

13   ROBERTS, and KEITH BURNS, together with others known and unknown to

14   the Grand Jury, each aiding and abetting the other, knowingly and

15   with intent to defraud, devised, participated in, and executed a

16   scheme to defraud EDD and the United States Treasury as to material

17   matters, and to obtain money and property from EDD and the United

18   States Treasury, namely, approximately $2,113,966 in UI benefits,

19   including PUA benefits and benefits funded by the LWAP, by means of

20   material false and fraudulent pretenses, representations, and

21   promises in relation to and involving a benefit authorized,

22   transported, transmitted, transferred, disbursed, and paid in

23   connection with a presidentially declared major disaster and

24   emergency.

25        22.      The fraudulent scheme operated, in substance, as described

26   in paragraphs 17 and 18 of this Indictment.

27

28
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 1   B.     USE OF THE MAILS

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

 3   and San Bernardino Counties, within the Central District of

 4   California, and elsewhere, the below-named defendants, together with

 5   others known and unknown to the Grand Jury, each aiding and abetting

 6   the other, for the purpose of executing the scheme to defraud

 7   described above, knowingly caused the following items to be delivered

 8   by the United States Postal Service and private and commercial

 9   interstate carrier, according to the directions thereon:

10

11        COUNT      DEFENDANTS          DATE     ITEM MAILED

12                CAMPBELL, TATE,
      TWO                             7/6/2020    EDD debit card ending in 9219
                  and HENDERSON                   in the name of victim-
13                                                claimant A.W. mailed by FIS
                                                  Corporation to 1068 Casandra
14
                                                  Ln, Corona, CA 92879
15                CAMPBELL, TATE,
      THREE                           7/16/2020 EDD debit card ending in 3274
                  and HENDERSON                 in the name of victim-
16
                                                claimant D.L. mailed by FIS
17                                              Corporation to 420 N McKinley
                                                St # 111-291, Corona, CA
18                                              92879
                  CAMPBELL, TATE,
19    FOUR                            8/17/2020 EDD debit card ending in 1467
                  HENDERSON, GULLY,             in the name of Oregon
                  GUERINGER, and
20                                              resident and claimant M.R.R.
                  ROBERTS                       mailed by FIS Corporation to
21                                              709 N 7th St, Colton CA,
                                                92324
22
      FIVE        CAMPBELL, TATE      8/24/2020 EDD debit card ending in 9998
23                DUPREE,                       in the name of claimant R.J.
                  HENDERSON, GULLY,             mailed by FIS Corporation to
24                GUERINGER,                    767 La Loma Ln, Corona, CA
25                ROBERTS, and                  92879
                  BURNS
26

27

28
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 1     COUNT       DEFENDANTS            DATE     ITEM MAILED

 2   SIX       CAMPBELL, TATE         8/28/2020 EDD debit card ending in 4345
               DUPREE,                          in the name of defendant
 3             HENDERSON, GULLY,                BURNS mailed by FIS
               GUERINGER,                       Corporation to 709 N 7th St,
 4
               ROBERTS, and                     Colton, CA 92324
 5             BURNS

 6   SEVEN     CAMPBELL, TATE         9/6/2020    EDD debit card ending in 6905
               DUPREE,                            in the name of Texas resident
 7             HENDERSON, GULLY,                  and claimant J.H. mailed by
               GUERINGER,                         FIS Corporation to 1261 W
 8             ROBERTS, and                       Rosecrans Ave Apt 235,
               BURNS                              Gardena CA, 90247
 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

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 1                          COUNTS EIGHT THROUGH FOURTEEN

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

 3                                 [ALL DEFENDANTS]

 4          24.   The Grand Jury realleges paragraphs 1 through 15 and 17 and

 5   18 of this Indictment here.

 6          25.   On or about the following dates, in Los Angeles, Riverside,

 7   and San Bernardino Counties, within the Central District of

 8   California, and elsewhere, the below-named defendants, together with

 9   others known and unknown to the Grand Jury, knowingly transferred,

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

11   possessed, and used, without lawful authority, means of

12   identification that the below-named defendants knew belonged to other

13   persons, namely, the names and Social Security Numbers of the

14   individuals identified below, during and in relation to the offense

15   of Conspiracy to Commit Mail Fraud, a felony violation of Title 18,

16   United States Code, Section 1349, as charged in Count One of this

17   Indictment.

18

19     COUNT        DEFENDANT(S)      DATE(S)        MEANS OF IDENTIFICATION

20    EIGHT         CAMPBELL and     7/2/2020       Name and Social Security
                        TATE                        Number of victim-claimant
21                                                             D.L.
22    NINE            ROBERTS       8/13/2020–       Name and Social Security
                                     8/14/2020      Number of claimant M.R.R.
23
      TEN              DUPREE       8/20/2020-      Name and Social Security
24                                   8/21/2020       Number of claimant J.H.
25    ELEVEN          HENDERSON     7/15/2020       Name and Social Security
26                                                  Number of claimant L.J.H.
      TWELVE           GULLY         9/3/2020       Name and Social Security
27
                                                        Number of M.S.S.
28
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     Case 5:22-cr-00150-JGB Document 1 Filed 06/23/22 Page 16 of 18 Page ID #:16




 1     COUNT      DEFENDANT(S)        DATE(S)        MEANS OF IDENTIFICATION

 2   THIRTEEN       GUERINGER       8/29/2020-      Name and Social Security
                                     8/31/2020    Number of claimants K.B. and
 3                                                            D.W.
 4   FOURTEEN         BURNS         10/16/2020    Name of claimant A.I. on EDD
                                                           debit Card.
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     Case 5:22-cr-00150-JGB Document 1 Filed 06/23/22 Page 17 of 18 Page ID #:17




 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 Fourteen 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   //
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     Case 5:22-cr-00150-JGB Document 1 Filed 06/23/22 Page 18 of 18 Page ID #:18




 1   substantially diminished in value; or (e) has been commingled with

 2   other property that cannot be divided without difficulty.

 3
                                               A TRUE BILL
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 6                                                     /S/
                                               Foreperson
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 8   TRACY L. WILKISON
     United States Attorney
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11   SCOTT M. GARRINGER
     Assistant United States Attorney
12   Chief, Criminal Division
13   KRISTEN A. WILLIAMS
     Assistant United States Attorney
14   Acting Chief, Major Frauds Section
15   ALEXANDER B. SCHWAB
     Assistant United States Attorney
16   Deputy Chief, Major Frauds Section
17   ADAM P. SCHLEIFER
     Assistant United States Attorney
18   Major Frauds Section
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