Information — United States v. Stephen Glover, Central District of California (Document 35)
Summary
An Information filed June 21, 2022 in United States v. Stephen Glover, No. 2:22-cr-00260-PA, in the U.S. District Court for the Central District of California, as Document 35. Count One charges mail fraud under 18 U.S.C. § 1341, alleging that from in or around August 2020 through at least June 2021 Glover, then a United States Postal Service mail carrier, gave addresses on the mail route to co-schemers who used them to file fraudulent unemployment claims with the California Employment Development Department. It alleges that Glover intercepted the EDD debit cards and other mail sent to those addresses, passed much of it to co-schemers and used some cards to withdraw cash from ATMs. Count Two charges theft of mail by a Postal Service employee under 18 U.S.C. § 1709 for a letter taken on or about June 15, 2021. The signature block names United States Attorney Tracy L. Wilkison.
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“Information — United States v. Stephen Glover, Central District of California (Document 35).”
Original at ecf.cacd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-2-22-cr-00260-dkt-35-c-d-cal-3027d2a570/
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Case 2:22-cr-00260-PA Document 35 Filed 06/21/22 Page 1 of 3 Page ID #:128
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6/21/2022
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cd
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8 UNITED STATES DISTRICT COURT
9 FOR THE CENTRAL DISTRICT OF CALIFORNIA
10 UNITED STATES OF AMERICA, No. 2:22-cr-00260-PA
11 Plaintiff, I N F O R M A T I O N
12 v. [18 U.S.C. § 1341: Mail Fraud; 18
U.S.C. § 1709: Theft of Mail
13 STEPHEN GLOVER, Matter by Postal Service Employee]
14 Defendant.
15
16 The United States Attorney charges:
17 COUNT ONE
18 [18 U.S.C. §§ 1341. 2(b)]
19 A. THE SCHEME TO DEFRAUD
20 1. Beginning in or around August 2020, and continuing through
21 at least in or around June 2021, in Los Angeles County, within the
22 Central District of California, and elsewhere, defendant STEPHEN
23 GLOVER, together with others known and unknown to the United States
24 Attorney, each aiding and abetting the other, knowingly and with
25 intent to defraud, devised, participated in, and executed and
26 attempted to execute a scheme to defraud the California Employment
27 Development Department (“EDD”), as to material matters, and to obtain
28 money and property from California EDD, by means of material false
Case 2:22-cr-00260-PA Document 35 Filed 06/21/22 Page 2 of 3 Page ID #:129
1 and fraudulent pretenses, representations, and promises, and the
2 concealment of material facts.
3 2. The scheme to defraud operated, in substance, as follows:
4 a. Defendant GLOVER, who at the time was a United States
5 Postal Service (“USPS”) mail carrier, would provide addresses on his
6 mail route to co-schemers, which the co-schemers would use as the
7 mailing address when filing fraudulent claims for unemployment
8 benefits from the California EDD.
9 b. Based upon those fraudulent applications, California
10 EDD would mail debit cards and other correspondence to the addresses
11 listed on the applications.
12 c. After California EDD mailed out debit cards or other
13 correspondence to those addresses on defendant GLOVER’s mail route,
14 defendant GLOVER would then intercept and steal that mail.
15 d. Defendant GLOVER would then provide much of that EDD-
16 related mail to his co-schemers, which included EDD debit cards in
17 the names of others.
18 e. Defendant GLOVER would also use some of those stolen
19 EDD debit cards in the names of others to withdraw cash from ATMs.
20 B. USE OF THE MAILS
21 3. On or about June 15, 2021, within the Central District of
22 California, and elsewhere, defendant GLOVER, for the purpose of
23 executing and attempting to execute the above-described scheme to
24 defraud, willfully caused an item to be placed in an authorized
25 depository for mail matter to be sent and delivered by the USPS
26 according to the directions thereon, specifically, a letter from
27 California EDD addressed to victim R.M. at Valencia, California,
28 which contained a debit card in the name of R.M.
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Case 2:22-cr-00260-PA Document 35 Filed 06/21/22 Page 3 of 3 Page ID #:130
1 COUNT TWO
2 [18 U.S.C. § 1709]
3 4. On or about June 15, 2021, in Los Angeles County, within
4 the Central District of California, defendant STEPHEN GLOVER, an
5 employee of the United States Postal Service, stole, abstracted, and
6 removed mail, namely, a letter from California EDD addressed to
7 victim R.M. at Valencia, California, which had come into his
8 possession intended to be conveyed by the United States mail.
9 TRACY L. WILKISON
United States Attorney
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12 SCOTT M. GARRINGER
Assistant United States Attorney
13 Chief, Criminal Division
14 BENJAMIN R. BARRON
Assistant United States Attorney
15 Chief, Santa Ana Branch Office
16 BRADLEY E. MARRETT
Assistant United States Attorney
17 Deputy Chief, Santa Ana Branch
Office
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CHARLES E. PELL
19 Assistant United States Attorney
Santa Ana Branch Office
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