Information — United States v. Travis McKenzie, Central District of California (Document 38)
Summary
An Information filed June 22, 2022 in United States v. Travis McKenzie, No. 2:22-cr-00268-PA, in the U.S. District Court for the Central District of California, as Document 38. Count One charges mail fraud under 18 U.S.C. § 1341, alleging that from in or around August 2020 through at least June 2021 McKenzie filed fraudulent EDD unemployment applications in other people's names, and that a co-schemer who was a U.S. Postal Service mail carrier intercepted the debit cards mailed by California EDD and passed them on. It alleges McKenzie used some of the cards to withdraw cash from ATMs and make purchases at high end retailers. Count Two charges possession of approximately 317 pieces of stolen mail on or about May 20, 2021 under 18 U.S.C. § 1708, and Count Three charges unlawful use of another person's means of identification under 18 U.S.C. §§ 1028(a)(7), (b)(1)(D).
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“Information — United States v. Travis McKenzie, Central District of California (Document 38).”
Original at ecf.cacd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-2-22-cr-00268-dkt-38-c-d-cal-d5af5a295f/
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Case 2:22-cr-00268-PA Document 38 Filed 06/22/22 Page 1 of 4 Page ID #:110
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6/22/2022
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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-00268-SB
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. § 1708: Possession of
13 TRAVIS McKENZIE, Stolen Mail; 18 U.S.C.
§§ 1028(a)(7), (b)(1)(D): Unlawful
14 Defendant. Transfer, Possession, and Use of
Means of Identification]
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 TRAVIS
23 McKENZIE, 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-00268-PA Document 38 Filed 06/22/22 Page 2 of 4 Page ID #:111
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 McKENZIE would file fraudulent applications
5 for EDD unemployment benefits in other people’s names using mailing
6 addresses under the control of his and his co-schemers.
7 b. Based upon those fraudulent applications, California
8 EDD would mail debit cards and other correspondence to the addresses
9 listed on the applications.
10 c. After California EDD mailed out debit cards or other
11 correspondence to those addresses, defendant McKENZIE’s co-schemer,
12 who was a U.S. Postal Service mail carrier, would then intercept and
13 steal that mail and provide it to defendant.
14 d. Defendant McKENZIE would also use some of those stolen
15 EDD debit cards in the names of others to withdraw cash from ATMs and
16 make purchases at high end retailers.
17 B. USE OF THE MAILS
18 3. On or about December 2, 2020, within the Central District
19 of California, and elsewhere, defendant McKENZIE, for the purpose of
20 executing and attempting to execute the above-described scheme to
21 defraud, willfully caused an item to be placed in an authorized
22 depository for mail matter to be sent and delivered by the USPS
23 according to the directions thereon, specifically, a letter from
24 California EDD addressed to victim A.J. at Valencia, California,
25 which contained an EDD debit card in the name of A.J.
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Case 2:22-cr-00268-PA Document 38 Filed 06/22/22 Page 3 of 4 Page ID #:112
1 COUNT TWO
2 [18 U.S.C. § 1708]
3 4. On or about May 20, 2021, in Los Angeles County, within the
4 Central District of California, defendant TRAVIS McKENZIE unlawfully
5 possessed mail and mail matter that had been stolen and taken from
6 the United States mail, namely, approximately 317 pieces of mail and
7 mail matter addressed to various individuals within Los Angeles
8 County and elsewhere, and at that time and place, defendant McKENZIE
9 knew that said mail and mail matter were stolen.
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Case 2:22-cr-00268-PA Document 38 Filed 06/22/22 Page 4 of 4 Page ID #:113
1 COUNT THREE
2 [18 U.S.C. §§ 1028(a)(7), (b)(1)(D)]
3 5. On or about May 20, 2021, in Los Angeles County, within the
4 Central District of California, defendant TRAVIS McKENZIE knowingly
5 transferred, possessed, and used, without lawful authority, means of
6 identification of another person, namely, the name and debit card
7 number of A.J., in defendant McKENZIE’s residence in Valencia,
8 California, with the intent to commit, to aid and abet the commission
9 of, and in connection with the commission of, a violation of Federal
10 law, namely, Mail Fraud, in violation of Title 18, United States
11 Code, Section 1341, with said transfer, possession, and use affecting
12 interstate and foreign commerce and resulting in obtaining anything
13 of value aggregating $1,000 or more during any one year period.
14 TRACY L. WILKISON
United States Attorney
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17 SCOTT M. GARRINGER
Assistant United States Attorney
18 Chief, Criminal Division
19 BENJAMIN R. BARRON
Assistant United States Attorney
20 Chief, Santa Ana Branch Office
21 BRADLEY E. MARRETT
Assistant United States Attorney
22 Deputy Chief, Santa Ana Branch
Office
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CHARLES E. PELL
24 Assistant United States Attorney
Santa Ana Branch Office
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