June 10, 2021 - SACRAMENTO, Calif. — A 16-count indictment was unsealed Wednesday charging Kenneth Ray Hawkins, 47, of Tracy; Jacqueline Marie Marquez, 34, formerly of Las Vegas; Alyssa Marie Jones, 32, of Barstow; and Ebony Chanel Jones, 20, of Barstow, with conspiracy to commit mail fraud and mail fraud, Acting U.S. Attorney Phillip A. Talbert announced.

A federal grand jury returned the indictment on May 13. According to court documents, between June 2020 and January 2021, the four defendants conspired to execute and executed a scheme to defraud by filing fraudulent unemployment insurance claims with the California Employment Development Department (EDD), seeking Pandemic Unemployment Assistance benefits under the CARES Act. During the conspiracy, Hawkins was an inmate at the Deuel Vocational Institution (DVI), a California state prison in Tracy, California. Hawkins collected identity information, including names and Social Security numbers, of California prison inmates and other individuals and used the identities and an unauthorized cellphone to file fraudulent unemployment insurance claims from his jail cell. The claims represented, among other things, that the claimants had recently lost employment from businesses or were unable to find employment due to the COVID-19 pandemic. These claims were fraudulent because, for example, the inmates were incarcerated, not recently employed, and ineligible for unemployment insurance benefits.

In the applications, Hawkins requested that the benefits be mailed to various California addresses that were under the control of one or more co-conspirators. EDD approved dozens of the fraudulent claims and authorized Bank of America to mail out EDD debit cards containing benefits. Co-defendants Marquez, Alyssa Jones, and Ebony Jones then obtained the EDD debit cards and used them to withdraw the benefits at ATMs throughout California for the benefit of the conspirators. The scheme sought over $1.2 million and resulted in EDD paying out over $900,000.

This case is the product of an investigation by the U.S. Postal Inspection Service, the California Department of Corrections and Rehabilitation Office of Correctional Safety, the DVI Investigative Services Unit, and EDD – Investigation Division. Special Assistant U.S. Attorney Robert J. Artuz is prosecuting the case.

Alyssa Jones and Ebony Jones recently made their initial appearances in the Central District of California and were released on bond to appear in the Eastern District of California. Marquez has not yet made her initial appearance in federal court. Hawkins remains in state prison for an unrelated conviction.

If convicted, each defendant faces a maximum statutory penalty of 20 years in prison and a $250,000 fine on each of the 16 counts. Any sentence, however, would be determined at the discretion of the court after consideration of any applicable statutory factors and the Federal Sentencing Guidelines, which take into account a number of variables. The charges are only allegations; the defendants are presumed innocent until and unless proven guilty beyond a reasonable doubt.