Free Motion to Issue Summons - District Court of California - California

Case 4:08-cr-00208-WDB

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JOSEPH P. RUSSONIELLO (CASBN 44332) United States Attorney
W. DOUGLAS SPRAGUE (CASBN 202121) Chief, Oakland Branch MAUREEN BESSETTE (NYSBN 246854) Assistant United States Attorney 1301 Clay Street, Suite 340S Oakland, CA 94612 Telephone: (510) 637-3680 Fax: (510) 637-3724 Email: [email protected] Attorneys for the United States of America

9 10 11 12 13 14 15 16 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28 v. VANESSA McKNIGHT, UNITED STATES OF AMERICA, Plaintiff, UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION ) ) ) ) ) ) ) ) ) ) ) Case No. CR-08-0208-WDB DECLARATION Of SARALA NAGALA IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS

I, Sarala Nagala, hereby declare as follows: 1. I am a Law Clerk in the United States Attorney's Office assigned to this case. I have received the following information from agents employed by the Department of Homeland Security Office of the Inspector General (DHS OIG) and from reports and other documents provided to me by the DHS OIG. 2. Hurricane Katrina made landfall in the southeastern United States on August 29, 2005. On or about September 16, 2005, McKnight contacted the Federal Emergency Management Agency (FEMA) and applied for Hurricane Katrina disaster assistance by providing the following false information: (1) her primary residence was 2725 Hamilton Street, New Orleans, //// DECLARATION Of SARALA NAGALA IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS CR-08-0208-WDB

Case 4:08-cr-00208-WDB

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Louisiana 70118; (2) her residence and personal property were damaged by Hurricane Katrina; and (3) access to her residence was restricted as a result of the disaster. 3. When McKnight applied for FEMA disaster assistance, she in fact resided in Oakland, California, at the Shekinah Glory Worship Center Academy (SGWCA). The proof that she resided in Oakland, California, rather than New Orleans, Louisiana, is the following: (1) a statement from Evelyn Combs, a former SGWCA employee, that McKnight moved into the SGWCA on June 15, 2005, and was living there when Hurricane Katrina hit New Orleans; (2) a County of Alameda Monthly Eligibility Report showing that, on August 2, 2005, McKnight applied for financial assistance and food stamps with Alameda County, California, and listed her SGWCA address on the application; (3) a County of Alameda Monthly Eligibility Report showing that McKnight received financial aid and food stamps at her SGWCA address for the months of July and August 2005; and (4) Social Security Administration records showing that, on August 23, 2005 (six days before Hurricane Katrina), McKnight applied for a replacement Social Security Card at the Social Security office in Oakland, California, and listed her SGWCA address on the application. 4. On September 17, 2005, FEMA mailed McKnight a letter that confirmed her application for Hurricane Katrina disaster assistance and asked her to certify that the information she provided to FEMA was correct. On November 24, 2005, McKnight signed and returned form 90-69B, which certified as correct all the information she provided to FEMA, including her falsified New Orleans address. 5. McKnight subsequently received disaster relief funds from FEMA. 6. A summons was issued on April 7, 2008, for McKnight's last known address. The summons was not executed. This is a second summons to a different address obtained through an electronic search by Agent Rick Fuentes of DHS OIG. /// /// /// /// DECLARATION Of SARALA NAGALA IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS CR-08-0208-WDB

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7. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief.

Executed April 15, 2008, at Oakland, California.

DATED:

4/15/08

Respectfully submitted, JOSEPH P. RUSSONIELLO United States Attorney /s/ SARALA V. NAGALA Law Clerk United States Attorney's Office

DECLARATION Of SARALA NAGALA IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS CR-08-0208-WDB

Case 4:08-cr-00208-WDB

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JOSEPH P. RUSSONIELLO (CASBN 44332) United States Attorney
W. DOUGLAS SPRAGUE (CASBN 202121) Chief, Oakland Branch MAUREEN BESSETTE (NYSBN 246854) Assistant United States Attorney 1301 Clay Street, Suite 340S Oakland, CA 94612 Telephone: (510) 637-3680 Fax: (510) 637-3724 Email: [email protected] Attorneys for the United States of America

9 10 11 12 13 14 15 16 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28 v. VANESSA McKNIGHT, UNITED STATES OF AMERICA, Plaintiff, UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION ) ) ) ) ) ) ) ) ) ) ) Case No. CR-08-0208-WDB DECLARATION Of SARALA NAGALA IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS

I, Sarala Nagala, hereby declare as follows: 1. I am a Law Clerk in the United States Attorney's Office assigned to this case. I have received the following information from agents employed by the Department of Homeland Security Office of the Inspector General (DHS OIG) and from reports and other documents provided to me by the DHS OIG. 2. Hurricane Katrina made landfall in the southeastern United States on August 29, 2005. On or about September 16, 2005, McKnight contacted the Federal Emergency Management Agency (FEMA) and applied for Hurricane Katrina disaster assistance by providing the following false information: (1) her primary residence was 2725 Hamilton Street, New Orleans, //// DECLARATION Of SARALA NAGALA IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS CR-08-0208-WDB

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Louisiana 70118; (2) her residence and personal property were damaged by Hurricane Katrina; and (3) access to her residence was restricted as a result of the disaster. 3. When McKnight applied for FEMA disaster assistance, she in fact resided in Oakland, California, at the Shekinah Glory Worship Center Academy (SGWCA). The proof that she resided in Oakland, California, rather than New Orleans, Louisiana, is the following: (1) a statement from Evelyn Combs, a former SGWCA employee, that McKnight moved into the SGWCA on June 15, 2005, and was living there when Hurricane Katrina hit New Orleans; (2) a County of Alameda Monthly Eligibility Report showing that, on August 2, 2005, McKnight applied for financial assistance and food stamps with Alameda County, California, and listed her SGWCA address on the application; (3) a County of Alameda Monthly Eligibility Report showing that McKnight received financial aid and food stamps at her SGWCA address for the months of July and August 2005; and (4) Social Security Administration records showing that, on August 23, 2005 (six days before Hurricane Katrina), McKnight applied for a replacement Social Security Card at the Social Security office in Oakland, California, and listed her SGWCA address on the application. 4. On September 17, 2005, FEMA mailed McKnight a letter that confirmed her application for Hurricane Katrina disaster assistance and asked her to certify that the information she provided to FEMA was correct. On November 24, 2005, McKnight signed and returned form 90-69B, which certified as correct all the information she provided to FEMA, including her falsified New Orleans address. 5. McKnight subsequently received disaster relief funds from FEMA. 6. A summons was issued on April 7, 2008, for McKnight's last known address. The summons was not executed. This is a second summons to a different address obtained through an electronic search by Agent Rick Fuentes of DHS OIG. /// /// /// /// DECLARATION Of SARALA NAGALA IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS CR-08-0208-WDB

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7. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief.

Executed April 15, 2008, at Oakland, California.

DATED:

4/15/08

Respectfully submitted, JOSEPH P. RUSSONIELLO United States Attorney /s/ SARALA V. NAGALA Law Clerk United States Attorney's Office

DECLARATION Of SARALA NAGALA IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS CR-08-0208-WDB

Case 4:08-cr-00208-WDB

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JOSEPH P. RUSSONIELLO (CASBN 44332) United States Attorney

UNITED STATES DISTRICT COURT 7 NORTHERN DISTRICT OF CALIFORNIA 8 OAKLAND DIVISION 9 UNITED STATES OF AMERICA, 10 Plaintiff, 11 v. 12 VANESSA McKNIGHT, 13 14 15 16 Having reviewed the Declaration of Sarala V. Nagala, the Court finds that probable cause 17 exists to believe that an offense has been committed. Accordingly, pursuant to Fed. R. Crim. P. 18 58(d)(3), the Clerk of the Court is directed to issue a Summons directing the defendant, Vanessa 19 McKnight, 7510 Ney Avenue, Apartment D, Oakland, CA 94605, to appear on May 6, 2008 at 20 10:00 am before Magistrate Judge Wayne D. Brazil to answer the Information that has been filed 21 by the United States Attorney. 22 23 IT IS SO ORDERED. 24 25 26 27 28 Dated: ___________________ WAYNE D. BRAZIL United States Magistrate Judge Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No. CR-08-0208-WDB

[PROPOSED] ORDER FOR SUMMONS

[PROPOSED] ORDER FOR SUMMONS CR-08-0208-WDB