Case 4:19-cr-40074-KES Document 1 Filed 09/04/19 Page 1 of 3 PageID #: 1 UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION UNITED STATES OF AMERICA, Plaintiff, vs. CR REDACTED INDICTMENT Mail Theft 18 U.S.C. § 1708 JENNIFER GROETHE, Mail Fraud Defendant. is U.S.C. § 1341 The Grand Jury Charges; COUNT 1 (Mail Theft) On or about between October 23, 2018, and December 3, 2018, in the District of South Dakota, the defendant, Jennifer Groethe, did steal, take, and abstract letters, postal cards, packages, and mail from and out of authorized depositories for United States mail matter, and did abstract and remove from such letters, postal cards, packages, and mail, articles and things contained therein, and did secrete, embezzle and destroy such letters, postal cards, packages, and mail and articles and things therein, namely, Jennifer Groethe did steal mail matter addressed to Load King, P.O. Box 427, Elk'Point, South Dakota 57025, all in violation of 18 U.S.C. § 1708. COUNTS 2-13 (Mail Fraud) 1. On or about between February 21, 2018 and January 8, 2019, in the District of South Dakota and elsewhere, the Defendant, Jennifer Groethe, Case 4:19-cr-40074-KES Document 1 Filed 09/04/19 Page 2 of 3 PageID #: 2 did willfully and unlawfully devise, and intend to devise, a scheme and artifice to defraud for obtaining money and property by means of false and fraudulent pretenses, representations, and promises. 2. Throughout the relevant time period, the Defendant was employed by Load King as an accounting and sales coordinator. Her duties included collecting incoming checks sent to Load King in Elk Point, South Dakota, via the United States Postal Service. She also credited accounts receivable and was supposed to deposit checks into Load King's bank account. 3. The Defendant's employer. Load King, sold scrap metals to Sioux City Compressed Steel (SCCS). 4. As part of the scheme and artifice to defraud, the defendant contacted Sioux City Compressed Steel, and falsely represented to them that her name should be added as a payee to checks payable to Load King. 5. As part of the scheme and artifice to defraud her employer. Load King, the Defendant did take from the mails, checks from Sioux City Compressed Steel addressed to Load King, 701 East Rose Street, Elk Point, South Dakota, 57025. 6. As part of the scheme and artifice to defraud, the Defendant cashed the checks at Wells Fargo Bank in Sioux City, Iowa, by falsely representing that Load King authorized her to do so. The Defendant cashed each check and kept the funds for per personal use and deprived Load King of its funds and property. 7. On or about the dates listed below, the Defendant took checks from the mail for the purpose of executing the scheme and artifice to defraud as follows; [2] Case 4:19-cr-40074-KES Document 1 Filed 09/04/19 Page 3 of 3 PageID #: 3 Count 2 3 4 5 6 7 8 9 10 11 12 13 Date February 21, 2018 March 7, 2018 April 4, 2018 April 18, 2018 May 9, 2018 May 29, 2018 August 2, 2018 September 4, 2018 October 4, 2018 November 7, 2018 December 6, 2018 January 8, 2019 Sender sees sees sees sees sees sees sees sees sees sees sees sees Recipient Load King Load King Load King Load King Load King Load King Load King Load King Load King Load King Load King Load King All in violation of 18 U.S.C. § 1341. A TRUE BILL: Name Redacted Foreperson RONALD A. PARSONS, JR. United States Attorney By: [3] Item mailed $4,948.75 check $2,258.00 check $13,292.51 check $3,092.77 check $12,832.70 check $5,966.51 check $8,965.88 check $18,957.31 check $22,306.28 check $13,064.99 check $19,572.97 check $10,555.46 check