I Have Filed a Second Federal Criminal Complaint!

On March 7, 2022, I filed another Federal Criminal Complaint (FCC) with the Federal Treasury Inspector General, the Sacramento Grand Jury, and the Federal Bureau of Investigation. This time it was against two more Franchise Tax Board employees and Department of Justice employee Deputy Attorney General Anna Barsegyan.

The charges against Keith Swank, Franchise Tax Board employee are: Five Counts of Perjury, Five Counts of Collusion to Cover Up Racketeering, Five Counts of Collusion to Cover Up Embezzlement and Fifteen Counts of Obstruction of Justice. These were all done to hide evidence from coming out in my court case that would concretely prove Franchise Tax Board’s eight criminal schemes to overcharge taxpayers, the accounting fraud which accompanies these schemes, and the systematic violation of taxpayer rights.  

The charges against Chelsea Hubbard, Franchise Tax Board employee are: Six Counts of Perjury, Ten Counts of Obstruction of Justice, Ten Counts of Collusion to Cover Up Embezzlement, Three Counts of Collusion to Cover Up Racketeering. These were all done to hide evidence from coming out in my court case that would concretely prove Franchise Tax Board’s eight criminal schemes to overcharge taxpayers, the accounting fraud which accompanies these schemes, and systematic violation of taxpayer rights. 

The charges against Deputy Attorney General Anna Barsegyan, Department of Justice employee are: Knowingly and Deliberately Misleading a Judge, Harassment, Retaliation, Abuse of the Court System, Violation of Rights, Obstruction of Justice, Conspiracy to Cover Up Criminal Activities, and Setting Keith Swank Up as a “patsy” via Suborning Perjury and Subterfuge. These were all done to hide evidence from coming out in my court case that would concretely prove Franchise Tax Board’s eight criminal schemes to overcharge taxpayers, the accounting fraud which accompanies these schemes, and systematic violation of taxpayer rights.  

Prima Fascia evidence indicates that Anna Barsegyan may also have set up Chelsea Hubbard and/or Franchise Tax Board employee Grace LeBleu as “patsies,” too.

Here is the FCC: pages 1 – 19, pages 20 – 39, pages 40 – 58, and pages 59 – 68 and the exhibit list.

I am working on redacting and uploading the evidence. There are so many documents that it is overwhelming. This is the exhibit list; I have links to all of the documents that have been uploaded so far:

FCC Exhibit #	Description	# of pages	SDSC Exhibit #
1	Overview of FTB’s 8 Schemes	5	61
2	Letter to Governor Brown dated 04-09-2018	9
3	Declaration in Support of Motion to Compel	84	filed 05-24-21
4	Standard Operating Procedures for Demand Penalties	1
5	Letter from Taxpayer Advocate dated 01-25-2019	5
6	Letter to Governor Brown dated 02-07-2018	3	72
7	Letter from Taxpayer Advocate dated 01-28-2021	3	57
8	Letter from Disclosure Department dated 08-08-2019	2
9	Letter from Disclosure Department dated 07-21-2020	3
10	2005 W2s and NPA	2
11	Proof Payments are Identified as “No Payments”	1
12	Chart of Payments Made Between 2008 and 2016	1	2
13	Plaintiff’s Specially Prepared Interrogatories	53	48
14	Plaintiff’s Request for Admissions	45	52
15	Letter to Governor Brown dated 02-23-2018	5	86
16	Proof of 4 Schemes to Overcharge Interest	15
17	Complaint to San Diego District Attorney	17
18	CBS News Story dated 11-21-2017	4	n/a
19	CBS News Story dated 02-07-2021	4	n/a
20	FTB Coercion and Extortion Form Letter	1	n/a
21	Plaintiff’s Demand for Documents Dated 10-01-2020	3	39
22	Defendant’s Response to Demand for Documents, set 1	16	40
23	Meet and Confer for Plaintiff’s Demand for Documents	11	42
24	Follow Up Emails to Meet and Confer	6	44
25	FTB’s Meet and Confer Response to Demand for Docs 1	4	45
26	Follow Up Emails to Meet and Confer	4	46
27	Declaration in Support of Motion to Compel Documents	42	filed 12-15-2020
28	Proof Records Exist of Dates Payments Applied	5	76
29	2021 Taxpayer Bill of Rights Requests and Response	12	77
30	Plaintiff’s Demand for Documents, set #002	2	78
31	Defendant’s Response to Demand for Documents, set 2	7	79
32	Meet and Confer for Plaintiff’s Demand for Documents 2	9	80
33	Amended Response to Demand for Documents, set 2	7	81
34	FTB Response to Specially Prepared Interrogatories, #1	23	48
35	Meet and Confer to Specially Prepared Interrogatories, 1	54	58
36	FTB Response to Meet and Confer for Interrogatories 1	6	82
37	Proof of Improper Redactions	12	83
38	Privilege Log	3	84
39	Proof of Improper Redactions	7	85
40	Redactions Which Appear to be Improper	26	87
41	CA Supreme Court Accusation Eric Yadao	46	53
42	Respondent’s Opening Brief for OTA Case	16	88
43	Employee Information and Oaths	7	62
44	Declarations of Hubbard and Swank	13	filed 09-01-2021
45	Emails Between Grab and Barsegyan from May 2021	2	89
46	Plaintiff’s Response to Defendant’s Meet and Confer	12	75
47	FTB Opposition to Motion to Compel Documents	16	filed on 05-13-2021
48	Oral Arguments Motion to Compel Hearing May 2021	5	67
49	Oath and Complaint Letter Barsegyan	4	63
50	SDPD Police Report	1	64
51	Defendant’s Motion for Sanctions Dated 09-01-2021	16	filed 09-01-2021
52	Proof of Exposure of Personal Information	1	filed 09-10-2021
53	Office of Tax Appeals Opinion	10	1
54	SDSC Complaint for Refund of Personal Income Tax	32	filed 01-29-2020
55	Video of June 2021 FTB Board of Directors Meeting	USB	68
56	Declaration of Thi Luong	6	filed 09-01-2021
57	Agenda and Budget Requests from June FTB Meeting	3	69
58	Emails Between Smith and Grab Dated 11-06-2018	2	70
59	Correspondence Between Calhoun and Grab	8	71
60	2019 Annual Taxpayer Bill of Rights Speech	USB	73
61	Letter from Taxpayer Advocate dated 01-31-2020	4	74
62	Emails Between Grab and Barsegyan January 2022	5	90