LOS ANGELES – July 11 2011 – The California National Guard’s former Bonus and Incentive Manager has entered into a plea agreement in which she admits to submitting $15.2 million dollars in false and fraudulent claims to the United States Department of Defense. The plea agreement, along with a single count information, was filed today in federal court here in Los Angeles.
The information charges Retired Master Sergeant Toni L. Jaffe, 52, with making a false claim against the United States in violation of 18 U.S.C. § 287.
For over 15 years, Jaffe, a resident of Citrus Heights, was the Bonus and Incentive Manager for the California National Guard. As part of her plea agreement, Jaffe has admitted that beginning in at least the fall of 2007 and continuing to on or about October 6, 2009, she routinely submitted false and fictitious claims on behalf of her fellow California National Guard members. Jaffe admitted that she submitted claims to pay bonuses to members of the California National Guard whom she knew were not eligible to receive the bonuses and to pay off officers loans even though she knew the officers were ineligible for loan repayment. According to the plea agreement, Jaffe admits responsibility for $15.2 million in wrongfully paid bonuses and loan repayments. An audit of the full loss amount is ongoing.
“The deliberate misappropriation of tens of millions of dollars of federal government money is unacceptable, and those responsible for stealing federal money through fraud will be prosecuted to the fullest extent of the law,” said United States Attorney André Birotte Jr. “We hope this federal case sends a clear message that we will continue to safeguard federal funds against fraud and abuse, whether it occurs within the California National Guard or elsewhere.”
The particular incident charged in the information occurred in January 2009, when Jaffe submitted a fraudulent claim on behalf of a California National Guard officer resulting in the payment of a $20,000 Critical Skill Retention Bonus to which he was not entitled.
“The California National Guard has been fully cooperating in this investigation from the beginning,” said Major General David Baldwin, the Adjutant General for the California National Guard. “We applaud the United States Attorney’s decisive action in this case.”
The charge in the information carries a maximum statutory sentence of five years imprisonment, payment of a fine in the amount of $250,000 or two times the gross gain or gross loss, three years of supervised release and payment of a $100 special assessment. As part of her plea agreement, defendant is also required to pay restitution to the United States, which is currently estimated to be $15.2 million.
An information contains allegations that a defendant has committed a crime. Every defendant is presumed innocent until and unless proven guilty.
This continuing investigation is being conducted by the Federal Bureau of Investigation, the Army Criminal Investigative Command, and the Defense Criminal Investigative Services. The California National Guard has also been cooperating with the investigation.

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