SEALED COMPLAINT as to Adiana Pierre (1), Erin Jare Brown (2), Gardy Alexandre (3),… — USA v. Pierre et al (Dkt. 4)

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An AO 91 criminal complaint against Adiana Pierre a/k/a Adiana Richardson, et al., Case No. 23-mj-5013-JGD, in the U.S. District Court for the District of Massachusetts, signed January 24, 2023 and filed as Document 4. The complaint charges conspiracy to commit wire fraud under 18 U.S.C. § 1349 and money laundering conspiracy under 18 U.S.C. § 1956(h) for conduct from May 2020 to August 2020 in Plymouth, Massachusetts. It is based on an attached affidavit of IRS-CI Special Agent Than Trung Nguyen and was sworn before Judith G. Dein.

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AO 91 (Rev. 11/11)   Criminal Complaint
UNITED STATES DISTRICT COURT
for the
__________ District of __________
United States of America
)
)
)
)
)
)
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v.
Case No.
Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of
in the county of 
in the
District of
, the defendant(s) violated:
Code Section
Offense Description
This criminal complaint is based on these facts: 
u Continued on the attached sheet.
Complainant’s signature
Printed name and title
Sworn to before me and signed WHOHSKRQLFDOO\.
Date:
Judge’s signature
City and state:
Printed name and title
            District of Massachusetts
ADIANA PIERRE
a/k/a Adiana Richardson , ET AL.
23-mj-5013-JGD
May 2020 - August 2020
Plymouth
Massachusetts
18 U.S.C. § 1349
18 U.S.C. § 1956(h)
Conspiracy to Commit Wire Fraud
Money Laundering Conspiracy
See Attached Affidavit.
✔
Than Trung Nguyen, IRS-CI Special Agent
Boston, Massachusetts
Hon. Judith G. Dein
Jan 24, 2023
Case 1:24-cr-10007-MJJ     Document 4     Filed 01/24/23     Page 1 of 1

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