Criminal Complaint — United States v. Danielle Miller (No. 1:21-mj-05198, D. Mass.)

Summary

A criminal complaint (form AO 91) in United States of America v. Danielle Miller, Case No. 21-mj-5198-JGD, in the U.S. District Court for the District of Massachusetts, filed 05/10/21 as Document 1. The complaint charges wire fraud under 18 U.S.C. § 1343, stating that on or about August 1, 2020, in Suffolk County, the defendant transmitted wire communications to execute a scheme to defraud by accessing a myRMV account maintained by the Massachusetts Registry of Motor Vehicles. It states that the complaint is based on the affidavit of Special Agent Jacqleen Cunningham of Homeland Security Investigations, attached and incorporated by reference. The complaint was sworn by telephone under Fed. R. Crim. P. 4.1 before Hon. Judith G. Dein, U.S. Magistrate Judge, on 05/10/2021.

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Case 1:21-mj-05198-JGD Document1 Filed 05/10/21 Page 1of1

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

District of Massachusetts

United States of America )
V. )
Danielle Miller ) ;
) Case No. 21-mj-5198-JGD
)
)
)
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 August 1, 2020 in the county of Suffolk in the
District of Massachusetts , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 1343 Wire fraud, that is, having devised and intending to devise a scheme and

artifice to defraud, and for obtaining money and property by means of
materially false and fraudulent pretenses, representations, and promises, did
transmit and cause to be transmitted by means of wire communications in
interstate and foreign commerce, writings, signs, signals, pictures, and
sounds for the purpose of executing the scheme to defraud — specifically, by
accessing a myRMV account maintained by the Massachusetts Registry of
Motor Vehicles.

This criminal complaint is based on these facts:

Please see the affidavit of Special Agent Jacqleen Cunningham, Homeland Security Investigations, which is attached
hereto and incorporated by reference.

& Continued on the attached sheet.

Complainant’s Muah

Jacqleen Cunningham, Special Agent, HSI

Printed name and title

Sworn to by telephone pursuant to Fed. R. Crim. P. 4.1.

Date: 05/10/2021 Jadath Oot Dave

Judge’ S signature

City and state: Boston, MA Hon. Judith G. Dein, U.S. Magistrate Judge

Printed name and title


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