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Criminal Complaint — United States of America v. Clifton Pape and Sally Jung, Case No. 5:21-MJ-7 (Dkt. 1, E.D. Tex.)

Summary

A criminal complaint in United States of America v. Clifton Pape and Sally Jung in the U.S. District Court for the Eastern District of Texas, Texarkana Division. The complaint alleges that, beginning in or before June 2020 and continuing, in the county of Bowie and elsewhere, the defendants committed major fraud against the United States in violation of 18 U.S.C. § 1031, based on an attached affidavit. The complainant, USSS SA William Mack, attested by phone before Magistrate Judge Caroline M. Craven in Texarkana. The attached notice of penalty, signed the 12th day of January, 2021, lists imprisonment for not more than ten years, a fine not to exceed $1,000,000 ($5,000,000 where the gross loss or gain is $500,000), up to three years of supervised release and a $100.00 special assessment.

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UNITED STATES DISTRICT COURT

for the

Eastern District of Texas

United States of America )
V. )
CLIFTON PAPE ) Case No.
) 5:21-MJ-_7_
SALLY JUNG )
)
)
Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
Beginning in or before June 2020 and continuing to today in the county of Bowie and elsewhere in the
Eastern District of _Texas and elsewhere _ , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 1031 Major fraud against the United States

This criminal complaint is based on these facts:

See attached affidavit.

A Continued on the attached sheet.

Appearing by Phone

Complainant’s signature

USSS SA William Mack

Printed name and title

Attested to by the applicant in accordance with the requirements of Fed¢R. Crim. P. 4.1 by phgne.

Judge’s signature

City and state: Texarkana, Texas Caroline M. Craven United States Magistrate Judge

Printed name and title
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS

TEXARKANA DIVISION
UNITED STATES OF AMERICA §
§
Vv. § No. 5:21-MJ-_7_
§ JUDGE SCHROEDER
CLIFTON PAPE §
SALLY JUNG §
NOTICE OF PENALTY
Count One
VIOLATION: 18 U.S.C. § 1031
(Major fraud against the United States)
PENALTY: Imprisonment for not more than ten years; a

fine not to exceed $1,000,000; a term of
supervised release of not more than three
years. If the gross loss to the Government or
the gross gain to a defendant is $500,000, then
a not to exceed $5,000,000.

AROLINE M. CRAVEN
UNITED STATES MAGISTRATE JUDGE

SPECIAL ASSESSMENT: — $100.00

SIGNED this 12th day of January, 2021.

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