Indictment Memorandum — No. 2:21-cr-00417 (Dkt. 4, W.D. Pa.)
Summary
An indictment memorandum filed September 28, 2021 as Document 4 in United States of America v. Jaime Jones, Case 2:21-cr-00417-CCW, U.S. District Court for the Western District of Pennsylvania, submitted under seal by Acting U.S. Attorney Stephen R. Kaufman and AUSA Jeffrey R. Bengel. It states that a federal grand jury returned a twelve-count indictment charging wire fraud under 18 U.S.C. § 1343 on dates from June 17, 2020 (Counts One and Two) through August 23, 2020 (Count Twelve), lists the elements of wire fraud, and sets out the penalties per count: imprisonment of not more than twenty (20) years, a fine of up to $250,000 or an alternative fine under 18 U.S.C. § 3571(d), and supervised release of not more than three (3) years. It adds a $100.00 mandatory special assessment per count, possible restitution, and that forfeiture is not applicable; the memorandum is three pages.
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Case 2:21-cr-00417-CCW Document4 Filed 09/28/21 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA V. Criminal No. U -Y} 7 [UNDER SEAL] JAIME JONES INDICTMENT MEMORANDUM AND NOW comes the United States of America, by its attorneys, Stephen R. Kaufman, Acting United States Attorney for the Western District of Pennsylvania, and Jeffrey R. Bengel, Assistant United States Attorney for said District, and submits this Indictment Memorandum to the Court: I. THE INDICTMENT A federal grand jury returned a twelve-count Indictment against the above-named defendant for alleged violations of federal law: One through -Wire Fraud 18 U.S.C. § 1343 Twelve June 17, 2020 (Count One) * June 17, 2020 (Count Two) June 25, 2020 (Count Three) June 25, 2020 (Count Four) June 25, 2020 (Count Five) June 26, 2020 (Count Six) iP i LL 1), June 26, 2020 (Count Seven) —— June 29, 2020 (Count Eight) SEP 28 2021 July 2, 2020 (Count Nine) July 10, 2020 (Count Ten) CLERK U.S. DISTRICT COURT July 19, 2020 (Count Eleven) WEST. DIST. OF PENNSYLVANIA August 23, 2020 (Count Twelve) Case 2:21-cr-00417-CCW Document 4 Filed 09/28/21 Page2of3. Il. ELEMENTS OF THE OFFENSES . A. As to Counts One through Twelve: In order for the crime of Wire Fraud, in violation of 18 U.S.C. § 1343, to be established, the government must prove all of the following essential elements beyond a reasonable } doubt: 1. That JAIME JONES knowingly devised a scheme to defraud or to obtain money or property by materially false or fraudulent pretenses, representations or promises or willfully participated in such a scheme with knowledge of its fraudulent nature; 2. That JAIME JONES acted with the intent to defraud; and 3. That in advancing, furthering, or carrying out the scheme, JAIME JONES transmitted any writing, signal, or sound by means of a wire, radio, or television communication in interstate commerce or caused the transmission of any writing, signal, or sound of some kind by means of a wire, radio, or television communication in interstate commerce. Third Circuit Model Criminal Jury Instruction 6.18.1343. II. PENALTIES A. As to Counts One to Twelve: Wire Fraud (18 U.S.C. § 1343): . (1) imprisonment for not more than twenty (20) years; (2) a fine not more than the greater of; (a) $250,000 (18 U.S.C. § 3571(b)(3)); or (b) an alternative fine in an amount not more than the greater of twice the gross pecuniary gain to any person or twice the pecuniary loss to any person other than the defendant, unless the imposition of this alternative fine would unduly complicate or prolong the sentencing process (18 U.S.C. § 3571(d)); oN « ! Case 2:21-cr-00417-CCW Document4 Filed 09/28/21 Page 3of3 t (3) a term of supervised release of not more than three (3) years (18 U.S.C. §§ 3559, 3583); (4) Any or all of the above. IV. MANDATORY SPECIAL ASSESSMENT A mandatory special assessment of $100.00 must be imposed at each count upon ‘ \ which the defendant is convicted pursuant to 18 U.S.C. § 3013. V. RESTITUTION Restitution may be required in this case as to Counts One through Twelve together . with any authorized penalty, as part of the defendant’s sentence pursuant to 18 U.S.C. §§ 3663, 3663A, and 3664. VI. FORFEITURE c Forfeiture is not applicable in this case. Respectfully submitted, STEPHEN R. KAUFMAN Acting United States Attorney JEFFREY R. BENGE®? Assistant U.S. Attorney DC ID No. 1018621
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- gov.uscourts.pawd.283261.4.0.pdf
- Original
- archive.org