Indictment — United States v. Lawrence Courtney Lawhorn et al., Western District of Missouri (Document 1)

Summary

A grand jury indictment in United States v. Lawrence Courtney Lawhorn, Tina Battie, Latoya Marie Brown and Lauren Courtney Luque, Case No. 2:22-cr-04013-BCW, in the U.S. District Court for the Western District of Missouri, filed February 8, 2022 as Document 1. Count 1 charges conspiracy to commit wire fraud under 18 U.S.C. § 1349, Counts 2 through 4 charge wire fraud and Counts 5 through 8 attempted wire fraud over electronic EIDL applications, and Count 9 charges conspiracy to launder money under 18 U.S.C. § 1956(h). The indictment alleges the defendants formed fictitious business entities to apply for Economic Injury Disaster Loans, causing actual loss of $30,000.00 and intended loss of not less than $70,000.00. It includes forfeiture allegations and is signed by Assistant United States Attorney Aaron M. Maness.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Indictment — United States v. Lawrence Courtney Lawhorn et al., Western District of Missouri (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-2-22-cr-04013-dkt-1-w-d-mo-6e0a7eb4f9/, SHA-256 33fe662a0579ebf865ba0c8e46181b983a180348c30ea49c32c6a8e0e370ae53.

Full text

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION

UNITED STATES OF AMERICA, No. 22-cr-04013-BCW-01/04

Plaintiff, COUNT 1
18 U.S.C. § 1349
v. NMT 20 Years Imprisonment
NMT $250,000 Fine
(01) LAWRENCE COURTNEY LAWHORN, NMT 3 Years Supervised Release
a/k/a “Courtney McAllister,” “Cooter,” “Coot” Class C Felony
[DOB: 01/21/1988]
COUNTS 2 through 8
(02) TINA BATTIE 18 U.S.C. § 1343
a/k/a “Tina Plant” NMT 20 Years Imprisonment
[DOB: 12/16/1985] NMT $250,000 Fine
NMT 3 Years Supervised Release
(03) LATOYA MARIE BROWN, Class C Felony
[DOB: 09/09/1985]
COUNT 9
(04) LAUREN COURTNEY LUQUE, 18 U.S.C. § 1956(h)
a/k/a “Apple” NMT 20 Years Imprisonment
[DOB: 03/10/1986] NMT $500,000 Fine or Twice the Amount
of the Criminally Derived Property
Defendants. NMT 3 Years Supervised Release
Class C Felony

FORFEITURE ALLEGATION
18 U.S.C. §§ 981(a)(1)(A) and (C) and
982(a)(1) and (2)(A)
28 U.S.C. § 2461(c)

$100 Special Assessment (Each Count)
Mandatory Restitution (Each Count)

Defendants/Counts
(01) L. Lawhorn: 1-9,
(02) T. Battie: 1-9.
(03) L. Brown, 1, 3, and 9.
(04) L. Luque: 1, 4, and 9.

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 1 of 15
INDICTMENT

THE GRAND JURY CHARGES THAT:

Introduction and Background

At all times relevant to this Indictment:

The Small Business Administration/The CARES Act/Economic Injury Disaster Loans

1. The United States Small Business Administration (“SBA”) was an executive

branch agency of the United States government that provided support to entrepreneurs and small

businesses. The mission of the SBA was to maintain and strengthen the nation’s economy by

enabling the establishment and viability of small businesses and by assisting in the economic

recovery of communities after disasters.

2. As part of this effort, the SBA enabled and provided for loans through banks, credit

unions and other lenders. These loans had government-backed guarantees. In addition to

traditional SBA funding programs, The CARES Act, which was signed into law in March 2020,

established several new temporary programs and provide for the expansion of others to address

the COVID-19 pandemic.

3. One of these new programs was the expansion of an existing disaster relief program

– the Economic Injury Disaster Loan (“EIDL”) – to provide for loan assistance (including

$10,000.00 advances) for small businesses. The EIDL proceeds could be used to pay fixed debts,

payroll, accounts payable, and other bills associated with the small business that could have been

paid had the disaster not occurred; however, such loans proceeds were not intended to replace lost

sales or profits or for the expansion of the business.

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 2 of 15
4. Unlike other types of SBA-guaranteed loans, EIDL funds were issued directly from

the United States Department of Treasury and applicants applied through the SBA via an online

portal and application. Through the online portal, EIDL applicants submitted personal and

business information in support of each EIDL application, but were not re quired to submit any

supporting or substantiating documentation with their application.

5. An EIDL application included a paragraph where the applicant affirmed that the

information submitted was true and correct under penalty of law and acknowledged that false

information might result in criminal sanctions. The application process involved filling out data

fields relating to the size of the affected business entity, the ownership of the business, the number

of employees working for the business, and gross business revenues realized in the 12 months

prior to the impact of COVID-19 on the national economy. The business must have existed in an

operational condition on or before February 1, 2020.

6. The EIDL application information submitted by the applicant was used by the SBA

to calculate the amount of money the business was eligible to receive in the form of a loan. In

addition to the loan and EIDL applicant could click on and check a box on the application to

request an EIDL Advance of up to $10,000.00 based on the number of employees of the business.

The EIDL Advance did not have to be repaid.

Cash App (Formally Known as Square Cash)

7. Cash App (formally Square Cash) was a mobile payment service developed by

Block Inc. that allowed users to transfer money (“Cash App”). Cash App allowed users to conduct

banking, investments, peer-to-peer money transfers and cryptocurrency transactions. Account

users were limited in the amounts they could send or receive depending on whether the user was

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 3 of 15
verified. An unverified user account could only send $250/week and receive $1000/month. A

verified user account could send $7,500.00/week with no limit on funds that could be received.

To verify an account, a user was required to submit the user’s legal name, date of birth, and the

last four digits of the user’s social security number. As for banking, this service allowed users to

send, receive, and store money. Users could transfer money out of the Cash App to any local

bank account. Cash App charged a 2.75% fee to transfer money to a bank account.

The Defendants

8. Defendant LAWRENCE COURTNEY LAWHORN a/k/a “Courtney

McAllister,” “Cooter,” “Coot” (“LAWHORN”) was a resident of the Western District of

Missouri, who at various times resided in Columbia and the Kansas City, Missouri areas.

LAWHORN was in romantic relationships with defendants LAUREN COURTNEY LUQUE

and LATOYA MARIE BROWN. LAWHORN had a Bank of America bank account, bank

account number XXXXXXXX6872, which was opened on June 17, 2020.

9. Defendant TINA BATTIE a/k/a “Tina Plant” (“BATTIE”) was a resident of the

Western District of Missouri, who resided in the Columbia, Missouri area. BATTIE was the

owner of A1 Empire, Inc. A1 Empire, Inc. was incorporated in the State of Missouri as a business

services/business management corporation. A1 Empire, Inc. had a Bank of America account,

account number XXXXXXXX7881 (“A1 Empire Bank of America account”). BATTIE was the

sole signatory on the A1 Empire Bank of America account. BATTIE had a verified Cash App

account with the “Identify Verification Name” of “Tina Battie” and the “cashtag” of “a1empire”.

(“BATTIE’S Cash App account”). The A1 Empire Bank of America account was linked to

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 4 of 15
BATTIE’S Cash App account as a payment source. BATTIE also had the ability to transfer

funds from BATTIE’S Cash App account to an NFCU account (“NFCU account”).

10. Defendant LAUREN COURTNEY LUQUE (“LUQUE”) was a resident of the

Western District of Missouri, who resided in Fulton, Missouri. LUQUE, along with another

individual, had a Bank of America account, account number XXXXXXXX2210 (LUQUES’S

Bank of America account). LUQUE’S Bank of America account had a card associated with it,

card number XXXXXXXXXXXX5203. LUQUE had a verified Cash App account with the

“Identify Verification Name” of “Lauren Luque” and the “cashtag” of “applemc”. (“LUQUE’S

Cash App account”). A payment source linked to LUQUE’S Cash App account was a Bank of

America National Association card brand, card number XXXXXXXXXXXX5890. LUQUE had

a United Credit Union account, member number 4026604 (“LUQUE’S U.C. Union account”).

11. Defendant LATOYA MARIE BROWN (“BROWN”) was a resident of the

Western District of Missouri, who at various times resided in Columbia and the Kansas City,

Missouri areas. BROWN has a child in common with LAWHORN. BROWN had a bank

account with BMO Harris Bank, N.A., account number XXXXXX7440 (“BROWN’S BMO

Harris account”). BROWN’S BMO Harris account had a card associated with it, number

XXXXXXXXXXXX5890. BROWN had a verified Cash App account with the Cash App account

with the “Identify Verification Name” of “Latoya Brown” and the “cashtag” of “toyabrockin”

(“BROWN’S Cash App account”). A payment source linked to BROWN’S Cash App Account

was a BMO Harris Bank N.A. card brand, card number XXXXXXXXXXXX5890.

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 5 of 15
COUNT 1
(Conspiracy to Commit Wire Fraud)
18 U.S.C. § 1349

12. Between June 1, 2020, and August 24, 2020, said dates being approximate, in the

Western District of Missouri, and elsewhere, the defendants (01) LAWRENCE COURTNEY

LAWHORN a/k/a “Courtney McAllister,” “Cooter,” “Coot,”, (02) TINA BATTIE a/k/a “Tina

Plant”, (03) LAUREN COURTNEY LUQUE a/k/a “Apple”, and (04) LATOYA MARIE

BROWN, and other conspirators known and unknown, knowingly and willfully combined,

conspired, confederated, agreed, and had a tacit understanding with each other and others known

and unknown, to devise and intend to devise a scheme and artifice to defraud, and to obtain money

and property by means of materially false and fraudulent pretenses, representations, and promises

affecting a financial institution, for which the defendants transmitted and caused to be transmitted

by means or wire communications in interstate commerce certain writings, signs, signals, and

sounds for the purposes of executing the scheme and artifice to defraud and for obtaining money

by means of materially false and fraudulent pretenses, representations, and promises; in violation

of Title 18, United States Code, Section 1343.

Manner and Means

13. The manner and means used by the defendants and unindicted co-conspirators to

achieve the objectives of the conspiracy to commit wire fraud included, but were not limited to the

following:

a. The primary purpose of the conspiracy and scheme and artifice was for the

defendants to fraudulently obtain pandemic-related financial benefits in the form of SBA-

sponsored EIDL loans.

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 6 of 15
b. It was further part of the conspiracy and scheme and artifice that the

defendants and others formed fictitious business entities such as “Lawrence Lawhorn,”

“Latoya Brown,” and “Lauren Luque,” as well as businesses associated with Unindicted

Co-Coconspirator 1, Unindicted Co-Conspirator 2, Unindicted Co-Conspirator 3, and

Unindicted Co-Conspirator 4 all of which were used to fraudulently apply for loans under

the EIDL program.

c. It was further part of the conspiracy and scheme and artifice that the

defendants submitted or a co-conspirator on behalf of the defendants submitted

applications for loans under the EIDL program that contained materially false statements,

misrepresentations, and omissions related to the claimed business entities.

d. It was further part of the conspiracy and scheme and artifice that the

defendants falsely attested, or a co-conspirator falsely attested on behalf of the defendant,

that the information was true and accurate.

e. It was further part of the conspiracy and scheme and artifice that the

defendants helped conspirators, and unindicted co-conspirators, fraudulently apply for

EIDL funds and in some cases were paid a percentage of funds obtained.

f. It was further part of the conspiracy and scheme and artifice that the

defendants and co-conspirators, including unindicted co-conspirators, caused actual loss in

the amount of $30,000.00 and intended loss of in an amount of not less than $70,000.00.

g. It was further part of the conspiracy and scheme and artifice that the Small

Business Association sustained a financial loss.

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 7 of 15
h. It was part of the conspiracy and scheme and artifice to defraud that the

defendants knowingly and willfully transmitted and caused to be transmitted by means of

wire communication through interstate commerce, certain signs, signals, and sounds, that

is, the electronic transmission of information from terminals, computers, and/or cellular

telephones within the Western District of Missouri and terminals and/or computer servers

located outside the State of Missouri.

14. All contrary to the provisions of Title 18, United States Code, Section 1343, and all

in violation of Title 18, United States Code, Section 1349.

COUNTS 2 through 4
(Wire Fraud)
18 U.S.C. § 1343

15. The factual allegations in paragraph 13 of this Indictment are incorporated by

reference as if fully set forth to allege a scheme and artifice to obtain money by materially false

representations.

16. On or about the dates set forth in each individual count, within the Western District

of Missouri and elsewhere, the defendants set forth in each individual count, aiding and abetting

each other and others, for the purpose of executing the above-described scheme and artifice to

obtain money by materially false representations, knowingly transmitted or caused to be

transmitted in interstate commerce by means of wire communications the following signs, signals

and sounds, each constituting a separate count of this Indictment, as follows:

COUNT DATE DEFENDANT(S) INTERSTATE TRANSMISSION
2 6/23/2020 (01) LAWRENCE COURTNEY Submission of electronic EIDL
LAWHORN a/k/a “Courtney application for the business entity
McAllister,” “Cooter,” “Coot,” “Lawrence Lawhorn”
(02) TINA BATTIE a/k/a “Tina Plant”

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 8 of 15
COUNT DATE DEFENDANT(S) INTERSTATE TRANSMISSION
3 6/24/2020 (01) LAWRENCE COURTNEY Submission of electronic EIDL
LAWHORN a/k/a “Courtney application for the business entity
McAllister,” “Cooter,” “Coot,” “Latoya Brown”
(02) TINA BATTIE a/k/a “Tina Plant,”
(03) LATOYA MARIE BROWN
4 6/25/2020 (01) LAWRENCE COURTNEY Submission of electronic EIDL
LAWHORN a/k/a “Courtney application for the business entity
McAllister,” “Cooter,” “Coot,” “Lauren Luque”
(02) TINA BATTIE a/k/a “Tina Plant,”
(04) LAUREN COURTNEY LUQUE
a/k/a “Apple”

17. All in violation of Title 18, United States Code, Sections 1343 and 2.

COUNTS 5 through 8
(Attempted Wire Fraud)
18 U.S.C. § 1349

18. The factual allegations of paragraph 13 of this Indictment are incorporated by

reference as if fully set forth to allege a scheme and artifice to obtain money by materially false

representations.

19. On or about the dates set forth in each individual count, within the Western District

of Missouri and elsewhere, the defendants set forth in each individual count, aiding and abetting

each other and others, for the purpose of executing the above-described scheme and artifice to

obtain money by materially false representations, knowingly transmitted or caused to be

transmitted in interstate commerce by means of wire communications the following signs, signals

and sounds, each constituting a separate count of this Indictment, as follows:

COUNT DATE DEFENDANT(S) INTERSTATE TRANSMISSION
5 06/23/2020 (01) LAWRENCE COURTNEY Submission of electronic EIDL
LAWHORN a/k/a “Courtney application for the business entity
McAllister,” “Cooter,” “Coot,” “Michael Stapleton”
(02) TINA BATTIE a/k/a “Tina Plant”

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 9 of 15
COUNT DATE DEFENDANT(S) INTERSTATE TRANSMISSION
6 06/24/2020 (01) LAWRENCE COURTNEY Submission of electronic EIDL
LAWHORN a/k/a “Courtney application for the business entity “Kathy
McAllister,” “Cooter,” “Coot,” Kimhang”
(02) TINA BATTIE a/k/a “Tina Plant”

7 06/24/2020 (01) LAWRENCE COURTNEY Submission of electronic EIDL
LAWHORN a/k/a “Courtney application for the business entity “Tiera
McAllister,” “Cooter,” “Coot,” Wallace”
(02) TINA BATTIE a/k/a “Tina Plant”

8 07/01/2020 (01) LAWRENCE COURTNEY Submission of electronic EIDL
LAWHORN a/k/a “Courtney application for the business entity
McAllister,” “Cooter,” “Coot,” “Marquez Lawhorn”
(02) TINA BATTIE a/k/a “Tina Plant”

20. All in violation of Title 18, United States Code, Sections 1343, 1349, and 2.

COUNT 9
(Conspiracy to Launder Money)
18 U.S.C. §§ 1956(a)(1)(B)(i) and (h)

21. On Between June 1, 2020, and July 31, 2020, said dates being approximate, in the

Western District of Missouri, and elsewhere, the defendants, (01) LAWRENCE COURTNEY

LAWHORN a/k/a “Courtney McAllister,” “Cooter,” “Coot,”, (02) TINA BATTIE a/k/a “Tina

Plant”, (03) LAUREN COURTNEY LUQUE a/k/a “Apple”, and (04) LATOYA MARIE

BROWN, knowingly and intentionally combined, conspired and agreed with each other, and

others, known and unknown to the Grand Jury, to commit offenses against the United States in

violation of Title 18, United States Code, Section 1956, to wit: to knowingly conduct and attempt

to conduct financial transactions affecting interstate commerce and foreign commerce, which

transactions involved the proceeds of specified unlawful activity, that is, wire fraud, as charged in

Counts 2, 3, and 4 of this Indictment, knowing that the transactions were designed in whole or in

part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 10 of 15
specified unlawful activity, and that while conducting and attempting to conduct such financial

transactions, knew that the property involved in the financial transactions represented the proceeds

of some form of unlawful activity, contrary to the provisions of Title 18, United States Code,

Section 1956(a)(1)(B)(i), all in violation of Title 18, United States Code, Section 1956(h).

Manner and Means

22. The members of the conspiracy used various manners and means to effect the

objects and purposes of the conspiracy, including but not limited to the following:

a. On or about June 25, 2020, $10,000.00 from the United States Treasury was

deposited into BROWN’S BMO Harris bank account based on the EIDL application

submitted for the business “Latoya Brown.”

b. On or about June 25, 2020, $10,000.00 from the United States Treasury

was deposited into LAWHORN’S Bank of America account based on the EIDL

application submitted for the business “Lawrence Lawhorn.”

c. On June 30, 2020, BROWN transferred $150.00 from BROWN’S BMO

Harris bank to LUQUE’S Cash App account via BROWN’S Cash App account.

BROWN’S Cash App account for the $150.00 transaction listed the subject as “Courtney.”

On June 30, 2020, BROWN transferred $4,000.00 from BROWN’S BMO Harris bank to

BATTIE’S Cash App account via BROWN’S Cash App account.

d. On or about June 30, 2020, $10,000.00 from the United States Treasury was

deposited into LUQUE’S Bank of America account based on the EIDL application

submitted for the business “Lauren Luque.”

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 11 of 15
e. On June 30, 2020, BATTIE transferred $3,500.00 from BATTIE’S Cash

App account to LUQUE’S Cash App account.

f. On June 30, 2020, LAWHORN and BATTIE renegotiated BATTIE’S

fees via text message.

g. On July 1, 2020, BROWN transferred $2,850.00 from BROWN’S BMO

Harris bank to LUQUE’S Cash App account via BROWN’S Cash App account. On July

1, 2020, BROWN transferred $1,000.00 from BROWN’S BMO Harris bank to

BATTIE’S Cash App account via BROWN’S Cash App account

h. On July 2, 2020, LUQUE transferred $6,175.37 from LUQUE’S Cash App

account to LUQUE’S Bank of American Account.

i. On July 2, 2020, BATTIE transferred $1,500.00 from BATTIE’S Cash

App account to A1 Empire Bank of America account.

j. On July 3, 2020, LUQUE transferred $2,000.00 from LUQUE’S Cash App

account to BATTIE’S Cash App account.

k. On July 3, 2020, BATTIE transferred $2,000.00 from BATTIE’S Cash

App account to A1 Empire Bank of America account.

l. On July 3, 2020, LUQUE transferred $12,151.00 from LUQUE’S Bank of

America account to LUQUE’S U.C. Union account. The $12,151.00 withdraw posted to

LUQUE’S Bank of America account on July 6, 2020.

m. On July 3, 2020, LUQUE withdrew $5,000.00 from LUQUE’S U.C. Union

account.

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 12 of 15
n. On July 6, 2020, LUQUE transferred $2,000.00 from LUQUE’S Bank of

America account to BATTIE’S Cash App account via LUQUE’S Cash App Account.

o. On July 7, 2020, BATTIE transferred $2,000.00 and $740.00 from

BATTIE’S Cash App account to A1 Empire Bank of America account.

p. On July 10, 2020, LUQUE withdrew $3,000.00 from LUQUE’S U.C.

Union account.

q. On July 13, 2020, LAWHORN withdrew $8,150.00 from LAWHORN’S

Bank of America account.

r. On July 22, 2020, BATTIE conducted a wire transfer of $6,000.00 from

A1 Empire Bank of America account to the NFCU account.

23. All in violation of Title 18, United States Code, Section 1956(h).

FORFEITURE ALLEGATION

24. The factual allegations of this Indictment are re-alleged and incorporated as though

fully set forth herein for the purpose of alleging forfeiture to the United States pursuant to the

provisions of Title 18, United States Code, Sections 981(a)(1)(A) and (C) and 982(a)(1) and

(2)(A), and Title 28, United States Code, Section 2461.

25. As a result of the offenses alleged in this Indictment, and pursuant to Title 18,

United States Code, Sections 981(a)(1)(A) and (C) and 982(a)(1) and (2)(A) and Title 28, United

States Code, Section 2461, the defendants:

a. (01) LAWRENCE COURTNEY LAWHORN a/k/a “Courtney

McAllister,” “Cooter,” “Coot” in relation to offenses alleged in Counts 1-9;

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 13 of 15
b. (02) TINA BATTIE a/k/a “Tina Plant”, in relation to offenses alleged in

Counts 1-9;

c. (04) LAUREN COURTNEY LUQUE a/k/a “Apple”, in relation to

offenses alleged in Counts 1, 4 and 9; and

d. (03) LATOYA MARIE BROWN in relation to offenses alleged in Counts

1, 3 and 9;

shall forfeit to the United States all property, real and personal, constituting and involved in and

derived from any proceeds the defendant obtained directly and indirectly as a result of the

violations incorporated by reference in this Allegation.

Money Judgment

26. A money judgment representing proceeds obtained by the defendants referenced in

paragraph 25 of this forfeiture allegation, in that the sum in aggregate constitutes and derived from

proceeds traceable to the offenses set forth in the counts related to the defendants referenced in

paragraph 25 of this forfeiture allegation and all property involved in and derived from proceeds

from the money laundering offense.

Substitute Assets

27. If any of the above-described forfeitable property, as a result of any act or omission

of the defendant:

a. cannot be located upon the exercise of due diligence;

b. has been transferred, sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 14 of 15
e. has been commingled with other property which cannot be divided without

difficulty;

it is the intention of the United States, pursuant to Title 21, United States Code, Section 853(p) as

incorporated by Title 28, United States Code, Section 2461(c), to seek forfeiture of any other

property of the defendant up to the value of forfeitable property.

A TRUE BILL.

/s/ Casey Castrop
FOREPERSON OF THE GRAND JURY

/s/ Aaron M. Maness
Aaron M. Maness
Assistant United States Attorney
Missouri Bar No. 63666

Dated: 02/08/2022

Case 2:22-cr-04013-BCW Document 1 Filed 02/08/22 Page 15 of 15

File and source

File: 1-indictment.pdf
Size: 289,506 bytes
SHA-256: 33fe662a0579ebf865ba0c8e46181b983a180348c30ea49c32c6a8e0e370ae53
Our copy: 1-indictment.pdf
Original: archive.org