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IN THE UNITED STATES DISTRICT
COURT FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA v. WILLIAM C. SHELTON, Defendant. CRIMINAL NO: VIOLATIONS: 18 U.S.C. §1029 (Access Device Fraud) 18 U.S.C. §982(a)(2)(B) (Criminal Forfeiture) INFORMATION The United States hereby informs the Court that: COUNT ONE Between in or about August of 2010 and August of 2011, within the District of Columbia and elsewhere, defendant William C. Shelton, knowingly and with intent to defraud, trafficked in and used one or more authorized access devises, that is, a Wachovia Bank debit card issued to the Advisory Neighborhood Commission in Ward 5B, and by such conduct, obtained something of value aggregating $1,000 of more during a one-year period, such trafficking and use affected interstate commerce in that fraudulent credit and debit card transactions utilize banking channels for gaining authorization approval for charges. (Access Device Fraud, in violation of Title 18, United States Code, Section 1029(a)(2)) FORFEITURE ALLEGATION The violation alleged in Count One of this Information, Access Device Fraud, in violation of Title 18, United States Code, Section 1029(a)(2), is re-alleged and incorporated by reference herein for the purpose of alleging forfeiture to the United States of America, pursuant to the provisions of Title 18, United States Code, Section 982(a)(2)(b)). As a result of the offense alleged in Count One of this Information, the defendant in this Information, WILLIAM C. SHELTON, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(2)(B), any property constituting, or derived from proceeds obtained directly or indirectly, as a result of the said violation, including but not limited to:
By virtue of the commission of the offense charged in Count One of this Information, any and all interest that the defendant, William C. Shelton, has in the property constituting, or derived from, any proceeds obtained, directly or indirectly, as the result of the charged offense, is vested in the United States and hereby forfeited to the United States pursuant to Title 18, United States Code, Section 982(a)(2)(B), as a result of any act or omission of the defendant:
it is the intention of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the said defendant up to the value of said property listed above as being subject to forfeiture. (Criminal Forfeiture, Title 18, United States Code, Section 982(a)(2)(B)) Respectfully submitted, By: BRIDGET M. FITZPATRICK |
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