`
`Case: 1:09-cr-00528 Document #: 1 Filed: 06/18/09 Page 1 of 4 PagelD #:1a(
`Case: 1:09-cr-00528 Document #: 1 Filed: 06/18/09 Page 1 of 4 PageID #:1
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`
`JUDGE LEINENWERS=
`
`UNITED STATES OF AMERICA
`
`y.
`
`CHARLES PATTON,
`
`Defendant.
`
`)
`
`2
`
`)
`}
`
`INFORMATI
`
`CaseNo,
`
`MAGISTRATE JUDGE DENLOW
`OOCR52 8
`
`Violations:
`
`18 U.8.C.§ 2315
`18 U.S.C. § 981(a)(1)(C)
`28 U.S.C. § 2461(c)
`
`THE UNITED STATES OF AMERICA, THROUGHITS ATTORNEYS, CHARGES:
`
`l,
`
`For purposesofthis Information, the “relevant period”is that period from in or
`
`about March 2004 until in or about September 2008. During the relevant period, the defendant,
`
`CHARLES PATTON(“defendant”), was a memberofthe Illinois Army National Guard in
`
`Chicago, Illinois. From in or about March 2004until in or about March 2005,defendant’s friend
`
`and fellow Illinois Army National Guard member, Major Christopher West (“West”), was
`
`deployed to Bagram Airfield, Afghanistan as the “S4” in charge ofBase Operations.
`COUNTONEFILED
`JUN 18 2008 TC
`jON | ;, 204
`MICHAEL W, DOGBINS
`GLERK, U.S. DISTRICT COURT
`
`[18 U.S.C. § 2315 — Receipt of Stolen Property]
`During the relevant period, the defendant herein,
`ARL
`CHARLES PATTON:
`
`2.
`
`knowingly received, possessed, concealed, and stored moneyofthe value of $5,000 or more,
`
`which crossed a boundary of the United States after being stolen, unlawfully converted, and
`
`taken, knowing the moneyto have beenstolen, unlawfully converted, and taken; to wit,
`
`defendant received through the United States mail at his residence in the Northern District of
`
`Illinois from West in Afghanistan at least $100,000 in United States currency, which defendant
`
`
`
`
`Case: 1:09-cr-00528 Document #: 1 Filed: 06/18/09 Page 2 of 4 PageID #:2
`Case: 1:09-cr-00528 Document#: 1 Filed: 06/18/09 Page 2 of 4 PagelD #:2
`
`possessed, concealed, and stored, and which defendant knew had been stolen and otherwise
`
`unlawfully converted and taken by West in Afghanistan in an illegal scheme connected to the
`
`supply of concrete bunkers and barriers at Bagram Airfield.
`3.
`During his deployment to Afghanistan, West sent money he had stolen,
`
`unlawfully converted and taken to defendantat his residence in the Northern District ofIllinois.
`
`Upon receiving the money, which was hidden in a series of boxes sent via the United States mail
`
`by West, defendant possessed, concealed and stored the moneyin his residence.
`
`4.
`
`In or about the end of November 2004, upon West’s return from Afghanistan
`
`during mid-tour leave, West came to defendant’s residence and retrieved the money West had
`
`previously mailed to defendantat his residence.
`
`5.
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`Upon West’s return to Afghanistan in December 2004, West continued to send
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`boxes containing stolen and otherwise unlawfully converted money to defendantat his residence,
`
`which defendant received, possessed, concealed, and stored, knowing the money had beenstolen
`
`and otherwise unlawfully converted and taken by West in Afghanistan.
`
`6.
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`In or about early April 2005, West requested defendant open a safe deposit box in
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`defendant’s name, which he did on or about April 11, 2005. Into this safe deposit box, defendant
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`placed a large manila envelope containing approximately ten smaller sachets of money, each of
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`which held approximately ten thousand dollars. Defendantreceived this envelope of money from
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`West, knowing this money to have been stolen, unlawfully converted, and taken by West.
`
`7.
`
`During the remainder of the relevant period, defendant possessed, concealed, and
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`stored this money in his safe deposit box, periodically retrieving money for West, as requested,
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`some of which he deposited into his own bank account prior to remitting it to West.
`
`
`
`
`Case: 1:09-cr-00528 Document #: 1 Filed: 06/18/09 Page 3 of 4 PageID #:3
`Case: 1:09-cr-00528 Document #: 1 Filed: 06/18/09 Page 3 of 4 PagelD #:3
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`All in violation of Title 18, United States Code, Section 2315.
`
`RE
`CRIMINAL FORF
`[18 U.S.C. § 981(a)(1(C);
`28 U.S.C. § 2461 — Criminal Forfeiture]
`
`g.
`
`The allegations contained in paragraphs 1-7 of this Information are hereby re-
`
`alleged and incorporated by reference for the purposeof alleging forfeitures pursuant to 18
`
`U.S.C, § 981(a)(1(C) and 28 U.S.C, § 2461(c). Upon conviction ofthe offense in violation of
`
`18 U.S.C. § 2315 set forth in Count Oneofthis Information, defendant shall forfeit to the United
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`States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), any property, real or
`
`personal, which constitutes or is derived from proceeds traceable to the offense, including, but
`
`not limited to: $16,700 in United States currency seized from defendant’s safe deposit box
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`#1172 at Seaway National Bank on September 4, 2008.
`
`
`
`
`Case: 1:09-cr-00528 Document #: 1 Filed: 06/18/09 Page 4 of 4 PageID #:4
`Case: 1:09-cr-00528 Document #: 1 Filed: 06/18/09 Page 4 of 4 PagelD #:4
`
`9,
`If any of the property described above, as a result of any act or omission of
`defendant: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or
`
`sold to, or deposited with, a third party; (c) has been placed beyondthe jurisdiction of the Court,
`
`(d) has been substantially diminished in value; or (e) has been commingled with other property
`
`which cannot be divided without difficulty, the United States shall be entitled to forfeiture of
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`substitute property pursuant to 21 U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461(c).
`
`All pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28,
`United States Code, Section 2461(c).
`
`
`
`Christine A. Varney
`Assistant Attorney General
`Antitrust Division
`United States Department of Justice
`
` A. Yule.
`
`‘Phelan
`Lisa M.
`Chief, National Criminal Enforcement
`Antitrust Division
`United States Department of Justice
`
`Scott D. Hammond
`Deputy Assistant Attorney General
`Antitrust Division
`United States DepartmentofJustice
`
`
`
` Mare Siegel
`
`Director of Criminal Enforcement
`Antitrust Division
`United States Department of Justice
`
`\
`
`Pletcher
`Mark W.
`Emily W. Allen
`Antitrust Division
`United States Department of Justice
`450 Fifth Street, N.W.; Suite 11300
`Washington, D.C, 20530
`
`Dated: June (8, 2009
`
`
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