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Michelle Schramm Indictment
Michelle Schramm Indictment
Plaintiff,
v.
1. MICHELLE SCHRAMM,
a/k/a UK CHIN SCHRAMM,
Defendant.
INDICTMENT
18 U.S.C. § 1952(a)(3) & (b)
18 U.S.C. § 2422(a)
18 U.S.C. § 1957(a)
26 U.S.C. § 7206(1)
18 U.S.C. § 982(a)(1)
COUNTS 1 - 24
(Travel Act – Use of Interstate Facility to Promote a Business
Enterprise Involving Prostitution Offenses)
through and including March 17, 2009, in the State and District of
Metropolitan area. The three businesses were: (1) Bali Spa located
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services.
“Johns”).
SCHRAMM and was responsible for providing the money collected from
2
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3
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4
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COUNT 25
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for which any person can be charged with a criminal offense, and
COUNT 26
for which any person can be charged with a criminal offense, and
COUNT 27
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for which any person can be charged with a criminal offense, and
COUNTS 28 - 31
(Engaging in Monetary Transaction in Property Derived from
Specified Unlawful Activity & Aiding and Abetting)
violation of Title 18, U.S.C. 2422(a), and aided and abetted the
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COUNT 32
(Filing False Tax Return)
did willfully make and subscribe a false U.S. Individual Income Tax
Return, Form 1040, for the year 2006, which was verified by a
was filed with the Internal Revenue Service, which said return the
$97,785 (line 12 of Form 1040) which Defendant then and there well
knew and believed was false and understated the amount of business
income.
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COUNT 33
(Filing False Tax Return)
did willfully make and subscribe a false U.S. Individual Income Tax
Return, Form 1040, for the year 2007, which was verified by a
was filed with the Internal Revenue Service, which said return the
$128,524 (line 12 of Form 1040) which Defendant then and there well
knew and believed was false and understated the amount of business
income.
FORFEITURE ALLEGATION
United States Code, Section 2461(c), Title 18, United States Code,
Section 2428, and Title 18, United States Code, Section 982.
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18, United States Code, Section 981(a)(1)(C), and Title 28, United
States Code, Section 2461(c) any and all of the defendants’ right,
Title 18, United States Code, Section 2428, any and all of the
property.
Section 2461(c), Title 18, United States Code, Section 2428, for
the violations described herein include, but are not limited to:
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the scheme and by the defendant, for violations of Title 18, United
States Code, 1952; and
any and all of the defendant(s)’ right, title and interest in all
States Code, Section 982(b) and Title 28, United States Code,
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A TRUE BILL:
JOHN F. WALSH
United States Attorney
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(Rev. 05/05)
YOB: 1955
ADDRESS: Unknown
OFFENSE: - Counts 1 - 24, 18 U.S.C. §1952 (Travel Act – Use of Interstate Facility to
Promote a Business Enterprise Involving Prostitution Offenses)
Counts 32 and 33, 26 U.S.C. § 7206(1) (Filing a False Income Tax Return)
PENALTY:
Counts 1 to 24: NMT 5 years imprisonment, a $250,000 fine, or both; NMT 3 years supervised
release; and a $100 Special Assessment Fee (each count)
Counts 25 - 27: NMT 20 years imprisonment, a $250,000 fine, or both; NMT 3 years supervised
release; and a $100 Special Assessment Fee (each count)
Counts 28-31: NMT 10 years imprisonment, a $250,000 fine, or both; NMT 3 years supervised
release; $100 Special Assessment Fee
Counts 32-33: NMT 3 years imprisonment, a $100,000 fine, or both; NMT 1 years supervised
release; and a $100 Special Assessment Fee (each count)
Dennis Adams, Eric Smith, Brad Zborowski and Mark Ortler, Investigators
Arapahoe County Sheriff’s Office
THE GOVERNMENT
X will seek pretrial detention in this case will not seek pretrial detention in this case
The statutory presumption of detention is not applicable to this defendant. (Circle one)
OCDETF CASE: Yes X No