Indictment Against Scott Beard

UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
FILED 17FEBJ1616142 IJSDCORE
EUGENE DIVISION
UNITED STATES OF AMERICA

v.
Case No. 6:16-CR-
INDICTMENT
SCOTT RAYMOND BEARD,

KRISTA JEAN MUDRICK
Counts 1 & 2: Theft Concerning

Program Receiving Federal Funds
18 U.S.C. 666(a)(l)(A)
Defendants.
Counts 3 & 4 Money Laundering

18 U.S.C. 1956(a)(l)(B)(i) and 2
Count 5: Passport Fraud
18 U.S.C. 1542
Count 6: False Statement
18 U.S.C. 1001
Forfeiture Allegations
28 U.S.C. 2461(c)
18 U.S.C. 98l(a)(l)(C)
18 U.S.C. 982(a)(l)
THE GRAND JURY CHARGES:

Introduction and Overview
1)
Deschutes County is a government agency in the State of Oregon. In
both 2014 and 2015 Deschutes County received more than $10,000 in federal
benefits and assistance.
2)
The Deschutes County Sheriffs Office, known hereinafter as "DCSO,"
is a law enforcement agency within Deschutes County, Oregon.
3)
The Central Oregon Drug Enforcement Task Force, known hereinafter
as "CODE," is a multi-agency drug enforcement task force which investigates illegal

drug trafficking in Central Oregon. One of its participating agencies is the DCSO.
CODE is funded by multiple sources, including federal funds which originate from
the U.S. Department of Health and Human Services, Office of National Drug
Control.
4)
Deschutes County is the fiduciary for CODE, responsible for managing
the budgeting process and providing funds to law enforcement for illegal drug
trafficking investigations. Defendant SCOTT RAYMOND BEARD is a Captain for
the DCSO, in charge of the Detectives Division. His official responsibilities include
approving funding requests by CODE and DCSO for undercover drug purchases and
expenses related to witnesses.
5)
When CODE or DCSO detectives need cash for covert drug purchases,
or to pay witness expenses, they contact defendant BEARD. Defendant BEARD

then reviews and approves paperwork requesting that funds from the Deschutes
County Finance Department be provided to CODE or DCSO. Based on those
requests, the Deschutes County Finance Department issues checks made payable to
defendant BEARD. Defendant BEARD cashes the checks and is responsible for
delivering the cash to CODE or DCSO.
6)
When CODE or DCSO officers seize cash or other items of value they
are secured in an evidence room at the DCSO. Defendant BEARD's responsibilities

include ensuring seized funds are transferred to the Deschutes County Finance
Department, to be deposited into a segregated bank account until particular cases

are completed and seized funds are ordered forfeited or returned.
7)
Defendant KRISTA JEAN MUDRICK was an employee of the DCSO
from February 2011 until March 2013. Defendant BEARD was one of defendant
MUDRICK's supervisors. Beginning at a date unknown to the grand jury, but at
least by October 2013, the two commenced a sexual relationship which continued
until at least September 2015.
The Scheme to Embezzle and Steal Public Funds

8)
Beginning at a date unknown to the grand jury but at least by January
2014, defendant BEARD devised a scheme to embezzle, steal, and obtain by fraud,
money from Deschutes County to pay for personal items, to include Krista Jean
Mudrick's expenses for: monthly rent; household expenses; international and
domestic vacations; a Harley Davidson motorcycle; concert tickets; gym membership
and tanning fees; and cosmetic surgeries.
9)
One manner in which defendant BEARD accomplished his scheme was
to embezzle, steal, and obtain by fraud funds intended to be used by CODE or

DCSO for undercover drug purchases and witness expenses. Defendant BEARD did
so by causing inflated or fictitious funding requests to be sent to the Deschutes
County Finance Department on behalf of CODE and DCSO. Relying on these false
representations, the Deschutes County Finance Department issued checks payable
to defendant BEARD, which he cashed. Instead of providing the cash to CODE or
DCSO, as he was required to do, defendant BEARD kept all of the funds, or a
substantial amount of the funds, for his own personal use. Defendant BEARD also
forged and fabricated documentation making it appear as though funds that he
stole had been provided to law enforcement or used to pay witness expenses. Thefts
involving defendant BEARD's fraudulent funding requests to the Deschutes County
Finance Department occurred from January 2014 through September 2015 and
totaled approximately $136,000.
10)
Another manner in which defendant BEARD accomplished his scheme
was to embezzle, steal, and obtain by fraud money which had been seized by CODE
and DCSO officers during drug enforcement operations. Instead of delivering seized
cash, coins, and precious metals to the Deschutes County Finance Department, as
he was required to do, defendant BEARD stole the funds. Defendant BEARD's
thefts of seized currency and precious metals occurred from September 2014
through September 2015 and totaled about $69, 747.
11)
During the course of his scheme, defendant BEARD embezzled, stole,
and obtained by fraud a total of approximately $205,747.
COUNT 1
(Theft Concerning Program Receiving Federal Funds)
Paragraphs 1through11 are hereby re-alleged and incorporated as though
set forth in full herein.
Deschutes County is a government agency that received federal assistance in
excess of $10,000 during the one year period beginning January 1, 2014 and ending
December 31, 2014.
Defendant SCOTT RAYMOND BEARD is an agent of Deschutes County in

that he is a DCSO employee.
Between January 1, 2014 and December 31, 2014, defendant SCOTT
RAYMOND BEARD did knowingly embezzle, steal, and obtain by fraud
approximately $78,900 under the care, custody and control of Deschutes County;
In violation of Title 18, United States Code, Section 666(a)(l)(A).
COUNT2
(Theft Concerning Program Receiving Federal Funds)
Deschutes County is a government agency that received federal assistance in
excess of $10,000 during the one year period beginning January 1, 2015 and ending
December 31, 2015.
Defendant SCOTT RAYMOND BEARD is an agent of Deschutes County in
that he is a DCSO employee.
From January 2015 through September, 2015, defendant SCOTT RAYMOND
BEARD did knowingly embezzle, steal, and obtain by fraud approximately $126,847
under the care, custody and control of Deschutes County;
In violation of Title 18, United State Code, Section 666(a)(l)(A).
COUNT 3
(Money Laundering)
On or about April 24, 2015, in the District of Oregon, defendant SCOTT

RAYMOND BEARD, did knowingly conduct and attempt to conduct a financial
transaction affecting interstate and foreign commerce, to wit, he purchased a 2009
Harley Davidson motorcycle for $6, 700 in cash, which involved the proceeds of a
specified unlawful activity, i.e., theft concerning a program receiving federal funds
as described in Counts 1 and 2, knowing that the transaction was designed in whole
and in part to conceal and disguise the nature, location, source, ownership, and
control of the proceeds of said specified unlawful activity and that while conducting
and attempting to conduct such financial transaction knew that the property
involved in the financial transaction represented the proceeds of some form of
unlawful activity.
In violation of Title 18, United States Code, Sections 1956(a)(l)(B)(i) and 2.
COUNT4
(Money Laundering)
Paragraphs 1 through 11 are hereby re-alleged and incorporated as though
In late July and early August 2015, in the District of Oregon, defendant
SCOTT RAYMOND BEARD did knowingly conduct and attempt to conduct a
financial transaction affecting interstate and foreign commerce, to wit, he deposited
or caused to be deposited $14,650 in cash into an account in the name of Krista
Mudrick, to pay for her bilateral breast augmentation, mastopexy, and
abdominoplasty procedures, which involved the proceeds of a specified unlawful
activity, i.e., theft concerning a program receiving federal funds as described in

Counts 1 and 2, knowing that the transactions were designed in whole and in part
to conceal and disguise, the nature, location, source, ownership, and control of the
proceeds of said 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.
In violation of Title 18, United States Code, Sections 1956(a)(l)(B)(i) and 2.
COUNT 5
(Passport Fraud)
On or about September 23, 2014, in the District of Oregon and elsewhere,
defendant SCOTT RAYMOND BEARD willfully and knowingly made a false
statement in an application for a passport with intent to induce and secure for his
own use the issuance of a passport under the authority of the United States,
contrary to the laws regulating the issuance of such passports and the rules
prescribed pursuant to such laws, in that in such application defendant SCOTT
RAYMOND BEARD declared under penalty of perjury that he had lost his
previously issued United States passport during a move, which statement he knew
to be false.
In violation of Title 18, United States Code, Section 1542.
COUNT 6
(False Statement)
On or about October 6, 2015, in the District of Oregon, defendant KRISTA
JEAN MUDRICK, did willfully and knowingly make a materially false, fictitious,
and fraudulent statement and representation in a matter within the jurisdiction of
the executive branch of the Government of the United States, by stating to agents of
the Federal Bureau of Investigation and Internal Revenue Service that Scott Beard
did not help pay for her Harley Davidson motorcycle, that she paid cash for the
motorcycle from money she earned from her business, that other than $600 Scott
Beard had not provided any funds for her, that Scott Beard did not pay airfare and
hotel expenses related to a trip they took to Amsterdam and South Africa, and that
she had no romantic relationship with Scott Beard.
These statements and representations were materially false because, as
defendant KRISTA JEAN MUDRICK then and there knew, Scott Beard paid $6,700
in cash for her motorcycle, that she did not pay for the motorcycle with funds she
earned from her business, that Scott Beard had provided her at least $100,000 in
cash and money orders, including airfare and hotel expenses for a trip to
Amsterdam and South Africa, and that she had a sexual relationship with Scott
Beard.
In violation of Title 18, United States Code, Section 1001.
FIRST FORFEITURE ALLEGATION

Upon conviction of one or more of the offenses in Counts 1 and 2 of this
Indictment, defendant SCOTT RAYMOND BEARD shall forfeit to the United
8
States, pursuant to Title 18, United States Code, Section 98l(a)(l)(C) and Title 28,
United States Code, Section 246l(c), any property, real or personal, which
constitutes or is derived from proceeds traceable to the offense, including, but not
limited to:
1. MONEY JUDGMENT
A sum of money in United States Currency, representing the amount
of proceeds obtained as a result of the offense, in the form of a money judgment.
2.
If any of the property described above, as a result of any act or
omission of the defendant[s]:

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 beyond the 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,
it is the intent of the United States, pursuant to Title 21, United States Code,
Section 853(p) as incorporated by Title 28, United States Code, Section 246l(c), to
seek forfeiture of any other property of said defendant up to the value of the
forfeitable property described above.
SECOND FORFEITURE ALLEGATION

Upon conviction of one or more of the offenses alleged in Counts 3 and 4 of
this Indictment, defendant SCOTT RAYMOND BEARD shall forfeit to the United
States pursuant to Title 18, United States Code, Section 982(a)(l), all.property, real
and personal, involved in the money laundering offenses and all property traceable
to such property, including but not limited to the following:
1. MONEY JUDGMENT
A sum of money in United States Currency, representing the amount

of proceeds obtained as a result of the offense, in the form of a money judgment.
2. MOTORCYCLE
A 2009 Harley Davidson motorcycle.
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 or 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
(e) has been commingled with other property which cannot be divided
without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code,
Section 853(p) as incorporated by Title 18, United States Code, Section 982(b) and
Title 28, United States Code, Section 246l(c), to seek forfeiture of any other
10
property of said defendant(s) up to the value of the forfeitable property described

above.
Dated this
_j2 day of February 2016.
Presented by:
BILLY J. WILLIAMS
y
r
Assistant United States Attorney
11

Indictment Against Scott Beard

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Indictment Against Scott Beard

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UNITED STATES DISTRICT COURT

FILED 17FEBJ1616142 IJSDCORE

UNITED STATES OF AMERICA

Case No. 6:16-CR-

SCOTT RAYMOND BEARD,

Counts 1 & 2: Theft Concerning

Counts 3 & 4 Money Laundering

THE GRAND JURY CHARGES:

Deschutes County is a government agency in the State of Oregon. In

The Deschutes County Sheriffs Office, known hereinafter as "DCSO,"

is a law enforcement agency within Deschutes County, Oregon.

The Central Oregon Drug Enforcement Task Force, known hereinafter

as "CODE," is a multi-agency drug enforcement task force which investigates illegal

Deschutes County is the fiduciary for CODE, responsible for managing

or to pay witness expenses, they contact defendant BEARD. Defendant BEARD

are secured in an evidence room at the DCSO. Defendant BEARD's responsibilities

Department, to be deposited into a segregated bank account until particular cases

Defendant KRISTA JEAN MUDRICK was an employee of the DCSO

The Scheme to Embezzle and Steal Public Funds

Beginning at a date unknown to the grand jury but at least by January

One manner in which defendant BEARD accomplished his scheme was

to embezzle, steal, and obtain by fraud funds intended to be used by CODE or

Another manner in which defendant BEARD accomplished his scheme

During the course of his scheme, defendant BEARD embezzled, stole,

and obtained by fraud a total of approximately $205,747.

Defendant SCOTT RAYMOND BEARD is an agent of Deschutes County in

On or about April 24, 2015, in the District of Oregon, defendant SCOTT

activity, i.e., theft concerning a program receiving federal funds as described in

FIRST FORFEITURE ALLEGATION

If any of the property described above, as a result of any act or

omission of the defendant[s]:

cannot be located upon the exercise of due diligence;

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

has been placed beyond the jurisdiction of the court;

has been substantially diminished in value; or

has been commingled with other property which cannot be divided

SECOND FORFEITURE ALLEGATION

A sum of money in United States Currency, representing the amount

(c) has been placed beyond the jurisdiction of the court;

property of said defendant(s) up to the value of the forfeitable property described

_j2 day of February 2016.

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