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Marshall Indictment
Marshall Indictment
FILED
TIMOTHY J. RACICOT
Assistant U.S. Attorney /JUL 22 2020
U.S. Attorney's Office Clerk, U.S Courts
P.O. Box 8329 District Of Montana
Missoula Division
Missoula, MT 59807
105 E. Pine, 2d Floor
Missoula, MT 59802
Phone: (406) 542-8851
Fax: (406)542-1476
E-mail: [email protected]
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FORFEITURE
Title 18 U.S.C. § 981(a)(l)(C)
Title 28 U.S.C. § 2461(c)
Title 18 U.S.C. § 982(a)(l)
COUNT!
THE SCHEME TO DEFRAUD
March 21, 2016, at Whitefish, within Flathead County, in the State and District of
with the intent to defraud, knowingly devised a scheme and plan for obtaining
MARSHALL, convinced John Doe (true name withheld to protect privacy) he was
a former CIA agent and a former member of an elite Force Reconnaissance unit in
the United States Marine Corps who had engaged in covert missions around the
world. In truth and in fact, MARSHALL was never employed as a CIA agent and
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To further execute the scheme, MARSHALL asked John Doe to fund "off
the books" missions for the CIA, which MARSHALL said would involve assault
teams that he would lead on rescue and other operations in foreign countries.
representations, promises, and omissions, John Doe wired large sums of money to
MARSHALL on at least six separate occasions, all under the guise of funding
not conduct any of the "missions" and used the money he received from John Doe
for personal living expenses, personal travel, and loans and gifts to friends and
business associates.
INTERSTATE WIRES
an online communication from John Doe in Montana to Wells Fargo Bank in San
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COUNT II
affecting interstate and foreign commerce, that is, he transferred $300,000 from his
Wells Fargo Bank savings account, account number ending in 8645, to his Wells
Fargo Bank checking account, account number ending in 5396, such money having
been derived from specified unlawful activity, that is the wire fraud scheme as
COUNT III
affecting interstate and foreign commerce, that is, he presented check number
1725, drawn on his Wells Fargo Bank account, account number ending in 5396, in
the amount of $300,000, to High Threat Concealment, such money having been
derived from specified unlawful activity, that is the wire fraud scheme as described
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COUNT IV
$10,000, affecting interstate and foreign commerce, that is, he presented check
number 1737, drawn on his Wells Fargo Bank account, account number ending in
5396, in the amount of $37,697, to Eisinger Motors, such money having been
derived from specified unlawful activity, that is the wire fraud scheme as described
COUNTY
affecting interstate and foreign commerce, that is, he deposited $200,000 into his
Wells Fargo Bank savings account, account number ending in 8645 , such money
having been derived from specified unlawful activity, that is wire fraud as
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COUNT VI
On or about April 29, 2016, at Kalispell, in Flathead County, in the State and
affecting interstate and foreign commerce, that is, he transferred $140,000 from his
Wells Fargo Bank savings account, account number ending in 8645, to his Wells
Fargo Bank checking account, account number ending in 5396, such money having
been derived from specified unlawful activity, that is wire fraud as described in
COUNT VII
affecting interstate and foreign commerce, that is, he presented check 1776, drawn
on his Wells Fargo Bank checking account, account number ending in 5396, in the
money having been derived from specified unlawful activity, that is wire fraud as
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COUNT VIII
MARSHALL, did willfully attempt to evade and defeat a large part of the income
tax due and owing by him to the United States of America for the calendar year
2013, by filing and causing to be filed with the Internal Revenue Service a false
and fraudulent United States Individual Income Tax Return, Form 1040, wherein
he failed to report all his taxable income for the calendar year 2013, and as he then
and there well knew and believed, there was an additional tax due and owing to the
COUNT IX
MARSHALL, did willfully attempt to evade and defeat a large part of the income
tax due and owing by him to the United States of America for the calendar year
2014, by filing and causing to be filed with the Internal Revenue Service a false
and fraudulent United States Individual Income Tax Return, Form 1040, wherein
he failed to report all his taxable income for the calendar year 2014, and as he then
and there well knew and believed, there was an additional tax due and owing to the
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COUNTX
MARSHALL, did willfully attempt to evade and defeat a large part of the income
tax due and owing by him to the United States of America for the calendar year
2015, by filing and causing to be filed with the Internal Revenue Service a false
and fraudulent United States Individual Income Tax Return, Form 1040, wherein
he failed to report all his taxable income for the calendar year 2015, and as he then
and there well knew and believed, there was an additional tax due and owing to the
FORFEITURE
Upon conviction of the wire fraud offense set forth in count I, the defendant,
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forfeiture:
all right, title, and interest in property, real and personal, involved in said
forfeiture:
A TRUE BILL.
Foreperson signature redacted. Original document filed under seal.
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