Free Redacted Document - District Court of Delaware - Delaware

, r. Case 1 :O7—cr—OOO64-SLB Document 15 Filed 05/10/2007 Page 1 of 4 _ ,
i IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ;
A Plaintiff, Z
v. Criminal Action No. 07- (OLII U K) A
RICHARD LAWRENCE, 2
V Defendant. @
INDICTMENT
The Federal Grand Jury for the District of Delaware charges that: _
Introduction
1. At all times relevant to this Indictment, Wilmington Trust Company, Wachovia
Bank and Citizens Bank were federally insured financial institutions, the deposits of which were
insured by the Federal Deposit Insurance Corporation, or FDIC.
Scheme t0 Defraud
2. Beginning in or around August 2004, and continuing at least until in or around
November 2004, Persons A and B, unindicted co-conspirators known to the grand jury, supplied
Richard Lawrence, the defendant, with at least thirty-tive counterfeit checks totaling over
$120,000. Persons A and B paid the defendant to negotiate the checks at various banks in and
around Delaware.
3. The face of each counterfeit check showed that it was issued to an individual, the
I Tl
I it I •
I l- . s
t .n-. iewrii i»4r i

` Case 1:07—cr—00064-SLB Doc`ument 15 Filed 05/10/2007 Page 2 of 4
conspirators known to the grand jury, supplied the defendant with identification, specifically,
fraudulent drivers’ licenses bearing the names of the payees on the checks.
4. After receiving each counterfeit check and piece of identification, Richard
Lawrence, the defendant, went to branches of the Wilmington Trust Company, Wachovia Bank
and Citizens Bank, showed the fraudulent identification, and cashed, or attempted to cash, each
check.
COUNT ONE
5. From on or about August 6, 2004, through on or about November 17, 2004, in the
District of Delaware and elsewhere, Richard Lawrence, the defendant, and Persons A and B,
unindicted co-conspirators known to the grand jury, did knowingly conspire with each other to
execute and attempt to execute a scheme and artifice to defraud the Wilmington Trust Company,
Wachovia Bank and Citizens Bank, federally insured financial institutions, as described more
fully in paragraphs 1 through 4 above, incorporated herein by reference, in violation of 18 U.S.C.
§ 1344, and in execution of the fraud and- in furtherance of the conspiracy, the defendant
committed the following overt acts: l
l a. On or about August 6, 2004, the defendant, using identification in the
name "B.R.", went to a Wachovia Bank branch and cashed a counterfeit check nominally payable
to B.R. in the amount of $3,496 drawn on the account of "H.L.";
b. On or about August 24, 2004, the defendant, using identification in the name
"N.B.", went to a Wachovia Bank branch and cashed a counterfeit check nominally payable to
N.B. in the amount of $4,962 drawn on the account of "D.G.";
2

( . Case 1:07—cr—00064-SLB Document 15 Filed 05/10/2007 Page 3 of 4 _ ’
c. On or about September 16, 2004, the defendant, using identification in the
name "J.K.", went to a Wilmington Trust Company branch and cashed a counterfeit check
nominally payable to J.K. in the amount of $1,709.21drawn on the account of "Applied Control
Engineering";
V d. On or about November 4, 2004, the defendant, using identification in the
name "R.H.", went to a Wachovia Bank branch and cashed a counterfeit check nominally
payable to R.H. in the amount of $2,700 drawn on the account of "Classic Settlements, lnc."; and
e. On or about November 15, 2004, the defendant, using identification in the
name "Y.N.", went to a Citizens Bank branch and cashed a counterfeit check nominally payable
to Y.N. in the amount of $2,950 drawn on the account of "Y.N."
All in violation ofTit1e 18, United States Code, Section 1349.
COUNT TWO
1 6. From in or around August 2004, through in or around November 2004, in the
District of Delaware and elsewhere, Richard Lawrence, the defendant, did knowingly use,
U without lawful authority, means of identification of at least fifteen persons during and in relation
to a violation of the bank fraud statute, 18 U.S.C. § 1344, and the bank fraud conspiracy statute,
18 U.S.C. § 1349, as described in paragraphs 1 through 5 above, incorporated herein by
/ / S /
3 U U l

Case 1:07-cr-00064-SLR Document 15 Filed 05/10/2007 Page 4 of 4
AITRUE BILL:
Forepersen
COLM F. CONNOLLY
United States { terney U
BY: S I ·
Beth M0sk0w-Schnoll
Assistant United States Attorney
Dated: May 10, 2007
I