UNITED STATES DISTRICT COURT
DICTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA

v.

KEVIN TRUDEAU

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CRIMINAL NO. 90-10230H
VIOLATION:
      18 USC §1029(a)(2)
      Credit Card Fraud

INDICTMENT

COUNT ONE: (18 U.S.C. Section 1029(a)(2) - Credit Card Fraud)

The Grand Jury charges that:

From in or about October, 1984 to in or about May, 1990, at Boston and elsewhere in the District of Massachusetts,

KEVIN TRUDEAU

defendant herein, pursuant to a common and continuing scheme and plan, knowingly and with intent to defraud, did use unauthorized access devices to obtain things of value aggregating more than $1,000 during a one-year period, in that KEVIN TRUDEAU fraudulently used the following credit cards:

American Express No. 3728-389563-23003
American Express No. 3782-077975-41005
American Express No. 3719-033229-13019
American Express Nos. B=3719-033229-12003, 3782-005450-51012
American Express Nos. B=3782-055450-51004, 3783-639201-31006

thereby defrauding and obtaining from American Express, $122,735.68, more or less, and affecting interstate and foreign commerce.

All in violation of Title 18, United States Code, Section l029(a)(2).

COUNT TWO: (18 U.S.C. Section 1029(a)(2) - Credit Card Fraud)

The Grand Jury further charges that:

From in or about August, 1988 to in or about October, 1988, at Boston and elsewhere in the District of Massachusetts,

KEVIN TRUDEAU

defendant herein, pursuant to a common and continuing scheme and plan, knowingly and with intent to defraud, did use unauthorized access devices to obtain things of value aggregating more than

$1,000 during a one-year period, in that KEVIN TRUDEAU fraudulently used the following credit cards:

Chemical Bank No. 4211-5200-2569-6752
Bank of America No. 4024-0807-2034-7018
South Shore Bank No. 4164-2810-0011-0296
CitiBank No. 4271-3820-0022-8227
CitiBank No. 5319-4002-5770-8674
CitiBank No. 4128-8805-6305-6

thereby defrauding Chemical Bank, Bank of America, South Shore Bank, and Citibank and affecting interstate and foreign commerce.

All in violation of Title 18, United States Code, Section 1029(a)(2).

A TRUE BILL

/s/
__________________________
Foreman of the Grand Jury

/s/
__________________________
Assistant United States Attorney

DISTRICT OF MASSACHUSETTS, Sept 11, 1990 @ 3:04 PM

Returned into the District Court by the Grand Jury and filed.

__________________________
Marilyn Valentino
Deputy Clerk

This page was posted on August 26, 2005.

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