Caroline Boyle's Indictment

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Case 1:17-cr-00080-RM Document 10 Filed 03/16/17 USDC Colorado Page 1 of 3

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLORADO

Criminal Case No. 17-mj-01043-CBS 17-cr-80-RM


UNITED STATES OF AMERICA ,
Plaintiff,

v.

1. CAROLINE ZARATE BOYLE

Defendant.

INDICTMENT
FORGED WRITING
18 U.S.C. 495

The Grand Jury charges:

1. On or about December 21, 2016, in the State and District of Colorado,

Defendant, Caroline Zarate Boyle, with intent to defraud the United States, did

transmit and present to an officer of the United States a false, forged, and

counterfeited writing in support of and in relation to an account and claim.

Specifically, Defendant, an employee of the U.S. Postal Service, did transmit and

present to her supervisor, via e-mail, a false, forged, and counterfeited note

appearing to be from physician I.H. Said note falsely represented that the doctor

was treating Defendant for non-Hodgkin lymphoma (NHL) and stated that the

doctor was advising [Defendant] to take off from work so she can focus on her

treatment. Defendant transmitted and presented such writing to support requests


Case 1:17-cr-00080-RM Document 10 Filed 03/16/17 USDC Colorado Page 2 of 3

for paid leave and other accommodations. In doing so, Defendant violated 18 U.S.C.

495 (2012).

Notice of Forfeiture

2. The allegations contained in this Indictment are hereby re-alleged and

incorporated by reference for the purpose of alleging forfeiture pursuant to the

provisions of 18 U.S.C. 492 (2012).

3. Upon conviction of the offense alleged in this Indictment, Defendant

shall forfeit to the United States, pursuant to 492, any articles, devices, and other

things made, possessed, used or intended to be used to commit the offense.

4. If any of the property just described, as a result of any act or omission of

Defendant:

cannot be located upon 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 without

difficulty;

it is the intent of the United States, pursuant to 21 U.S.C. 853(p) (2012), as

appropriate, to seek forfeiture of any other property of Defendant, up to the value of

the forfeitable property described above.

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Case 1:17-cr-00080-RM Document 10 Filed 03/16/17 USDC Colorado Page 3 of 3

DATED this 16th day of March, 2017.

A TRUE BILL

Ink signature on file in Clerks Office


Foreperson

Robert C. Troyer
Acting U.S. Attorney

s.Daniel E. Burrows
Daniel E. Burrows
U.S. Attorneys Office
1801 California St.
Suite 1600
Denver, CO 80202
Telephone: (303) 454-0100
FAX: (303) 454-0409
E-mail: daniel.burrows@usdoj.gov
Special Assistant U.S. Attorney

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