IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
UNITED STATES OF AMERICA
v.
BRADLEY ANDERSON,
Defendant.
INDICTMENT
18 U.S.C. §§ 1029(a)(I)
18 U.S.C. §§ 1029(a)(4)
18 U.S.C. §§ 1028(!l)(7)
18 U.S.C. §§ 1028A
."
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THE GRAND JURY CHARGES:
COUNT ONE
(Access Device Fraud - 18 U.S.C. §§ 1029(a)(I),(b)(I), (c)(l)(A)(i) and 2)
Beginning in January 2008 and continuing until April!, 2008, within the District ofOregon
and elsewhere, BRADLEY ANDERSON, defendant herein, did, knowingly and with the intent to
defraud, produce, use or traffic in or attempt to do the same, a counterfeit access device, namely a
card that had been re-encoded with another's access device infonnation linking it to Bank of
America Account Number #:XX:X:X:XXXX:X637, said conduct affecting interstate commerce; all in
violation of Title 18, United States Code, Section 1029(a)(I), (b)(I), (c)(I)(A)(i) and 2.
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COUNT TWO
(Access Device Fraud -18 U.S.C. §§ 1029(a)(I),(b)(1), (c)(l)(A)(i) and 2)
BeginningJanuary 2008 andcontinuing until April I, 2008, within the District ofOregonand
elsewhere, BRADLEY ANDERSON, defendant herein, did, knowingly and with the intent to
defraud, produce, use or traffic in or attempt to do the same, multiple counterfeit access devices,
namely cards that had been re-encoded with another's access device information linking it to Bank
of West account # XXXXXXXXXXXXX507, said conduct affecting interstate commerce; all in
violation of Title 18, United States Code, Section 1029(a)(1), (b)(l), (c)(l)(A)(i) and 2.
COUNT THREE
(Access Device Fraud - 18 U.S.C. §§ l029(a)(1),(b)(1), (c)(l)(A)(i) and 2)
Beginning in January 2008 and continuing until April!, 2008, within the District ofOregon
and elsewhere, BRADLEY ANDERSON, defendant herein, did, knowingly and with the intent to
defraud, produce, use or traffic in or attempt to do the same, a counterfeit access device, namely a
card that had been re-encoded with another's access device information linking it to Bank of
America account # XXXXXXXXXXXXX273, said conduct affecting interstate commerce; all in
violation of Title 18, United States Code, Section 1029(a)(!), (b)(!), (c)(l)(A)(i) and 2.
COUNT FOUR
(Access Device Fraud - 18 U.S.C. §§ l029(a)(1),(b)(1), (c)(l)(A)(i) and 2)
Beginning in January 2008 and continuing until April!, 2008, within the District ofOregon
and elsewhere, BRADLEY ANDERSON, defendant herein, did, knowingly and with the intent to
defraud, produce, use or traffic in or attempt to do the same, a counterfeit access device, namely a
card that had been re-encoded with another's access device information linking it to Bank of
America account # XXXXXXXXXXXXX033, said conduct affecting interstate commerce; all in
violation of Title 18, United States Code, Section 1029(a)(!), (b)(l) (c)(l)(A)(i) and 2.
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COUNT FIVE
(Access Device Fraud - 18 U.S.C. §§ I029(a)(4),(b)(I), (c)(I)(A)(ii) and 2)
Beginning in January 2008 and continuing until April 1,2008, withinthe District ofOregon
and elsewhere, BRADLEY ANDERSON, defendant herein, did, knowingly and with the intent to
defraud, produce, have control and custody of and possess device-making equipment that is
electronic equipment to make, print, encode and otherwise produce counterfeit access devices, said
conduct affecting interstate commerce; all in violation of Title 18, United States Code, Section
1029(a)(4), (b)(l), (c)(I)(AXii) and 2.
COUNT SIX
(Identity Theft - 18 U.S.C. § 1028(a)(7), (b)(2)(B), and (c)(3)(A)
On or about March 18,2008, in the District ofOregon, BRADLEYANDERSON, defendant
herein, knowingly transferred, possessed and used, in and affecting interstate commerce, without
lawful authority, a means of identification ofanother person, to wit: the credit card number of J.T.,
a person known to the grand jury, with the intent to commit, and to aid or abet, and in connection
with, any unlawful activity that constitutes a violation of federal law, and that constitutes a felony
violation under any applicable state or local law, to wit:
1. Wire Fraud in violation of Title 18, United States Code, Section 1343; and
2. Identity Theft, in violation of Oregon Revised Statutes 165.800;
all in violation of Title 18, United States Code, Section 1028(a)(7), (b)(2)(B), and (c)(3)(A).
COUNT SEVEN
(Aggravated Identity Theft - 18 U.S.C. § 1028A)
On or about March 23, 2008, within the District of Oregon, BRADLEY ANDERSON,
the defendant herein, did knowingly possess and use, without lawful authority, a means of
identification of another person during and in relation to a felony violation of Title 42, United
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States Code, Section 408(a)(7)(B), to wit: on or about March 23,2008, BRADLEY
ANDERSON, with the intent to deceive, falsely represented that social security number XXX-
XX-XX57 belonging to J.J., a person known to the grand jury, belonged to him in order to obtain
a credit card in J.1.'s name; all in violation of Title 18, United States Code, Section 1028A.
FORFEITURE ALLEGATION
Upon conviction of the offenses in violation of Title 18, United States Code, Section
1029 set forth in Counts 1-5 of this Indictment, BRADLEY ANDERSON, the defendant herein,
shall forfeit to the United States of America pursuant to 18 U.S.C. § 1029(c)(I)(C) and 18
U.S.C. § 982 (a)(2)(B) and 28 U.S.C. § 2461(c), any property constituting, or derived from,
proceeds obtained, directly or indirectly, as a result of such violations;
(B) pursuant to Title 18, United States Code, Section 1029(c)(l)(C), any personal
property used or intended to be used to commit the offenses any property constituting, or derived
from, proceeds obtained, directly or indirectly, as a result of such violations.
The property to be forfeited includes, but is not limited to:
a. $89.00 cash.
b. Nexus 40 inch flat screen t.v.
c. Cwnmins jet Scan money/check reader.
d. Element flat screen t.v., serial # FR7D0215610002821.
e. Philip dvd player, serial # KXIA0739931675.
f. Cool Pix Camera (in box).
g. Nikon D50 digital camera with light bar, # 3147203.
h. A HP Pavillion laptop computer gray/black, # CNF7446LSN.
1. A Toshiba Dyna Book laptop computer gray/black (no visible serial
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number).
J. A Toshiba hard drive, #: 36AH9152T6X3 ECA.
k. A Seagate external hard drive black/gray., #: 4LSIQHS2.
1. Two Linksys wireless routers, taped and wired together, #:
CONCI0937434.
m. A Cruzer thumb drive, blue in color (no visible serial number).
n. A Ativa thumb drive, white in color, # OOI73FID711).
o. A Lexar jump drive, red in color (no visible serial number).
p. A Verbatim thumb drive, red in color (no visible serial number).
q. A Apple Mac Book Laptop, gray in color (no visible serial number).
r. A PNYjump drive, purple in color (no visible serial number).
s. A Scandisk Micro Cruzer jump drive, white in color (no visible serial
number).
t. Skimmer molds.
u. Credit card readers
v. Kitchen aide mixer, #WU3829822.
w. Assorted card stock, blank credit card cards.
3. If any of the property described above, as a result of any act or omission
ofthe 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
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e. 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) as
incorporated by 18 U.S.C. § 982(b), 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 the offenses alleged in Count 5 of this Indictment, BRADLEY
ANDERSON, the defendant herein, shall forfeit to the United States pursuant to 18 U.S.C.
§ 1028 and 18 U.S.C. § 982 (a)(2)(B) and 28 U.S.C. § 2461(c) any property constituting or
derived from proceeds obtained directly or indirectly as a result of the said violations, and all
personal property used or intended to be used in this violation, including but not limited to the
following:
a. $89.00 cash.
b. Nexus 40 inch flat screen t.v.
c. Cummins jet Scan money/check reader.
d. Element flat screen t.v., serial # FR7D0215610002821.
e. Philip dvd player, serial # KXIA0739931675.
f. Cool Pix Camera (in box).
g. Nikon D50 digital camera with light bar, # 3147203.
h. A HP Pavillion laptop computer gray/black, # CNF7446LSN.
i. A Toshiba Dyna Book laptop computer gray/black (no visible serial
number).
J. A Toshiba hard drive, # 36AH9152T6X3 ECA.
k. A Seagate external hard drive black/gray, # 4LS1QHS2.
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1. Two Linksys wireless routers, taped and wired together, #
CGNCIG937434.
m. A Cruzer thumb drive, blue in color (no visible serial number).
n. A Ativa thumb drive, white in color, # 00173FID711.
o. A Lexar jump drive, red in color (no visible serial number).
p. A Verbatim thumb drive, red in color (no visible serial number).
q. A Apple Mac Book Laptop, gray in color (no visible serial number).
r. A PNYjump drive, purple in color (no visible serial number).
s. A Scandisk Micro Cruzer jump drive, white in color (no visible serial
number).
t. Skimmer molds.
u. Credit card readers.
v. Kitchen aide mixer, #WU3829822.
w. Assorted card stock, blank credit card cards.
If any of the above-described forfeitable property, as a result of any act or omission ofthe
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;
fill
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it is the intent ofthe United States, pursuant to 21 U.S.C. § 853(P) as incorporated by 18 U.S.C.
§ 982(b), to seek fotfeiture of any other property of said defendant(s) up to the value ofthe
fotfeitable property described above.
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Dated this /0 day of September 2008.
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