Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 1 of 5 SEALED UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS MIDLAND-ODESSA DIVISION

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1 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 1 of 5 SEALED UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS MIDLAND-ODESSA DIVISION FILED WEcS JUN O14 DEPUTy UNITED STATES OF AMERICA, V. Plaintiff, CRIMINAL NO. INDICTMENT P1 [Vio: 18 U.S.C Wire Fraud] MICHAEL DANIEL SANCHEZ, Defendant. THE GRAND JURY CHARGES: Descrintion of the Fraudulent Scheme 1. At material times to this Indictment, Midland College operated a four-week training program that provided students with the necessary training (classroom and field) to obtain a commercial driver's license (CDL). 2. Upon successful completion of the program, the student would receive a certificate from Midland College, and would then be eligible to take the CDL exam with the State of Texas. 3. At material times to the Indictment, Michael Daniel Sanchez was the Midland College Director of Transportation. In that capacity, Sanchez managed the commercial truck driving program and instructors. 4. The cost to the student for the training program was $4,100, payable directly to Midland College. 5. Typically, Sanchez was the first point of contact for individuals interested in enrolling in the training program. 6. In October 2012, Sanchez began accepting payments directly from students, rather than

2 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 2 of 5 have the student go to the Midland College cashier window to pay the money to the college. In some instances, Sanchez charged the full $4,100 and never turned that money over to Midland College. In other instances, Sanchez charged a lesser amount, such as $2,000 or $2,500 and kept that amount as well. 7. In an effort to conceal the fraud, Sanchez, in some instances, would tell the student he/she was registered as a student, but would never formally enroll the student. Consequently, Midland College was not aware of the student who had not officially paid. 8. In other instances, for those students already formally enrolled, Sanchez would send an to the Midland College Administrator shortly after enrollment asking that a particular student be "dropped," or un-enrolled, so that Midland College would not expect any payment for the training program from that person. 9. In some instances, in an effort to conceal the fraud, Sanchez ed students a fake receipt for the money paid to Sanchez, but never given to Midland College. 10. In each instance, the students believed they were formally enrolled and that the certificate of completion was genuine. 11. Sanchez fraudulently obtained tuition monies from at least nine (9) students, thereby defrauding Midland College of approximately $36,900 COUNT ONE [18 U.S.C. 1343] Paragraphs 1 through 11 of the "Description of Fraudulent Scheme" section of the Indictment are hereby incorporated as if set forth in full. That from on or about October 1, 2012 through November 30, 2013, in the Western District of Texas and elsewhere, the Defendant,

3 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 3 of 5 MICHAEL DANIEL SANCHEZ, for the purpose of executing a scheme and artifice to defraud various individuals, and obtain money from those individuals by means of materially false and fraudulent pretenses, representations, and promises, intentionally and knowingly transmitted and caused to be transmitted information via wire, which process caused itings, signs and signals transmitted in interstate commerce. All in violation of Title 18, United States Code, Section UNITED STATES OF AMERICA'S NOTICE OF DEMAND FOR FORFIEITURE I. Wire Fraud Violations and Forfeiture Statutes [Title 18 U.S.C. 1343, subject to forfeiture pursuant to Title 18 U.S.C. 981(a)(1)(C), made applicable to criminal forfeiture by Title 28 U.S.C See Fed. R. Crim. P. 32.2] As a result of the foregoing criminal violation set forth in Count One, the United States of America gives notice to Defendants Michael Daniel Sanchez of its intent to seek forfeiture of the property described below upon conviction pursuant to Title 18 U.S.C. 981(a)(1)(C), made applicable to criminal forfeiture by Title 28 U.S.C. 2461, which states the following: Title 18 U.S.C Civil forfeiture (a)(1) The following property is subject to forfeiture to the United States: (C) Any property, real or personal, which constitutes or is derived from proceeds traceable to... any offense constituting "specified unlawful activity" (as defined in section 1956(c)(7) of this title), or a conspiracy to commit such offense. This notice of forfeiture includes but is not limited to the property described below. II. Money Judgment Money Judgment: A sum of money equal to Thirty-Six Thousand, Nine Hundred Dollars ($36,900.00) that represents proceeds traceable to the violation set forth in the count described above and for which Defendant Michael Daniel Sanchez is liable.

4 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 4 of 5 III. Substitute Assets If any of the money judgment described above as being subject to forfeiture for violations of Title 18 U.S.C and 1349, as a result of any act or omission of the Defendants named above: 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; it is the intent of the United States of America to seek forfeiture of any other property, up to the value of said money judgment, as substitute assets pursuant to Title 21 U.S.C. 853(p) and Fed. R. Crim. P. 32.2(e)(1). A TRUE BILL. Uriginal signed by the foreperson of the GEd JUry FORPERSON OF THE nand JURY ROBERT PITMAN UNITE STATES ATTORNEY AUSTIN M. BERRY Assistant United States Attorney

5 PERSONAL DATA SHEET (REDACTED) UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS Sealed MO 14CR 1 4 COUNTY: Midland DIVISION: MIDLAND/ODESSA JUDGE: DATE: June 25, 2014 MAGCT#: FBI#: CASE NO: MO-14-CR- DEFENDANT: Michael Daniel Sanchez ASSISTANT U.S. ATTORNEY: ADDRESS: XXXXXXXXXXXXXXXXXXXXXXXXX CITIZENSHIP: INTERPRETER NEEDED LANGUAGE: DEFENSE ATTORNEY: EMPLOYED APPOINTED DEFENDANT IS: Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 5 of 5 DOB: XXXXXXXXXX DATE OF ARREST: BENCH WARRANT: XXX PROBATION OFFICER: NAME AND ADDRESS OF SURETY: YOUTH CORRECTIONS ACT APPLICABLE: No PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct USC 1343 Wire fraud OFFENSE IS: FELONY MAXIMUM SENTENCE: Ct. 1 - A term of imprisonment not to exceed 20 years; a term of supervised release not to exceed 3 years; a fine not to exceed $250,000; and a mandatory $100 special assessment. PENALTY IS MANDATORY: As stated above. REMARKS: AGENT: Nicolas Aguado, FBI WDT-Cr-3