Download Mcafee Complaint
Approved: __________________________________ SAMSON ENZER / ELIZABETH HANFT Assistant United States Attorneys Before: THE HONORABLE GABRIEL W. GORENSTEIN United States Magistrate Judge Southern District of New York - - - - - - - - - - - - - - - - x 21 MAG 1600 : UNITED STATES OF AMERICA : SEALED COMPLAINT : - v. - : Violations of : 18 U.S.C. §§ 371, JOHN DAVID MCAFEE, : 1343, 1349, 1956 and 2. : Defendant. : COUNTY OF OFFENSES: : New York - - - - - - - - - - - - - - - - X SOUTHERN DISTRICT OF NEW YORK, ss.: BRANDON RACZ, being duly sworn, deposes and says that he is a Special Agent with the Federal Bureau of Investigation (“FBI”) and charges as follows: COUNT ONE (Commodities and Securities Fraud Conspiracy: Scalping) 1. From at least in or about December 2017, up to and including in or about October 2018, in the Southern District of New York and elsewhere, JOHN DAVID MCAFEE, the defendant, and a co-conspirator not named as a defendant herein (“CC-1”), as well as others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit offenses against the United States, to wit, commodities fraud, in violation of Title 7, United States Code, Sections 9(1) and 13(a)(5), and Title 17, Code of Federal Regulations, Section 180.1(a), and securities fraud, in violation of Title 15, United States Code, Sections 78j(b) and 78ff, and Title 17, Code of Federal Regulations, Section 240.10b-5. 2. It was a part and an object of the conspiracy that JOHN DAVID MCAFEE, the defendant, and CC-1,
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