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Case 1:08-cr-00311-PLF-JMF Document 1 Filed 10/07/08 Page 1 of 3

UNITED STATS DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v.

SEAN JACKSON,

Defendant.

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CRIMINAL NO.

VIOLATION: 18 U.S. C. § 1343
(Wire Fraud)

INFORMATION

The United States Attorney informs the Court that:

Count One

I.

Introduction

At all times material to this Information:

1.

Computer World Services Corporation was a business with an office in the District

of Columbia.

2.

Between on or about the dates of August 7, 2006 and August 7, 2007, the defendant,

SEAN JACKSON, was employed by Computer World Services as an Assistant Controller.

3.

As a part of his duties, SEAN JACKSON was responsible for day-to-day accounting

operations, including monthly and year-end close and management reporting. His duties required

him to oversee budgeting, general ledger, accounts payable and receivable, payroll, fixed asset

management, and other similar tasks. He was responsible for entering transactions into the

accounting system and reconciling the bank account.

4.

In order to accomplish his duties, the defendant, SEAN JACKSON had pay-by-phone

access to a Sun Trust Bank account in which funds belonging to Computer World Services

Case 1:08-cr-00311-PLF-JMF Document 1 Filed 10/07/08 Page 2 of 3

Corporation were held. Using this access, SEAN JACKSON made numerous payments on a credit

card account that was held in the name of SEAN JACKSON’s wife. The defendant SEAN

JACKSON entered the withdrawals in the Computer World Services Corporation accounting system

and coded the other side of the transactions against a variety of accounts in the Computer World

Services general ledger.

5.

At no time was defendant SEAN JACKSON authorized to make withdrawals or

transfers of any kind from the aforementioned account of Computer World Services Corporation to

make payments toward any privately-held personal credit card, whether held in his own name, his

wife’s name, or any other friend, family member, or personal associate.

II.

6.

Wire Fraud Scheme

From on or about October 2006 through on or about August 2007, in the District of

Columbia, the defendant, SEAN JACKSON, voluntarily and intentionally devised and executed a

scheme to defraud Computer World Services out of money, that is, funds in an amount of

$67,320.70, under circumstances in which it was reasonably forseeable that interstate wire

communications would be used, and in which case interstate wire communications were in fact used,

in violation of 18 U.S.C. § 1343.

Case 1:08-cr-00311-PLF-JMF Document 1 Filed 10/07/08 Page 3 of 3

7.

In the execution of this scheme, the defendant, SEAN JACKSON, made electronic

transactions transferring financial assets of Computer World Services Corporation to make payments

either directly or indirectly toward his own personal expenses, and/or the personal expenses of family

members.

(Wire Fraud, in violation of 18 United States Code § 1343)

JEFFREY A. TAYLOR
UNITED STATES ATTORNEY
FOR THE DISTRICT OF COLUMBIA
Unified Bar Number 498610

By: ________/s/__________________

William L. Woodruff
Assistant United States Attorney
DC Bar: 481-039
Federal Major Crimes Section
555 4 St., N.W., Room 4840
Washington, D.C. 20530
(202) 307-6080
[email protected]

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