Free Redacted Document - District Court of Delaware - Delaware

` Case 1 :07-cr-00018-GIVIS Document 2 Filed O2/06/2007 Page 1 of 3
e _ IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
. . UNITED STATES OF AMERICA, )
_ v. i Criminal Action No. 07- / Q)
A ‘ I BARRY M. YOUNG, _ . _ . __,;.--- tl- L-N——
. J .- _¤.-"- I -- * "iift;.
Defendant. ) ` "
INDICTMENT
The Grand Jury for the District of Delaware charges that:
g coUNT 01;;
On or about the April 25, 2003, in the District of Delaware, in a matter within the
jurisdiction ofthe United States Department of Justice, a Department ofthe United States, the
defendant, BARRY M. YOUNG, did knowingly and willfully make a false and fraudulent
material statement; that is, on a Financial Statement of Debtor, DOJ Form OBD—500, BARRY
M. YOUNG failed to report his employment by the State of Delaware as a high school teacher
- J and falsely represented that his monthly income was $720.00, when in fact, as the defendant well
knew, his monthly income was greater than that amount, in violation of§Title l8r Uriited Stat-ei? In J
Code, Section l001(a). _ __._“--7--m--{
’ F a‘;i1-· ‘ " . l
° On or about the August 8, 2005, in the District of Delaware, in zi matter _i
i _ jurisdiction of the United States Department of Justice, a Department ofthe United States, the
defendant, BARRY M. YOUNG, did knowingly and willfully make a false and material
statement; that is on a Financial Statement of Debtor, DOJ Fonn OBD-500, BARRY M.
YOUNG failed to report his employment by the State of Delaware as a high school teacher and
falsely represented that his monthly income was $250.00, when in fact, as the defendant well

‘ ‘ Case 1 :07-cr-00018-GIVIS Document 2 Filed O2/06/2007 Page 2 of 3
knew, his monthly income was greater than that amount, in violation of Title 18, United States
l Code, Section 1001(a).
— COUNT THRE
_ On or about the December 14, 2005, in the District of Delaware, in a matter within the
c jurisdiction of the United States Department of Justice and the United States Department of
` Health and Human Services, both Departments of the United States, the defendant, BARRY M.
YOUNG, did knowingly and willfully make a false and fraudulent material statements and
representations; that is he told known federal agents of the Department of Health and Human h
l Services that his name was David Garvin, when in fact his name is Barry Young, and told these
A same agents that Barry Young was not employed as a school teacher, when in fact he was so
employed, in violation of Title 18, United States Code, Section 1001(a).
COUNT FO@
On or about the December 19, 2005, in the District of Delaware, in a matter within the
jurisdiction of the United States Department-of Justice and the United States Department of
Health and Human Services, both Departments of the United States, the Defendant, BARRY M.
YOUNG, did knowingly and willfully make false and fraudulent material statements and
‘ representations; that is he told known federal agents of the Department of Health and Human
Services that Perry Patel incorporated Tracer Air, Inc. and served as its registered agent, when in
fact that function was performed by the defendant, and also told these same agents that David
Garvin was the President of Tracer Air, Inc., when in fact David Garvin was not the president of
Tracer Air, Inc., in violation of Title 18, United States Code, Section 100l(a).
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' Case 1:07-cr-OOO18—G|\/IS Document 2 Filed O2/06/2007 Page 3 of 3
A TRUE BILL:
Foreperson
COLM F. CONNOLLY 1 . I
United States Attorney
,» A /74 ;"
I ana H. Eisenstein
Assistant United States Attorney
Dated: February 6, 2007
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