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Case 6:12-cr-00196-AA

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UNITED STATES DISTRICT COURT


DISTRICT OF OREGON
EUGENE DIVISION

Case No. 6:12-CR-00196-HO UNITED STATES OF AMERICA, S UPERERSEDING INDICTMENT Title 18 U.S.C. 1001 (False Statements) Title 18 U.S.C. 1341 (Mail Fraud) Title 18 U.S.C. 1349 (Mail Fraud Conspiracy) Title 18 U.S.c. 2250{a) (Failure to Register as Sex Offender) Title 18 U.S.c. 981{a){I){C) Title 28 U.S.c. 2461{c) (Forfeiture Allegation 1) Title 18 U.S.C. 982{a){3) Title 28 U.S.C. 2461{c) (Forfeiture Allegation 2)

v.
MICHAEL ALLEN SNOW, aka: Winter Rain Waters, and WILLY GIBSON WHITEBIRD, Defendants.

THE GRAND JURY CHARGES: COUNT 1


[Conspiracy to Commit Mail Fraud]
1. Beginning in or about July 2010, and continuing through February 2012, in the District
of Oregon, defendants MICHAEL ALLEN SNOW and WILLY GIBSON WHITEBIRD did

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unlawfully, knowingly, and intentionally combine, conspire, confederate, and agree with each other and others, both known and unknown to the grand jury, to devise and intend to devise a material scheme and artifice to defraud the Social Security Administration and the State of Oregon, and to obtain property by means of material false and fraudulent pretenses, representations, and promises, in violation of Title 18, United States Code, Section 1349.

Overt Acts In Furtherance Of The Conspiracy


2. In furtherance of the conspiracy, and to accomplish its object, at least one of the conspirators committed, or caused to be committed, in the District of Oregon, the following overt acts, among others: a. On or before July 22, 2010 , defendant WILLY GIBSON WHITEBIRD fabricated birth and prenatal records in the name of Winter Rain Waters. b. On or about July 22, 2010, defendant MICHAEL ALLEN SNOW caused an application for a birth certificate for Winter Rain Waters along with fabricated birth and prenatal records to be submitted to the Oregon Department of Human Services Center for Health Statistics. c. On or about February 7, 2011, defendants MICHAEL ALLEN SNOW and WILLY GIBSON WIDTEBIRD appeared in Lane County Circuit Court in case number 16-10-28278, and falsely testified that SNOW was Winter Rain Waters, causing that court to order that the birth of Winter Rain Waters be registered by the State Registrar Vital Records. d. On or about June 30, 2011, defendant MICHAEL ALLEN SNOW submitted an application for a Social Security number to the Social
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Security Administration, falsely asserting that he was Winter Rain Waters. e. On or about July 28,2011, defendant MICHAEL ALLEN SNOW submitted an application for an Oregon Identification card to the Department of Motor Vehicles falsely asserting that he was Winter Rain Waters. All in violation of Title 18, United States Code, Section 1349.

Counts 2 and 3
[Mail Fraud]

1. The Grand Jury re-alleges each and every allegation contained in all the paragraphs in Count 1 of this Indictment and incorporates them by reference as if fully set forth herein.

General Allel:ations
2. At all times material to this Indictment, defendants, MICHAEL ALLEN SNOW and

WILLY GIBSON WHITEBIRD were residents of the state and District of Oregon.
3. At all times material to this Indictment, defendant WILLY GIBSON WHITEBIRD was a registered nurse and mid-wife licensed by the Oregon State Board ofNursing. 4. At all times material to this Indictment, defendant MICHAEL ALLEN SNOW was a convicted sex offender subject to the registration requirements of the Sex Offender Registration and Notification Act.

The Scheme to Defraud


5. It was part of the material scheme and artifice to defraud that defendant MICHAEL

ALLEN SNOW would claim to be Winter Rain Waters.


6. It was part of the material scheme and artifice to defraud that defendants, MICHAEL
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ALLEN SNOW and WILLY GIBSON WHITEBIRD would attest that SNOW was Winter
Rain Waters and that WHITEBIRD was the certified mid-wife who assisted with his birth in

1987. 7. It was part of the material scheme and artifice to defraud that defendant WILLY GIBSON WHITEBIRD would use her certification as a nurse and mid-wife to create false
records of birth and medical care.

8. It was part of the material scheme and artifice to defraud that defendants MICHAEL ALLEN SNOW and WILLY GIBSON WHITEBIRD would make false statements and submit
false documentation to the State of Oregon in order to obtain something of value; to wit, a Judgment for Registration of Birth in the name of Winter Rain Waters.

9. It was part of the material scheme and artifice to defraud that defendant MICHAEL ALLEN SNOW would submit the fraudulently obtained Judgment for Registration of Birth to
the Social Security Administration in order to obtain something of value; to wit, a Social Security card in the name of Winter Rain Waters.

10. It was part of the material scheme and artifice to defraud that defendants MICHAEL ALLEN SNOW and WILLY GIBSON WHITEBIRD would conceal the fact that SNOW was
a convicted sex offender.

11. On or about the dates listed below, in the District of Oregon, defendants MICHAEL ALLEN SNOW and WILLY GIBSON WHITEBIRD for the purpose of executing the
aforementioned material scheme and artifice to defraud, and attempting to do so, knowingly caused to be delivered through the Postal Service the following mailings, each mailing being a separate count of this Indictment;
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Count 2 Mailed on or about 06/07/2011

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Mailed from Portland, Oregon

Mailed to Winter Rain Waters 994 S. 71st St. Eugene, Oregon Winter Rain Waters 1192 E 41st Ave. Eugene, Oregon

Description of Item Judgment for Registration of Birth in the name of Winter Rain Waters Social Security card in the name of Winter Rain Waters

07/21/2011

Baltimore, Maryland

All in violation of Title 18, United States Code, Section 1341.

COUNT 4 [False Statement to Government Agency] On or about June 30, 2011, within the District of Oregon, MICHAEL ALLEN SNOW, defendant herein, in a matter within the jurisdiction of the Social Security Administration, knowingly and willfully caused a written statement to be submitted, knowing that the statement was untrue and material to the agency's decision to issue a Social Security number; Specifically, defendant MICHAEL ALLEN SNOW falsely asserted that he was Winter Rain Waters and had not previously been issued a Social Security number; all in violation of Title 18, United States Code, Section 1001.

COUNTS [Failure to Register as Sex Offender] On or between September 16,2011 and October 26,2011, in the District of Oregon and elsewhere, defendant MICHAEL ALLEN SNOW, a person who is required to register under the Sex Offender Registration and Notification Act as a result of convictions in the Circuit Court

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of the State of Oregon for Yamhill County for Rape in the First Degree and Sodomy in the First Degree, in case number CROO-328, and who thereafter traveled in interstate commerce from the State of Oregon to the State of Montana, knowingly failed to register or update a registration as required by the Sex Offender Registration and Notification Act, all in violation of Title 18, United States Code, Section 2250(a). COUNT 6 [Failure to Register as Sex Offender] On or about January 24,2012, in the District of Oregon, defendant MICHAEL ALLEN SNOW, a person who is required to register under the Sex Offender Registration and Notification Act as a result of convictions in the Circuit Court of the State of Oregon for Yamhill County for Rape in the First Degree and Sodomy in the First Degree, in case number CROO-328, and who thereafter traveled in interstate or foreign commerce from the State of Montana to the State of Oregon, knowingly failed to register or update a registration as required by the Sex Offender Registration and Notification Act, all in violation of Title 18, United States Code, Section 2250(a).

III

III

/11

1//

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FORFEITURE ALLEGATION 1

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Upon conviction of the offenses alleged in Counts 1, 2 and 3 of this indictment, MICHAEL ALLEN SNOW and WILLY GIBSON WHITEBIRD, defendants herein, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981 (a)(l)(C) and Title 28, United States Code, Section 2461 (c), any property, real or personal, which constitutes or is derived from proceeds traceable to the violations.

FORFEITURE ALLEGATION 2 Upon conviction of the offense alleged in Count 4 of this indictment, MICHAEL ALLEN SNOW and WILLY GIBSON WHITEBIRD, defendants herein, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(3) and Title 28, United States Code, Section 2461(c), any property, real or personal, which represents or is traceable to the gross receipts obtained, directly or indirectly, as a result of such violation. If any of the above-described forfeitable property in Forfeiture Allegations 1 or 2, as a result of any act or omission of the defendants: (a) cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the court; has been substantially diminished in value; or has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(P) as incorporated by Title 18, United States Code, Section
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(b)
(c) (d) (e)

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982(b), to seek forfeiture of any other property of said defendants up to the value of the forfeitable property described above. Dated this

i.!JL day of May, 2012.


A TRUE BILL.

/s/ Grand Jury Foreperson


OFFICIATING FOREPERSON

Presented by: S. AMANDA MARSHALL, OSB #953473


United States Attorney
District of Oregon

/s/ Helen L. Coover ..


HELEN L. COOPER, OSB #871957
Special Assistant United States Attorney

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