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DANIEL G.BOGDEN

D001111SE
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Unitcd States Attomcy

District ofNevada

Assistant Unitcd States Attomey

501 Las Vegas BIvd S.,Suite l1 00

Las Vegas,Nevada 89101

702-388-6336
jarcd.1.gHmmcr@usd gOV

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JARED L.GRIMMER

CLERK US DISTRICT COURT

DISTRICT OF NEVADA

DEP TV

UNITED STATES DISTRICT COURT

DISTRICT OFlEVADA

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UNITED STATES OF AMERICA,

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)Case No:2:16-cr-198

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}cRIMINAL INDICTMENT

Vs

} vIoLATION:

MICIIAEL STEVEN SANDFORI),

} 18 UoS.C.

Defendant.

922(g)(5)and 924(a)(2)

} 11legal Alien in Possession ofa Firearm

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1:`: shes

or Functions

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THE GRAND JURY CHARGES THAT:

COUNT l

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(Illegal Alien in Possession of a Firearln)

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On or aboutJunc 17,2016,in thc Statc and Federal E)istrict ofNevada,

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NIIICHAEL STEVEN SANDFORD,

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deindant herein,then bcing an alien illegally alld unla

fullv in thc United Statcs,did kno lngl

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possess a firearm; to

wit:

a Glock 9

millimeter handgun bearing an unknown serial number, sai

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transported in intcrstate commcrce, all

922(g)(5)and 924(a)(2).

violation of Title 18,United States Codc,

COUNT 2
(lllegal Alien in Possession of a Fireann)

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On or about June 18, 2016, in the State and Federal District of Nevada,
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MICHAEL STEVEN SANDFORD,

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defendant herein, then being an alien illegally and unlawfully in the United States, did knowingl
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possess a firearm;

to wit: a Glock 9 millimeter handgun bearing serial number VUH314,

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possession being in and affecting interstate commerce and said firearm having been shipped
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transported

in interstate commerce, all in violation of Title

18, United States Code, Secti

e22(e)O) ande2a@)Q).
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COUNT 3
(Impecling and Disrupting Government Business Official Functions)

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On or about June 18.2016, in the State and Federal District of Nevada,

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MICHAEL STEVEN SANDFORD,
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defendant herein, did knowingly and with intent to impede and disrupt the orderly conduct

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of

Govemment business and official functions, engage in disorderly and disruptive conduct in and

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within such proximity to a restricted building where Donald J. Trurnp, who was then receiving
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protection from the United States Secret Service, was temporarily visiting, when and so that

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conduct did in fact irnpede and disrupt the orderly conduct of Governrnent business and an
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official function, by atternpting to seize

police officer's handgun, and, during and in relation to

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the offense, did use a firearm, to wit: a Glock 9 millimeter handgun.
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AII in violation of Title

18, United States Code, Section 1752(a)(2) and

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(bXlXA).

DATED:this 29th day of Jllnc,2016.

A TRUE BILL:

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DANIEL G.BOGDEN

FOREPERSON OF THE GRAND JURY

Unitcd States Attorney

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United States Attorney

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