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Case 1:16-cr-00077-RGA Document 1 Filed 09/13/16 Page 1 of 4 PageID #: 1

ORIGINAL
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA,

v.
Plaintiff, Criminal Action No. 16 -11---
SEAN MOORE,

Defendant.

INFORMATION
w
The United States Attorney for the District of Delaware charges that:

Introduction ':'?
c..n
-.I
1. At times material to this Information, the defendant, SEAN MOORE, was a

Delaware resident.

2. At times material to this Information, the defendant was employed by a Charter

School in New Castle, Delaware (the "Charter School"), as the Director of Finance and

Operations.

3. At times material to this Information, the defendant's position at the Charter

School permitted him authority over the financial affairs of the school.

4. At times material to this Information, the Charter School received benefits in

excess of $10,000 from the United States Department of Education, under a Federal program

involving a grant and other forms of Federal assistance, in each of the 2012, 2013, and 2014

calendar years.
 Case 1:16-cr-00077-RGA Document 1 Filed 09/13/16 Page 2 of 4 PageID #: 2

COUNT I
Federal Program Theft (18 U.S.C. 666(a)(l)(A) & 666(b))

5. Beginning in or around January 1, 2012, and continuing up to and including

December 31, 2012, in the District of Delaware, the defendant, SEAN MOORE, being an agent

of the Charter School, embezzled, stole, obtained by fraud, without authority knowingly

converted to his own use, and intentionally misapplied property worth at least $52,548, to wit,
~

money, credits, and other things of value belonging to the Charter School, such property having

been owned by and under the care, custody, and control of the Charter School, an organization

receiving benefits in excess of $10,000 from the United States Department of Education, under a

Federal program involving a grant and other forms of Federal assistance, in the calendar year

beginning January 1, 2012, and ending December 31, 2012, in violation of 18 U.S.C.

666(a)(l )(A).

COUNT II
Federal Program Theft (18 U.S.C. 666(a)(l)(A) & 666(b))

6. Beginning in or around January 1, 2013, and continuing up to and including

December 31, 2013, in the District of Delaware, the defendant, SEAN MOORE, being an agent

of the Charter School, embezzled, stole, obtained by fraud, without authority knowingly

converted to his own use, and intentionally misapplied property worth at least $72,776, to wit,

money, credits, and other things of value belonging to the Charter School, such property having

been owned by and under the care, custody, and control of the Charter School, an organization

receiving benefits in excess of $10,000 from the United States Department of Education, under a

Federal program involving a grant and other forms of Federal assistance, in the calendar year

2
 Case 1:16-cr-00077-RGA Document 1 Filed 09/13/16 Page 3 of 4 PageID #: 3

beginning January 1, 2013, and ending December 31, 2012, m violation of 18 U.S.C.

666(a)(l)(A).

COUNT III
Federal Program Theft (18 U.S.C. 666(a)(l)(A) & 666(b))

7. Beginning in or around January 1, 2014, and continuing up to and including

December 31, 2014, in the District of Delaware, the defendant, SEAN MOORE, being an agent

of the Charter School, embezzled, stole, obtained by fraud, without authority knowingly

converted to his own use, and intentionally misapplied property worth at least $34,277, to wit,

money, credits, and other things of value belonging to the Charter School, such property having

been owned by and under the care, custody, and control of the Charter School, an organization

receiving benefits in excess of $10,000 from the United States Department of Education, under a

Federal program involving a grant and other forms of Federal assistance, in the cale,ndar year

beginning January 1, 2014, and ending December 31, 2014, in violation of 18 U.S.C.

666(a)(l)(A).

NOTICE OF FORFEITURE

8. Upon conviction of the offenses alleged in Counts I-III of this Information, the

defendant, SEAN MOORE, shall forfeit to the United States pursuant to Title 18, United States

Code, Section 982(a)(3)(A) any property, real or personal, which represents or is traceable to the

gross receipts obtained, directly or indirectly, as a result of said violation.

9. If any of the property described above, as a result of any act or omission of the

defendant:

a) cannot be located upon the exercise of due diligence;

b) has been transferred or sold to, or deposited with, a third party;

3
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c) has been placed beyond the jurisdiction of the court;

d) has been substantially diminished in value; or

e) has been commingled with other property which cannot be divided without

difficulty; then,

the United States of America shall be entitled to forfeiture of substitute property pursuant to 21

U.S.C. 853(p), as incorporated by 18 U.S.C. 982(b) and 28 U.S.C. 2461(c), all pursuant to

28 U.S.C. 2461(c).

CHARLES M. OBERLY, III

United States Attorney

BY: ltli INA PtM--

Elizabeth L. Van Pelt
Assistant United States Attorney

Dated: September 12, 2016