IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF MISSOURI

CENTRAL DIVISION

UNITED STATES OF AMERICA,

) No. 12-04061-01-CR-C-BCW
)
) Count One:
) 18 U.S.C. 1344
)
NMT 30 years and/or $1 million
)
Supervised Release: NMT 5 years
)
) Count Two:
) 18 U.S.C. 1957
)
NMT 10 years and/or $250,000
)
or twice the amount
)
of the criminal proceeds
)
Supervised Release: NMT 3 years
)
) $100 mandatory penalty
) assessment, each count

Plaintiff,
v.
TERRIE LYNN JOHNSON,
[DOB: 12/3/64]
Defendant.

INDICTMENT

THE GRAND JURY CHARGES THAT:

Introduction
At all times material:
1.

TERRIE LYNN JOHNSON, Defendant, was employed as a Branch Manager by

Landchoice Company, LLC (Landchoice) in Fulton, Callaway County, Missouri, between

December 2007 and December 2008.
2.

Landchoice maintained its business escrow account at Commerce Bank

(Commerce) in Fulton, Missouri. The Defendant maintained a personal checking account at

Exchange Bank (Exchange) in Fulton, Missouri.
3.

Commerce Bank was a financial institution, the accounts of which were insured
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Case 2:12-cr-04061-BCW Document 1 Filed 12/13/12 Page 1 of 4

by the Federal Deposit Insurance Corporation (FDIC).

4.

Exchange Bank was a financial institution, the accounts of which were insured by

the Federal Deposit Insurance Corporation (FDIC).

Countrywide Bank FSB (Countrywide) was a financial institution, the accounts

5.

of which were insured by the Federal Deposit Insurance Corporation (FDIC).

The Scheme and Artifice to Defraud
6.

From an unknown date, but at least as early as in or about December 26, 2007,

TERRIE LYNN JOHNSON, Defendant, devised and executed a scheme and artifice to defraud
Countrywide Bank FSB, an FDIC-insured financial institution.
7.

It was an object of the scheme and artifice to defraud that JOHNSON would

unlawfully take and obtain, by deception and fraud, money entrusted to Countrywide Bank, and
use the funds for her own benefit.
8.

It was part of the scheme and artifice to defraud that JOHNSON would falsify

her settlement statement (HUD Form 1-A) as part of her loan closing package which she
submitted to Countrywide Bank misrepresenting that the loan proceeds were solely to be used to
pay her existing loan at Jefferson Bank.
9.

It was a part of the scheme and artifice to defraud that JOHNSON would use the

loan proceeds from Countrywide Bank not to pay off her existing mortgage at Jefferson Bank but
for other purposes, including payment into her own personal account.
10.

It was further a part of the scheme and artifice to defraud that JOHNSON would

cause the funds to be deposited into her personal account with Exchange Bank.

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Count One
(Bank Fraud)
11.

Paragraphs 1 through 10 are herein incorporated by reference.

12.

In support of the scheme and artifice to defraud, TERRIE LYNN JOHNSON,

Defendant, committed or caused to be committed the following act in execution of the scheme to
defraud:
On or about December 26, 2007, in Callaway County, in the Western
District of Missouri, TERRIE LYNN JOHNSON, Defendant, knowingly created
and submitted to Countrywide Bank, a false settlement statement (HUD Form 1A) as part of her loan closing package which misrepresented that the loan
proceeds were solely to be used to pay off her existing mortgage at Jefferson
Bank, when, in fact, Defendant intended to use part of the proceeds for other
purposes, including depositing a portion of the proceeds into her personal bank
account at Exchange Bank.
All in violation of Title 18, United States Code, Section 1344.
Count Two
(Money Laundering)
13.

Paragraphs 1 through 10 are herein incorporated by reference.

14.

On or about January 3, 2008, in Callaway County, the Western District of

Missouri, and elsewhere, TERRIE LYNN JOHNSON, Defendant, did knowingly engage in a
monetary transaction through a financial institution, affecting interstate commerce, in criminally
derived property of a value greater than $10,000, that is, deposited $31,894.97 into her personal
account at Exchange Bank, such property having been derived from a specific unlawful activity,
that is, bank fraud, in violation of 18 U.S.C. 1344.
All in violation of 18 U.S.C. 1957.

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A TRUE BILL.

/s/
__________________________________
FOREPERSON OF THE GRAND JURY

/s/
____________________________
LAWRENCE E. MILLER
Assistant U.S. Attorney
Missouri Bar No. 39531

Dated: 12/13/12

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JS 45 (1/96)

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MISSOURI
CRIMINAL CASE COVER SHEET
Division of Filing

Western
X
Central

Southwestern

Defendant Information
Defendant Name
Alias Name
Birthdate

Place of Offense
Callaway
County

St. Joseph
Southern

Matter to be Sealed
X
Secret Indictment

Juvenile

Terrie Lynn Johnson

12/3/64

Related Case Information

Superseding Indictment/Information Yes X No if yes, original case number
New Defendant
X Yes No
Prior Complaint Case Number, if any
U.S. Attorney Information
AUSA Lawrence E. Miller
Interpreter Needed

Yes
Language and/or dialect
X
No
Location Status
Arrest Date

Currently in Federal Custody

Currently in State Custody

Currently on bond
U.S.C. Citations
Total # of Counts

Writ Required Yes

No

Set

Index Key/Code/Offense Level

Description of Offense Charged

Count(s)

18:1344A.F/4601/4

Bank Fraud

18:1957-5800.F/5800/4

Engaging in Monetary
Transactions

3
4
(May be continued on reverse)

Date

12/13/12

Signature of AUSA

/S/_____________________

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