IN THE DISTRICT COURT OF THE UNITED STATES

FOR THE MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

UNITED STATES OF AMERICA )

 )

 v. ) CR. NO. 2:06mj76-W

 )

EUGENE L. CLECKLER, and )

KIM CLECKLER )

MOTION TO AMEND COMPLAINT

Comes now the United States of America, by and through Leura G. Canary, United States

Attorney for the Middle District of Alabama, and as grounds for this Motion, states as follows:

On August 1, 2006, a Complaint was filed against Eugene L. Cleckler and Kim Cleckler,

2:06mj76-W (copy attached). The circled portion (which states “travel in interstate commerce

with intent to avoid prosecution”) was inadvertently carried over from a prior complaint and

should be deleted. The proposed deletion is clerical in nature only and does not affect the

substantive counts against the defendants.

The government requests that it be allowed to amend this complaint by deleting the

circled portion and resubmitting the corrected version for filing.

Respectfully submitted this the 9th day of August, 2006.

LEURA G. CANARY

UNITED STATES ATTORNEY

/s/Andrew O. Schiff

ANDREW O. SCHIFF

Assistant United States Attorney

One Court Square, Suite 201

Montgomery, AL 36104

Phone: (334)223-7280

Fax: (334)223-7135

E-mail: andrew.schiff@usdoj.gov

Case 2:06-mj-00076-SRW Document 12 Filed 08/09/2006 Page 1 of 2
-2-

IN THE UNITED STATES DISTRICT COURT FOR

THE MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

UNITED STATES OF AMERICA )

)

v. ) CR. NO. 2:06mj76-W

)

EUGENE L. CLECKLER, and )

KIM CLECKLER )

CERTIFICATE OF SERVICE

I hereby certify that on August 9, 2006, I electronically filed the foregoing with the Clerk

of the Court using the CM/ECF system which will send notification of such filing to the

following: George Beck, Esq. and Ronald Brunson, Esq.

Respectfully submitted,

/s/Andrew O. Schiff

ANDREW O. SCHIFF

Assistant United States Attorney

One Court Square, Suite 201

Montgomery, AL 36104

Phone: (334)223-7280

Fax: (334)223-7135

E-mail: andrew.schiff@usdoj.gov

 

Case 2:06-mj-00076-SRW Document 12 Filed 08/09/2006 Page 2 of 2
Case 2:06-mj-00076-SRW Document 1 Filed 08/01/2006 Page FPLED 

United States District Court AUG 1 2006 

CLERK 

MIDDLE DISTRICT OF ALABAMA U. 8 nlSTqCCT COURT 

MIDDLE DIST. OF ALA. 

LNTED STATES OF AMERICA 

EUGENE L. CLECKLER, and 

KIM CLECKLER 

CRIMINAL CONIPLAINT 

CASE NUMBER: 4: &MI. 76 -1Al 

(Name and Address of Defendant) 

I, the undersigned complainant being duly sworn state the'following is true and correct to the best of 

my knowledge and belief. On or about November, 1996, through November, 2000, in Chilton County, in 

the Middle District of Alabama defendant(s) did, (Track Statutory Language of Offense) 

See Attachment A 

- - 

6vil in interstate cyrce with intent: avoid prosecu&] - in violation of 18 USC 371. 18 USC --.- - 

2(a) and 2(b), & 26 USC 72 12(a). 

I further state that I am a Special Agent with Internal Revenue Service/Criminal Investigation Division and 

Official Title 

that this complaint is based on the following facts: 

See Attachment B 

Continued on the attached sheet and made a part hereof: EI Yes 17 No , 

sign= of Complainant 

Sworn to before me and subscribed in my presence, 

AUGUST 1.2006 at Montgomery. Alabama 

Date City and State 

SUSAN RUSS WALKER 

United States Magistrate Judge 

Name & Title of Judicial Off~cer Signature of Judicial Off~cer 

Case 2:06-mj-00076-SRW Document 12-2 Filed 08/09/2006 Page 1 of 1