IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA

v.

JONAS WINFIELD

:

:

:

:

CRIMINAL NO. _____________

DATE FILED: ________________

VIOLATIONS:

18 U.S.C. § 371 (conspiracy - 1 count)

18 U.S.C. § 1029(a)(2) (credit card fraud -

1 count)

INFORMATION

COUNT ONE

THE UNITED STATES ATTORNEY CHARGES THAT: 

At all times material to this information:

1. Amtrak was an interstate passenger rail service, providing train

transportation nationwide. Amtrak took reservations for train travel and issued tickets on those

reservations when provided with credit card information.

2. Defendant JONAS WINFIELD had access to credit card information as

an employee at a hotel in Philadelphia.

3. From on or about January 11, 2003 through on or about May 12, 2004, in

the Eastern District of Pennsylvania and elsewhere, defendant

JONAS WINFIELD

conspired and agreed, with Kenneth Winfield, charged elsewhere, and others known and

unknown to the United States Attorney, to commit an offense against the United States, that is, to

knowingly and with intent to defraud make unauthorized charges on stolen credit card numbers,

in violation of Title 18, United States Code, Section 1029(a)(2).

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MANNER AND MEANS

It was part of the conspiracy that:

4. Defendant JONAS WINFIELD stole credit card numbers from a

Philadelphia hotel which were then provided to others, including Kenneth Winfield, charged

elsewhere. Defendant JONAS WINFIELD and the others used the card numbers to fraudulently

purchase Amtrak train tickets. As a result of this scheme, Amtrak suffered a loss of

approximately $32,469.

 5. Defendant JONAS WINFIELD and the other conspirators called Amtrak

and made train reservations using the stolen credit card numbers. The conspirators then picked

up the fraudulently ordered tickets, usually before the true account holders had stopped the

unauthorized charges. Defendant JONAS WINFIELD frequently picked up the tickets through

automated ticketing machines located in Amtrak’s 30th Street Station in Philadelphia.

OVERT ACTS

In furtherance of the conspiracy, the defendant, and others known and unknown to

the United States Attorney, committed the following overt acts in the Eastern District of

Pennsylvania and elsewhere:

1. Defendant JONAS WINFIELD took from a Philadelphia hotel

documents recording the credit card numbers of guests.

2. Defendant JONAS WINFIELD provided the stolen numbers to Kenneth

Winfield, charged elsewhere.

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3. Defendant JONAS WINFIELD and the others using the stolen credit card

numbers fraudulently purchased approximately $32,469 in Amtrak train tickets using at least a

dozen credit card numbers stolen from the Philadelphia hotel.

4. Defendant JONAS WINFIELD went to Amtrak’s 30th Street Station in

Philadelphia and other places to physically retrieve the fraudulently obtained tickets.

 All in violation of Title 18, United States Code, Section 371.

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COUNT TWO

THE UNITED STATES ATTORNEY FURTHER CHARGES THAT:

1. Paragraphs 1 through 4 of the overt acts in Count 1 are incorporated here.

2. From on or about July 16, 2003 to on or about November 26, 2003, in

Philadelphia, in the Eastern District of Pennsylvania, and elsewhere, defendant

JONAS WINFIELD

knowingly and with intent to defraud used and attempted to use an unauthorized access device,

that is, an American Express credit card with the last three digits 008, in the name of P.D., to

obtain things of value aggregating $1,000 or more during a one-year period, that is,

approximately $1,435 in Amtrak train tickets, thereby affecting interstate commerce.

In violation of Title 18, United States Code, Sections 1029(a)(2) and (b)(1).

 

PATRICK L. MEEHAN

UNITED STATES ATTORNEY 

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