' , \ . 

UNDER SEAL 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA 

v. 

RACHEL LEE, 

BLANCEY LEE, 

aka BLANCEY ADAMS, 

PORSHA LEE, and 

SAMANTHA LEE, 

aka PEBBLES LEE, 

aka BUBBLES LEE, 

Defendants. 

THE GRAND JURY CHARGES: 

COUNT 1 

(Conspiracy to Commit Wire Fraud) 

At all times relevant to this indictment: 

A. The Defendants 

Case No.3 • 14 -C..r- 00 / 8'Y - , JO 

INDICTMENT 

18 u.s.c. § 1349 

18 u.s.c. § 1957 

18 u.s.c. § 1956(h) 

18 U.S.C. § 981(a)(l)(C) 

18 U.S.C. § 982(a)(l) & (b) 

21u.s.c.§853(p) 

and 28 U.S.C. § 2461(c) 

1. Defendant RACHEL LEE was a resident of Oregon. RACHEL LEE held 

herself out as a psychic medium and was affiliated with psychic shops in Bend, Oregon (Bend 

Psychic) Canby, Oregon (Canby Psychic) and St. Helens, Oregon (St. Helens Psychic) and two 

psychic shops in Portland, Oregon (Psychic of Oregon). 

2. Defendant BLANCEY LEE, aka BLANCEY ADAMS was at times a resident 

of Oregon. BLANCEY LEE held himself out as general contractor. BLANCEY LEE and 

codefendant RACHEL LEE at time held themselves out as a couple, as married, or as brother 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 1 of 24
and sister. BLANCEY LEE shared multiple residences with RACHEL LEE and others named 

in this indictment. 

3. Defendant PORSHA LEE was at times a resident of Oregon. PORSCHE LEE 

is believed to be the daughter of codefendant RACHEL LEE. PORSHA LEE at times shared 

the same residence with RACHEL LEE and others named in this indictment. PORSHA LEE 

at times held herself out as Mary Marks aka Mary Raines, the alleged wife of R.R. Jr. 

4. Defendant SAMANTHA LEE aka PEBBLES LEE aka BUBBLES LEE was 

at times a resident of Oregon. PEBBLES LEE at times shared the same residence with 

RACHEL LEE and others named in this indictment. PEBBLES LEE is believed to be the 

mother of the minor "G". 

B. General Allegations 

5. R.R. Jr. (herein after Jr.), currently 66 years old, worked on and lived at the R. 

Tree Farm in Gaston, Oregon, along with his father, R.R. Sr. (herein after Sr.). The R. Tree 

Farm consisted of more than 1200 acres. After Jr.' s mother died in 1992, Jr. and Sr. lived on the 

property alone. Jr. was the only child of Sr. Jr. never married and had no children. Jr. had few 

living blood relatives. 

6. Until his death in February 2011, Sr. was the owner and controlling member ofR. 

Tree Farm LLC. Before his death, Sr. amassed substantial assets related to his business and real 

estate holdings. After Sr. suffered a stroke in 1996, his health declined. 

7. Sometime in 2004, RACHEL LEE met Jr. Between 2004 and 2006, RACHEL 

LEE repeatedly initiated contact with Jr. via telephone and in person in locations in Washington 

and Multnomah Counties. During this time, RACHEL LEE was primarily living in Bend, 

Oregon, conducting business as a psychic medium at the Bend Psychic shop. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 2 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 2 of 24
C. The Conspiracy to Commit Wire Fraud 

8. From in or about 2004 through in or about May 2014, in the District of Oregon 

and elsewhere, defendants RACHEL LEE, BLANCEY LEE, and PORSHA LEE, did 

unlawfully, knowingly, and intentionally combine, conspire, confederate, and agree with each 

other, and with others, both known and unknown to the Grand Jury, to devise a material scheme 

and artifice to defraud Sr. and Jr. and to obtain money and property from Sr. and Jr. by means of 

material false and fraudulent pretenses, representations, and promises, and omissions of material 

fact and knowingly transmit and cause to be transmitted by means of wire communications in 

interstate commerce, writings, signs, signals, pictures, and sounds in furtherance and execution 

of the material scheme or artifice, in violation of Title 18, United States Code, Section 1343. 

D. Manner and Means of the Conspiracy 

9. The purpose of the defendants' conspiracy was to fraudulently obtain money from 

Sr. and Jr. 

10. It was part of the conspiracy that RACHEL LEE sometimes brought PORSHA 

LEE with her when RACHEL LEE visited Jr. RACHEL LEE introduced PORSHA LEE to 

Jr. as RACHEL LEE's daughter. 

11. It was part of the conspiracy that between 2004 and 2006, through material 

misrepresentations and omissions of material fact, RACHEL LEE gradually and incrementally 

established a relationship with Jr. and built trust with Jr. 

12. In October 2006, after Sr. suffered a stroke, it was part of the conspiracy that, 

through material misrepresentations and omissions of material fact, RACHEL LEE became 

Sr.'s full-time homecare worker. As a result, RACHEL LEE moved into the home shared by 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 3 

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Sr. and Jr. in Gaston, Oregon. RACHEL LEE brought PORSHA LEE with her to live at the 

Gaston home. 

13. It was part of the conspiracy that, as payment for RACHEL LEE's full-time 

homecare worker services, RACHEL LEE sought and received access to Jr.'s bank accounts, 

and to a debit card for those accounts, for the alleged purpose of covering expenses for Jr., Sr. 

and RACHEL LEE. Jr. did not authorize any other codefendant to access Jr.' s finances or to 

use debit cards tied to Jr.' s accounts. 

14. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, in addition to assisting with Sr.'s homecare needs, RACHEL LEE 

became involved in the business operations of R. Tree Farm. 

15. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, RACHEL LEE assumed access to R. Tree Farm bank accounts 

xx0314 and xx0161 no later than November 2006. 

16. It was part of the conspiracy that that between 2006 and 2011, defendant 

RACHEL LEE falsely represented to Jr. that she would act in a fiduciary capacity toward Jr. 

and Sr. and would use her access and control of Jr. and Sr. 's accounts solely for Jr. and Sr. 's 

benefit and to pay reasonable fees and expenses to RACHEL LEE and others for services 

performed for Jr. and Sr.'s benefit. 

17. It was part of the conspiracy that, shortly after moving in with Jr. and Sr., through 

material misrepresentations and omissions of material fact, RACHEL LEE brought BLANCEY 

LEE to the Gaston home, purportedly for the purpose of doing minor general contracting work at 

the Gaston home. BLANCEY LEE lived at the Gaston home on and off during approximately 

2006 and 2007. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 4 

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18. It was part of the conspiracy that RACHEL LEE falsely represented to Jr. that 

BLANCEY LEE was a non-steady boyfriend of RACHEL LEE and that the two were only 

loosely connected. 

19. It was part of the conspiracy that between 2006 and 2011, through material 

misrepresentations and omissions of material fact, RACHEL LEE moved Jr. and Sr. to a home 

in northwest Portland purchased by Sr. and Jr. BLANCEY LEE and PORSHA LEE lived with 

Jr., Sr. and RACHEL LEE at the northwest Portland address from time to time. 

20. It was part of the conspiracy that, in approximately 2006, through material 

misrepresentations and omissions of material fact, RACHEL LEE took administrative control of 

R. Tree Farm business operations and conducted negotiations with other businesses on behalf of 

R. Tree Farm. 

21. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, in approximately August 2009, RACHEL LEE opened a joint 

checking account with Jr. at Columbia Bank (xx7270). The funding for this account primarily 

came from transfers from a R. Tree Farm account (xx0161). RACHEL LEE controlled all the 

activity on the joint account. Jr.' s only knowledge of account activity on the joint account came 

through RACHEL LEE or PORSHA LEE. 

22. It was part of the conspiracy that RACHEL LEE falsely represented to bank 

employees at Columbia bank and that she and Jr. were engaged to be married. 

23. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, in approximately August 2009, RACHEL LEE opened a savings 

account at Columbia Bank in her name only (xx 1074). The funding for this account was 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 5 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 5 of 24
primarily sourced from Jr. and RACHEL LEE' s joint bank accounts without Jr.' s informed 

consent. 

24. It was part of the conspiracy that, in approximately 2009, based on material 

misrepresentations and omissions of material fact, Jr. and RACHEL LEE began representing to 

others that he had married a woman named Mary Marks. Jr. claimed that Mary Marks was an 

illegal immigrant from England and Jr. needed to marry her so that Marks could get her green 

card and remain in the U.S. legally. Jr. also claimed that Marks gave birth to his natural born 

son, minor "G." Mary Marks allegedly worked and lived in California, and visited Jr. and the 

minor "G" in Oregon, where the minor "G" remained in the care of RACHEL LEE. In fact, no 

marriage certificate exists for Jr. and Marks. The person who interacted with others as Jr.'s wife 

Mary Marks was PORSHA LEE in disguise. When posing as Mary Marks, PORSHA LEE 

typically presented in heavy make-up, a blond wig, glasses, a hat, and a British accent. 

25. It was part of the conspiracy that, in approximately 2009, through material 

misrepresentations and omissions of material fact, the fictitious Mary Marks/PORSHA LEE 

began sharing administrative control of R. Tree Farm with RACHEL LEE. 

26. It was part of the conspiracy that, between 2006 and 2011, through material 

misrepresentations and omissions of material fact, the defendants gradually and incrementally 

took complete control of all financial and business affairs of Sr. and Jr. 

·21. It was part of the conspiracy that, between 2006 and 2011, through material 

misrepresentations and omissions of material fact, the defendants gradually and incrementally 

isolated Jr. and terminated meaningful contact between Jr., his business associates, his neighbors, 

and his family. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 6 

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28. It was part of the conspiracy that, prior to 2011, based on material 

misrepresentations and omissions of material fact, RACHEL LEE became the executor ofSr.'s 

will. RACHEL LEE also acquired power of attorney for Jr. In February of 2011, Sr. passed 

away. 

29. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, by the time of Sr.'s death in February 2011, Jr. was fully and totally 

dependent on RACHEL LEE and PORSHA LEE/Mary Marks for all financial and business 

decision making. 

30. It was part of the conspiracy that, after Sr.'s death, through material 

misrepresentations and omissions of material fact, RACHEL LEE, PORSHA LEE, and 

PEBBLES LEE remained in close contact with Jr. 

31. It was part of the conspiracy that, after Sr.' s death, PEBBLES LEE allowed her 

child, the minor "G," to play the role of Jr.'s alleged son. RACHEL LEE fraudulently 

presented as the nanny for the minor "G." 

32. It was part of the conspiracy that, after Sr.'s death in 2011, through material 

misrepresentations and omissions of material fact, RACHEL LEE and PORSHA LEE/Mary 

Marks convinced Jr. that he needed to sell R. Tree Farm properties to pay his inheritance tax 

assessments. 

33. It was part of the conspiracy that, after February of 2011, through material 

misrepresentations and omissions of material fact, PORSHA LEE, posing as Jr.'s alleged wife 

Mary Marks, conducted negotiations with other business on behalf of the R. Tree Farm, 

including the negotiations for sale of R. Tree Farm properties. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 7 

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34. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, PORSHA LEE, posing as Jr.'s alleged wife Mary Marks, contacted 

realtor P.G. to initiate and negotiate the sale of Jr.'s R. Tree Farm properties. 

35. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, PORSHA LEE, posing as Jr.'s alleged wife Mary Marks, negotiated 

the sale of at least four parcels of Jr.' s property as follows: 

• Approximately 57-58 acres for $1 million; 

• Approximately 230 acres for $1.4 million on September 23, 2011; 

• Approximately 120 acres for $1.1 million; 

• The main plot of approximately 869 acres for $8.8 million on or about July 31, 

2012. 

36. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, RACHEL LEE and PORSHA LEE/Mary Marks caused funds to be 

transmitted in interstate commerce by means of wire in conjunction with the sale of the above 

listed Tree Farm properties and the receipt of the sales proceeds. 

37. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, RACHEL LEE directed the majority of the proceeds of the R. Tree 

Farm property sales to bank accounts and assets in RACHEL LEE's name and joint accounts 

RACHEL LEE shared with Jr. without Jr.'s full knowledge or informed consent. 

38. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, RACHEL LEE closed joint account xx7270 in September 2012. 

RACHEL LEE transferred the $1.1 million balance to open a new joint account with Jr. on 

September 10, 2012 (xx9334 at Columbia Bank). As with joint account xx 7270, Jr. had no true 

access to or control over this account and RACHEL LEE exercised complete control. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 8 

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39. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, sometime before July 2013, RACHEL LEE opened two additional 

accounts with Wells Fargo Bank; another joint account with Jr. (account xx4849) and a savings 

account in RACHEL LEE's name only (account xx8579). 

40. It was part of the conspiracy that RACHEL LEE falsely represented to Jr., 

between 2006 and 2011, that only RACHEL LEE had direct access to Jr.'s accounts and a debit 

card for unrestricted spending. 

41. It was part of the conspiracy that the codefendants failed to truthfully and 

accurately disclose certain material facts to Jr., including the fact that RACHEL LEE provided 

BLANCEY LEE with access to Jr.'s accounts. 

42. It was part of the conspiracy that RACHEL LEE falsely represented to Jr., 

between 2006 and 2011, that RACHEL LEE provided payments to RACHEL LEE's family 

and friends only as payment for the time they assisted with Sr. or for related reimbursements. 

43. It was part of the conspiracy that the codefendants failed to truthfully and 

accurately disclose certain material facts to Jr., including the fact that RACHEL LEE wrote 

thousands of dollars in checks to her family members including the defendants. 

44. It was part of the conspiracy that the codefendants failed to truthfully and 

accurately disclose certain material facts to Jr., including the fact that RACHEL LEE and 

BLANCEY LEE spent Jr.'s money on frequent trips to California and Las Vegas, including 

gambling, high-end clothing purchases, entertainment, and accommodations at luxury hotel 

resorts including the Bellagio, the Venetian, and The Wynn, all with Jr.'s money. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 9 

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45. It was part of the conspiracy that RACHEL LEE falsely represented to Jr., 

between 2006 and 2011, that RACHEL LEE and Jr. jointly owned multiple rental properties 

and that the income from those rental properties flowed, in part, to Jr. 

46. It was part of the conspiracy that the codefendants failed to truthfully and 

accurately disclose certain material facts to Jr., including the fact that RACHEL LEE and 

BLANCEY LEE purchased multiple real properties with Jr.'s money between 2010 and 2013. 

47. It was part of the conspiracy that the codefendants failed to truthfully and 

accurately disclose certain material facts to Jr., including the fact that renters at the Canby 

property actually paid rent to BLANCEY LEE. 

48. It was part of the conspiracy that the codefendants failed to truthfully and 

accurately disclose certain material facts to Jr., including the fact that RACHEL LEE and 

BLANCEY LEE purchased the following luxury vehicles with Jr.'s money: 

a. On or about August 1, 2012, RACHEL LEE and BLANCEY LEE purchased a 

2012 white California convertible Ferrari from Ferrari & Maserati of San Diego in 

La Jolla, California. BLANCEY LEE registered this vehicle in Oregon under his 

name, with plate number "MRBIG 1." 

b. On or about August 1, 2012, BLANCEY LEE purchased a 2012 Bentley. 

BLANCEY LEE registered this vehicle in Oregon under his name, with plate 

number "MRBIG." 

c. On or about September 24, 2012, BLANCEY LEE and RACHEL LEE 

purchased a 1955 Chevrolet Bel Air Convertible at Affordable Classics Inc. in 

Oregon City. 

49. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, on or about July 15, 2013, RACHEL LEE transferred $500,000 from 

R. Tree Farm account xx0161 to joint checking xx9334. RACHEL LEE told Jr. this transaction 

was conducted to help satisfy part of his tax liabilities. 

50. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, on or about July 15, 2013, RACHEL LEE induced Jr. to purchase a 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 10 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 10 of 24
cashier's check in the amount of $495,000, drawn from R. Tree Farm xx0161. The cashier's 

check was made payable to the Oregon Department of Revenue (ODOR). RACHEL LEE 

falsely represented to Jr. that the cashier's check would be used to satisfy part of Jr.'s tax 

liabilities. 

51. It was part of the conspiracy that RACHEL LEE failed to truthfully and 

accurately disclose certain material facts to Jr., including the fact that the $495,000 check to the 

ODOR was eventually endorsed by RACHEL LEE as "not used for purposes intended" and redeposited by RACHEL LEE into joint account xx9334 without Jr.' s knowledge or consent. 

52. It was part of the conspiracy that RACHEL LEE and PORSHA LEE/Mary 

Marks falsely represented to Jr. that no profits existed from the sale of the R. Tree Farm property 

and timber, due to taxes imposed and paid. 

53. It was part of the conspiracy that RACHEL LEE and PORSHA LEE/Mary 

Marks falsely represented to Jr. in 2013 that he would need to file for bankruptcy because he was 

out of money. 

54. It was part of the conspiracy that, through material misrepresentations and 

omissions of material fact, on April 23, 2013, RACHEL LEE caused $176,986.01 to be 

transferred from xx9334 Goint) and credited to xx1074 (RACHEL LEE only) by means of wire 

communications, further described as a telephone transfer request by RACHEL LEE. 

55. It was part of the conspiracy that RACHEL LEE and PORSHA LEE/Mary 

Marks failed to truthfully and accurately disclose certain material facts to Jr., including the fact 

that in November of2013, PORSHA LEE/Mary Marks caused the two homes that Jr. retained 

from the earlier R. Tree Farm property sales to be listed for sale. 

United States v. Rachel Lee. et al. 

INDICTMENT PAGEi 11 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 11 of 24
56. It was part of the conspiracy that the defendants failed to truthfully and accurately 

disclose certain material facts to Jr., including the fact that codefendants' theft caused Jr.'s 

accounts to be depleted. 

57. It was further part of the conspiracy that the defendants agreed to conceal the 

nature and existence of the conspiracy and took steps to conceal the existence of the conspiracy. 

58. The misrepresentations of material information and intentional failure to disclose 

material information, as alleged in paragraphs 11 through 57, induced Jr. to give RACHEL LEE 

full control of his finances and Sr.' s finances and resulted in the theft of millions of dollars of 

Jr.' s family assets by the defendants. 

All in violation of Title 18, United States Code, Section 1349. 

COUNTS2THROUGH12 

(Engaging in Monetary Transactions in Criminally Derived Property) 

1. The Grand Jury re-alleges each and every allegation contained in each of the 

paragraphs 1 through 58 of Count 1 of this Indictment, and incorporates them by reference as if 

set forth herein. 

2. On or about the dates listed below, in the District of Oregon and elsewhere, the 

defendants set forth below with respect to each count, together with those known and unknown 

to the Grand Jury, did knowingly engage in and attempt to engage in monetary transactions by, 

through, or to a financial institution affecting interstate or foreign commerce, with criminally 

derived property of a value greater than $10,000.00, that is, the purchase of cashier's checks, the 

making of wire transfers, and the writing of checks, on the dates listed below, such property 

having been derived from specified unlawful activity, each such monetary transaction being a 

separate count of this indictment: 

Ill 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 12 

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Count Defendant Date Amount Description of Transaction 

2 RACHEL LEE 02/01/2010 $34,000 Wire from Acct. 7270 on same 

day as purchase of 196 SE 3rd 

Street, Bend 

3 RACHEL LEE 04/09/2013 $490,808.05 Purchase of cashier's check from 

andBLANCEY Acct. 1074 for purchase of 1316 

LEE NE Broadway St., 

Portland, Oregon 

4 RACHEL LEE 10/05/2012 $251,006 Purchase of cashier's check from 

Acct. 9334 

5 RACHEL LEE 12/27/2012 $131,424.86 Wire out from Acct. 9334 for 

andBLANCEY purchase of 1180 Newberg 

LEE Highway, Woodburn, Oregon 

6 RACHEL LEE 11/29/2011 $231,963.03 Purchase of cashier's check from 

andBLANCEY Acct. 7270 for purchase of 422 

LEE SE l 61

h Ave., Hillsboro, Oregon 

7 RACHEL LEE 02/28/2013 $10,007 Purchase of a cashier's check 

from Acct. 107 4 

8 RACHEL LEE 07/27/2012 $25,000 Check #1456 from Acct. 7270 for 

andBLANCEY purchase of 2012 Ferrari 

LEE California 

9 RACHEL LEE 08/1/2012 $201,437 Wire out from Acct. 7270 for 

andBLANCEY purchase of 2012 Ferrari 

LEE California 

10 RACHEL LEE 08/01/2012 $125,000 Wire out from Acct. 7270 for 

andBLANCEY purchase of vehicle from 

LEE dealership in Dallas, Texas 

11 RACHEL LEE 09/2;z $56,006 Purchase of cashier's check from 

andBLANCEY Acct. 9334 for purchase of 1955 

LEE Chevrolet Bel-Air 

12 RACHEL LEE 04/19/2012 $103,000 Check payable to PORSHA LEE 

and PORSHA for listed amount signed by 

LEE RACHEL LEE, from Acct. 7270, 

no check number. 

All in violation of Title 18, United States Code, Section 1957. 

COUNT 13 

(Conspiracy to Commit Transactional Money Laundering) 

1. The Grand Jury re-alleges each and every allegation contained in each of the 

paragraphs of Counts 1 through 12 of this Indictment and incorporates them by reference as if 

set forth herein. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 13 

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2. From in or about 2004 and continuing until the date of this indictment, in the 

District of Oregon and elsewhere, defendants RACHEL LEE, BLANCEY LEE, PORSHA 

LEE, and SAMANTHA LEE, did unlawfully, knowingly, and intentionally combine, conspire, 

confederate, and agree with each other, and with others, both known and unknown to the Grand 

Jury, to engage or attempt to engage in monetary transactions affecting interstate commerce, in 

criminally derived property of a value greater than $10,000, such property having been derived 

from specified unlawful activity, in violation of Title 18, United States Code, Section 1956(h). 

FIRST FORFEITURE ALLEGATION 

Upon conviction of one or more of the offenses alleged in Count 1 of this Indictment, 

defendant(s) RACHEL LEE, BLANCEY LEE, PORSHA LEE, and SAMANTHA LEE shall 

forfeit to the United States pursuant to 18 U.S.C. § 981(a)(l)(C) and 28 U.S.C. § 2461(c), any 

property constituting or derived from proceeds obtained directly or indirectly as a result of the 

said violation(s), including but not limited to the following: 

1. MONEY JUDGMENT 

A sum of money representing the amount of proceeds obtained as a result of the offense 

of wire fraud, for which the defendants are jointly and severally liable, in the form of a money 

judgment. 

2. REAL PROPERTY 

(a) All that lot or parcel ofland, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 309 SE 1st A VENUE AND 126 S. 

KNOTT STREET, CANBY, CLACKAMAS COUNTY, OREGON, and more 

particularly described as: 

Parcel I: 

Lots 8 and 9, ALBERT LEE'S SECOND ADDITION TO THE CITY 

OF CANBY, in the city of Canby, County of Clackamas and State of 

Oregon. 

EXCEPTING THEREFROM the Southeasterly 46 feet conveyed to 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 14 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 14 of 24
Edward Hiller and wife by Deed recorded April 5, 1937, in Book 200, 

Page 636, Clackamas County Deed Records. 

Parcel II: 

The Southeasterly 45 feet of Lots 8 and 9, ALBERT LEE'S SECOND 

ADDITION TO THE CITY OF CANBY, in the City of Canby, 

Clackamas County, Oregon, described as follows: 

Beginning at the Southerly corner of said Lot 8, on M Street; thence 

Northwesterly, along the Northeasterly line of M street, 46 feet; 

thence Easterly, at right angles to M Street, 100 feet to the 

Northeasterly line of said Lot 9; thence Southeasterly, on said 

Northeasterly line of Lot 9, 46 feet to the most Easterly corner of said 

Lot 9; thence Southwesterly, on the Southeasterly line of said lots, 100 

feet to the place of beginning. 

(b) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 422 SE 16th AVENUE, HILLSBORO, 

WASHINGTON COUNTY, OREGON, and more particularly described as: 

Lots 3, 4 and the North one-half of Lot 5, Block 1, BROWN'S 

SUBDIVISION OF BLOCKS "HAND I" IN FAIRVIEW ADDITION TO 

HILLSBORO OREGON, in the City of Hillsboro, County of Washington 

and State of Oregon. 

Tax ID# R315260 

( c) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 1316 AND 1320 NE BROADWAY 

STREET, PORTLAND, MULTNOMAH COUNTY, OREGON, and more 

particularly described as: 

The West 40 feet of Lots 7 and 8, Block 226, HOLLADA Y'S ADDITION TO 

EAST PORTLAND, in the City of Portland, Multnomah County, Oregon. 

EXCEPTING the North 10 feet thereof taken for the widening of NE 

Broadway Street. Tax Account No. R182408. 

( d) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 196 S.E. 3rd STREET, BEND, 

DESCHUTES COUNTY, OREGON, and more particularly described as: 

Lot 13 in Block 186 of THIRD ADDITION TO BEND PARK, City of Bend, 

Deschutes County, Oregon. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 15 

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( e) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 260 S. KNOTT STREET, CANBY, 

CLACKAMAS COUNTY, OREGON, and more particularly described as: 

Part of Section 33, Township 3 South, Range 1 East of The Willamette 

Meridian, in the City of Canby, County of Clackamas and State of Oregon, 

Described as Follows: 

Beginning at a point which is North 26 West and 400 feet distant from the 

Southeast corner of a Tract described in Deed Recorded January 16, 1884 in 

Deed Book "X", Page 169, Clackamas County deed records; Thence North 

26 West, 50 feet; Thence South 64 West, 125 feet; Thence South 26 East, 50 

feet; Thence North64 East 125 feet to the place of beginning. 

(f) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 623 MAIN STREET, HILLSBORO, 

WASHINGTON COUNTY, OREGON, and more particularly described as: 

PARCEL I: 

Commencing at a point on the South line of Lot 5 , Block 2, ENNES 

ADDITION TO THE CITY OF HILLSBORO, in the City of 

Hillsboro, County of Washington, State of Oregon, which point is 87 

feet 7 inches West of the Southeast corner of Lot 6, said Block 2; 

running thence West, along the South line of Lot 5, Block 2, 65 feet; 

thence North 200 feet; thence East 65 feet; thence South 200 feet, 

more or less, to the place of beginning. 

EXCEPTING THEREFROM that certain tract described in deed 

recorded in Book 165, Page 256, Records of Deeds of Washington 

County, Oregon. 

TOGETHER WITH that portion of vacated alley running East and 

West through said Block 2 which inured thereto by reason of City of 

Hillsboro action entered December 12, 1900 in Book 2, Page 204 and 

recorded December 22, 1983, Fee No.83047308. 

PARCEL II: 

Situated in Section 31, TownshiplNorth, Range 2 West of the 

Willamette Meridian, City of Hillsboro, Washington County, Oregon 

and being a part of Lots 5 and 6 plus a portion of the vacated alley, all 

in Block 2, Ennes Addition to Hillsboro, a plat of record in said 

county, described as follows: 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 16 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 16 of 24
Beginning at the southeast comer of the Manley tract as described in 

Deed Book 216, Page 217, said County Records, common with the 

southwest corner of the Scheller tract as described in Deed Document 

No.95082331, and being on the north right of way of East Main Street, 

and running thence North 02°22'20" East, on the common line 

between aforesaid tracts, 211.17 feet to a point in the center of the 

vacated alley, said Block 2, Ennes Addition; thence South 86°43'50" 

East, in the center of the vacated alley, 85.45 feet to a point on the 

west line of that tract described in Deed Book 1046, Page 131; thence 

South 02°31 '35" West, parallel with NE 7th Avenue, on aforesaid 

tract west line, 60.00 feet to the southwest corner thereof; thence 

North 86°43'50" West 10.00 feet to a point; thence South 02°31'35" 

West 24.33 feet to a point; thence North 86°43'50" West 65.22 feet to a 

point; thence South 02°22'20" West, parallel to and 10.00 feet distant 

from the east line of the Manley tract as described in Deed Book 216, 

Page 217, said County Deed Records,127.57 feet to a point on the 

north right of way of East Main Street; thence North 82°31' 13" West, 

on said right of way, 10.04 feet to the point of beginning. 

(This legal description was created prior to January 1, 2008.) 

PARCEL III: 

Parcel 1 of Partition Plat No. 2008-027, in the city of Hillsboro, 

Washington County, Oregon 

(g) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

Ill 

Ill 

Ill 

fixtures, attachments and easements, located at 1180 NEWBERG HIGHWAY, 

WOODBURN, MARION COUNTY, OREGON, and more particularly described as: 

Part of George Leasure Donation Land Claim in Township 5 South, Rangel 

West of the Willamette Meridian, Marion County, Oregon, more particularly 

described as follows: 

Beginning at the Northeast corner of Lot 1 of HALL'S HOME TRACTS; 

thence South 13°24' West along the easterly line of said Lot, 140 feet; thence 

North 88°30' West 48.0 feet; thence North 0°45' East 135.0 feet to the North 

line of said Lot 1; thence South 88°30' East 78.50 feet to the point of 

beginning. 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 17 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 17 of 24
3. CONVEYANC~S 

Year Make Model VIN Plate 

2012 Ferrari California ZFF65TJA8D0189279 MRBIGl 

2012 Bentley Mulsane SCBBB7ZHXCCO 16796 MRBIG 

1955 Chevrolet Bel-Air VC550024100 WMC468 

2012 Mercedes Benz 550 WODNG9E84CA445894 725FNCS 

4. BANK ACCOUNT 

All United States currency funds or other monetary instruments credited to the following 

accounts: 

Account Account Name Bank Bank Location 

##1074 Rachel Lee Columbia Bank 1000 SW Broadway, Suite 

100, Portland, Oregon, 

97205 

##9334 Rachel Lee and Columbia Bank 1000 SW Broadway, Suite 

Ralph Raines Jr. 100, Portland, Oregon, 

97205 

##8579 Rachel Lee Wells Fargo Bank 1300 SW 5th Ave., Portland, 

Oregon,97204 

If any of the above-described forfeitable property, as a result of any act or omission of the 

defendants: 

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

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

( 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; 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 18 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 18 of 24
it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) as incorporated by 18 U.S.C. 

§ 982(b), to seek forfeiture of any other property of said defendant(s) up to the value of the 

forfeitable property described above. 

SECOND FORFEITURE ALLEGATION 

Upon conviction of one or more of the offenses alleged in Counts 2 through 13 of this 

Indictment, defendants RACHEL LEE, BLANCEY LEE, PORSHA LEE, and SAMANTHA 

LEE shall forfeit to the United States pursuant to 18 U.S.C. § 982(a)(l), all property, real and 

personal, involved in the money laundering offense(s) and all property traceable to such 

property, including but not limited to the following: 

1. MONEY JUDGMENT 

A sum of money representing the amount of proceeds obtained as a result of the offense 

of money laundering, for which the defendants are jointly and severally liable, in the form of a 

money judgment. 

2. REALPROPERTY 

(a) All that lot or parcel ofland, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 309 SE 1st A VENUE AND 126 S. 

KNOTT STREET, CANBY, CLACKAMAS COUNTY, OREGON, and more 

particularly described as: 

Parcel I: 

Lots 8 and 9, ALBERT LEE'S SECOND ADDITION TO THE CITY 

OF CANBY, in the city of Canby, County of Clackamas and State of 

Oregon. 

EXCEPTING THEREFROM the Southeasterly 46 feet conveyed to 

Edward Hiller and wife by Deed recorded April 5, 1937, in Book 200, 

Page 636, Clackamas County Deed Records. 

Parcel II: 

The Southeasterly 45 feet of Lots 8 and 9, ALBERT LEE'S SECOND 

ADDITION TO THE CITY OF CANBY, in the City of Canby, 

Clackamas County, Oregon, described as follows: 

Beginning at the Southerly corner of said Lot 8, on M Street; thence 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 19 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 19 of 24
Northwesterly, along the Northeasterly line of M street, 46 feet; 

thence Easterly, at right angles to M Street, 100 feet to the 

Northeasterly line of said Lot 9; thence Southeasterly, on said 

Northeasterly line of Lot 9, 46 feet to the most Easterly corner of said 

Lot 9; thence Southwesterly, on the Southeasterly line of said lots, 100 

feet to the place of beginning. 

(b) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 422 SE 16th AVENUE, HILLSBORO, 

WASHINGTON COUNTY, OREGON, and more particularly described as: 

Lots 3, 4 and the North one-half of Lot 5, Block 1, BROWN'S 

SUBDIVISION OF BLOCKS "HAND I" IN FAIRVIEW ADDITION TO 

HILLSBORO OREGON, in the City of Hillsboro, County of Washington 

and State of Oregon. 

Tax ID# R315260 

( c) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 1316 AND 1320 NE BROADWAY 

STREET, PORTLAND, MULTNOMAH COUNTY, OREGON, and more 

particularly described as: 

The West 40 feet of Lots 7 and 8, Block 226, HOLLADAY'S ADDITION TO 

EAST PORTLAND, in the City of Portland, Multnomah County, Oregon. 

EXCEPTING the North 10 feet thereof taken for the widening of NE 

Broadway Street. Tax Account No. R182408. 

( d) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 196 S.E. 3rd STREET, BEND, 

DESCHUTES COUNTY, OREGON, and more particularly described as: 

Lot 13 in Block 186 of THIRD ADDITION TO BEND PARK, City of Bend, 

Deschutes County, Oregon. 

( e) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 260 S. KNOTT STREET, CANBY, 

CLACKAMAS COUNTY, OREGON, and more particularly described as: 

United States v. Rachel Lee, et al. 

INDICTMENT PAGE! 20 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 20 of 24
Part of Section 33, Township 3 South, Range 1 East of The Willamette 

Meridian, in the City of Canby, County of Clackamas and State of Oregon, 

Described as Follows: 

Beginning at a point which is North 26 West and 400 feet distant from the 

Southeast corner of a Tract described in Deed Recorded January 16, 1884 in 

Deed Book "X", Page 169, Clackamas County deed records; Thence North 

26 West, 50 feet; Thence South 64 West, 125 feet; Thence South 26 East, 50 

feet; Thence North64 East 125 feet to the place of beginning. 

(f) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

fixtures, attachments and easements, located at 623 MAIN STREET, HILLSBORO, 

WASHINGTON COUNTY, OREGON, and more particularly described as: 

PARCEL I: 

Commencing at a point on the South line of Lot 5 , Block 2, ENNES 

ADDITION TO THE CITY OF HILLSBORO, in the City of 

Hillsboro, County of Washington, State of Oregon, which point is 87 

feet 7 inches West of the Southeast corner of Lot 6, said Block 2; 

running thence West, along the South line of Lot 5, Block 2, 65 feet; 

thence North 200 feet; thence East 65 feet; thence South 200 feet, 

more or less, to the place of beginning. 

EXCEPTING THEREFROM that certain tract described in deed 

recorded in Book 165, Page 256, Records of Deeds of Washington 

County, Oregon. 

TOGETHER WITH that portion of vacated alley running East and 

West through said Block 2 which inured thereto by reason of City of 

Hillsboro action entered December 12, 1900 in Book 2, Page 204 and 

recorded December 22, 1983, Fee No.83047308. 

PARCEL II: 

Situated in Section 31, TownshiplNorth, Range 2 West of the 

Willamette Meridian, City of Hillsboro, Washington County, Oregon 

and being a part of Lots 5 and 6 plus a portion of the vacated alley, all 

in Block 2, Ennes Addition to Hillsboro, a plat of record in said 

county, described as follows: 

Beginning at the southeast comer of the Manley tract as described in 

Deed Book 216, Page 217, said County Records, common with the 

southwest corner of the Scheller tract as described in Deed Document 

No.95082331, and being on the north right of way of East Main Street, 

and running thence North 02°22'20" East, on the common line 

between aforesaid tracts, 211.17 feet to a point in the center of the 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 21 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 21 of 24
vacated alley, said Block 2, Ennes Addition; thence South 86°43'50" 

East, in the center of the vacated alley, 85.45 feet to a point on the 

west line of that tract described in Deed Book 1046, Page 131; thence 

South 02°31 '35" West, parallel with NE 7th Avenue, on aforesaid 

tract west line, 60.00 feet to the southwest corner thereof; thence 

North 86°43'50" West 10.00 feet to a point; thence South 02°31 '35" 

West 24.33 feet to a point; thence North 86°43'50" West 65.22 feet to a 

point; thence South 02°22'20" West, parallel to and 10.00 feet distant 

from the east line of the Manley tract as described in Deed Book 216, 

Page 217, said County Deed Records,127.57 feet to a point on the 

north right of way of East Main Street; thence North 82°31' 13" West, 

on said right of way, 10.04 feet to the point of beginning. 

(This legal description was created prior to January 1, 2008.) 

PARCEL III: 

Parcel 1 of Partition Plat No. 2008-027, in the city of Hillsboro, 

Washington County, Oregon 

(g) All that lot or parcel of land, together with its buildings, appurtenances, improvements, 

Year 

2012 

2012 

1955 

2012 

fixtures, attachments and easements, located at 1180 NEWBERG HIGHWAY, 

WOODBURN, MARION COUNTY, OREGON, and more particularly described as: 

Part of George Leasure Donation Land Claim in Township 5 South, Rangel 

West of the Willamette Meridian, Marion County, Oregon, more particularly 

described as follows: 

Beginning at the Northeast corner of Lot 1 of HALL'S HOME TRACTS; 

thence South 13°24' West along the easterly line of said Lot, 140 feet; thence 

North 88°30' West 48.0 feet; thence North 0°45' East 135.0 feet to the North 

line of said Lot 1; thence South 88°30' East 78.50 feet to the point of 

beginning. 

3. CONVEYANCES 

Make Model VIN Plate 

Ferrari California ZFF65TJA8DO 189279 MRBIGl 

Bentley Mulsane SCBBB7ZHXCCO 16796 MRBIG 

Chevrolet Bel-Air VC550024100 WMC468 

Mercedes Benz 550 WODNG9E84CA445894 725FNCS 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 22 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 22 of 24
4. BANK ACCOUNTS 

All United States currency funds or other monetary instruments credited to the following 

accounts: 

Account Account Name Bank Bank Location 

##1074 Rachel Lee Columbia Bank 1000 SW Broadway, Suite 

100, Portland, Oregon, 

97205 

##9334 Rachel Lee and Columbia Bank 1000 SW Broadway, Suite 

Ralph Raines Jr. 100, Portland, Oregon, 

97205 

##8579 Rachel Lee Wells Fargo Bank 1300 SW 5th Ave., Portland, 

Oregon, 97204 

If any of the above-described forfeitable property, as a result of any act or omission of the 

defendants: 

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

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

( 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; 

Ill 

Ill 

Ill 

Ill 

Ill 

Ill 

Ill 

United States v. Rachel Lee, et al. 

INDICTMENT PAGEi 23 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 23 of 24
it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) as incorporated by 18 U.S.C. 

§ 982(b), to seek forfeiture of any other property of said defendant(s) up to the value of the 

forfeitable property described above. 

Dated this _1_ day of May 2014. 

Presented by: 

S. AMANDA MARSHALL, OSB #95347 

United States Attorney 

District of Oregon 

ssistant United States Attorney 

(503) 727-1000 

United States v. Rachel Lee, et al. 

INDICTMENT 

A TRUE BILL. 

PAGEi 24 

Case 3:14-cr-00184-JO Document 1 Filed 05/08/14 Page 24 of 24