UNITED STATES DISTRICT COURTDISTRICT OF MARYLAND
UNITED STATES OF AMERICAv.MARK
I, the undersigned complainant being duly sworn, state the following is true and correct tothe best of my knowledge and belief.1. On or about August 18, 2009, in the District of Maryland, defendant MARK
LUNSFORD presented to the United States Drug Enforcement Administration ("DEA"), adepartment and agency ofthe United States, a claim upon and against the United States, and adepartment and agency of the United States, knowing such claim to be materially false, fictitious,and fraudulent, to wit: aRequest for Payment Under 28 U.S.C.
524(c), in which LUNSFORDprovided a false justification for an award to DEA Confidential Source ("CS") 95-.075570 of 20percent of $17,490 that had been seized in connection with the execution of a search and seizurewarrant, in violation of Title 18, United States Code, Section 287.2. On or about July 1,2009, in the District of Maryland, defendant MARK
LUNSFORD, in a matter within the jurisdiction of the executive branch of the Government of the United States, knowingly and willfully made a materially false, fictitious, and fraudulentstatement and representation; to wit: LUNSFORD stated in a Form DEA-6. that DEA CS 95-075570 had provided intelligence to LUNSFORD about a person suspected to be a drug dealer("Suspect-I"'), when as LUNSFORD well knew, DEA CS 95-075570 had not provided anyinformation to LUNSFORD about Suspect-I, in violation of Title 18, United States Code,Section 1001. .3. In or about October 2008, in the District of Maryland, defendant MARK
LUNSFORD, being an officer and employee ofthe United States and of any department andagency thereof, embezzled and wrongfully converted to his own use the property of anotherhaving a value in excess of$IOOO; to wit, a rose-colored, stainless steel "AQUA MASTER"diamond watch, model number: 1282, which had come into LUNSFORD's possession and underhis control in the execution of such office and employment, and under color and claim of authority as such officer and employee, in violation of Title 18, United States Code, Section 654.I further state that I am a Special Agent with the Federal Bureau ofInvestigation, and thatthis complaint is based on the following facts: