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Michelle Schramm Indictment

Michelle Schramm Indictment

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Categories:Types, Legal forms
Published by: Nick on Mar 18, 2011
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Criminal Action No.UNITED STATES OF AMERICA,Plaintiff,v.1. MICHELLE SCHRAMM,a/k/a UK CHIN SCHRAMM,Defendant. 
18 U.S.C. § 1952(a)(3) & (b)18 U.S.C. § 2422(a)18 U.S.C. § 1957(a)26 U.S.C. § 7206(1)18 U.S.C. § 982(a)(1)The Grand Jury Charges that:
- 24(Travel Act – Use of Interstate Facility to Promote a BusinessEnterprise Involving Prostitution Offenses)
The Business Enterprise1. Beginning on or about December 7, 2005, and continuingthrough and including March 17, 2009, in the State and District ofColorado, the defendant MICHELLE SCHRAMM, a/k/a UK CHIN SCHRAMM(“Schramm”), controlled and operated three businesses in the DenverMetropolitan area. The three businesses were: (1) Bali Spa locatedin Arapahoe County, (2) Malley Spa located in Northglenn, and (3)Green Garden Spa (also known as Beach Tanning Spa) located inEdgewater. (collectively referred to as “spas”). In the course ofrunning her spas, the Defendant regularly provided prostitution
Case 1:10-cr-00571-PAB Document 1 Filed 11/15/10 USDC Colorado Page 1 of 13
services.2. The Defendant typically staffed her spas with a rotatingstaff of female workers (also referred to as “prostitutes”). Inexchange for money, the prostitutes would provide massages as wellas routinely perform sexual acts for customers (also referred to as“Johns”).3. To facilitate operation of the spas, the Defendantemployed a housemother. The housemother served as an on-sitemanager of the spas. She was typically responsible for schedulinga customer’s spa session, collecting funds from customers,providing towels and linens, cleaning, and attending to the variousneeds of the prostitutes and Johns. The housemother reported toSCHRAMM and was responsible for providing the money collected fromthe spa during the course of the day.4. The Defendant promoted, managed, established, carried onor facilitated the operation of each of the spas in various ways,including but not limited to:(A) arranging for the spas’ business locationsand furnishings;(B) arranging for or obtaining the spas’ businesslicenses;(C) paying for or arranging for the payment ofvarious bills connected with the spasincluding utilities and rent;(D) paying for or arranging for advertisement forthe spas through Westword magazine, internetwebsites and other media outlets;(E) collecting the proceeds from the spas and
Case 1:10-cr-00571-PAB Document 1 Filed 11/15/10 USDC Colorado Page 2 of 13
paying the various workers and housemother;(F) providing lodging for various workersincluding at times allowing such workers tostay at her personal residence or sleepinside the spas;(G) arranging for or providing interstatetransportation for the prostitutes to or fromColorado by airplane;(H) arranging for transportation of workerswithin Colorado through taxicabs or use of anautomobile controlled by the Defendant; and(I) supplying the prostitutes with condoms;Use of the Mail or a Facility in Interstate Commerce5. On or about the dates set forth below, in the State andDistrict of Colorado, and elsewhere, the defendant SCHRAMM used themail or a facility in interstate commerce as set forth below, withintent to otherwise promote, manage, establish, carry on, orfacilitate the promotion, management, establishment, or carryingon, of unlawful activity, namely, a business enterprise involvingthe prostitution offenses of Pimping in violation of ColoradoRevised Statute 18-7-206, and Keeping a Place of Prostitution inviolation of C.R.S. 18-7-204.Count Date Mailing or Facility Used in InterstateOr Foreign Commerce
1-4-2006 Credit card charge for prostitutionservices by CH for $220 using WellsFargo Bank and connected charge terminal
1-16-2006 Telephone Call from Defendant’s cellularphone to Bali Spa
2-5-2006 Credit card charge for prostitutionservices by MK for $210 using WellsFargo Bank and connected charge terminal
3-23-2006 Credit card charge for prostitution
Case 1:10-cr-00571-PAB Document 1 Filed 11/15/10 USDC Colorado Page 3 of 13

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