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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 13-cr-00259-REB UNITED STATES OF AMERICA, Plaintiff, v. MARK MICHAEL BOTE, Defendant.
INDICTMENT 49 U.S.C. §§ 46504 and 46507
COUNT ONE The Grand Jury charges that: On or about June 14, 2013, in the State and District of Colorado, elsewhere, and on Frontier Airlines Flight 601, which was then and there an aircraft in the special aircraft jurisdiction of the United States, MARK MICHAEL BOTE, the defendant herein, by intimidating a flight attendant of Flight 601, interfered with the performance of the duties of the flight attendant and lessened the ability of the flight attendant to perform those duties. The foregoing was in violation of Title 49, United States Code, Section 46504. COUNT TWO The Grand Jury further charges that: On or about June 14, 2013, in the State and District of Colorado, elsewhere, and on Frontier Airlines Flight 601, which was then and there an aircraft in the special aircraft jurisdiction of the United States, and was an aircraft in and intended for operation in air
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transportation, MARK MICHAEL BOTE, the defendant herein, knowing the information to be false, willfully and maliciously gave, under circumstances in which the information reasonably may be believed, false information about an act that if done would violate Section 46505(b)(1) and (3) of Title 49, to wit: the defendant stated to a flight attendant of Flight 601 that he had on or about his person and property a concealed dangerous weapon that would be accessible in flight, and stated that he had about his person and had placed on the aircraft, an explosive or incendiary device. The foregoing was in violation of Title 49, United States Code, Section 46507.
A TRUE BILL:
Ink signature on file in the Clerk’s Office__ FOREPERSON
JOHN F. WALSH United States Attorney
By: s/James R. Allison JAMES R. ALLISON Assistant U.S. Attorney United States Attorney’s Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 Fax: (303) 454-0403 E-mail: firstname.lastname@example.org Attorney for the Government
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MARK MICHAEL BOTE 1989
ADDRESS (CITY/STATE): In custody COMPLAINT FILED? X YES NO 13-mj-01094-CBS
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO AOFFENSE@ SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE:
COUNT ONE: Interference with flight crew members and attendants, 49 U.S.C. § 46504 COUNT TWO: False information and threats, 49 U.S.C. § 46507 In the special aircraft jurisdiction of the United States
LOCATION OF OFFENSE:
COUNT ONE: NMT 20 years imprisonment, NMT $250,000 fine, or both; $100 special assessment; NMT 5 years supervised release. COUNT TWO: NMT 5 years imprisonment, NMT $250,000 fine, or both; $100 special assessment; NMT 3 years supervised release. Special Agent Martin Daniell, III Federal Bureau of Investigation
AUTHORIZED BY: James R. Allison Assistant U.S. Attorney ESTIMATED TIME OF TRIAL: X five days or less over five days other
THE GOVERNMENT X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is or is not applicable to this defendant. (Circle one) OCDETF CASE: Yes X No