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information as follows:
1. From on or about April 8, 1991 through April
11, 1991, at Chicago * * * defendant JAMES E. WELLS
knowingly and intentionally, for the purpose of evading
the filing with the Internal Revenue Service of a
Currency Transaction Report (IRS Form 4789), as re-
quired by Title 31, United States Code, Section
5313(a), structured and assisted in structuring, and
attempted to structure and assist in the structuring,
of a transaction with domestic financial institutions,
namely, by cashing twenty simultaneously-purchased and
sequentially-numbered cashier’s checks, each drawn on
Bell Federal Savings in the amount of $2,000 and pay-
able to defendant JAMES E. WELLS, at the following
domestic financial institutions in the following
amounts on or about the dates cited:
Date Amount Financial Institution
4/8/91 $10,000 New Rush Street Currency Exchange
4/9/91 10,000 New Rush Street Currency Exchange
4/9/91 4,000 New Milwaukee-Ogden Currency Exchange
4/9/91 4,000 Columbia Currency Exchange
4/10/91 2,000 New Milwaukee-Ogden Currency Exchange
4/11/91 10,000 New Milwaukee-Ogden Currency Exchange;
In violation of Title 31, United States Code,
Sections 5324(3) and 5322(a).
2. From on or about April 12, 1991 through April
19, 1991, at Chicago * * * defendant JAMES E. WELLS
knowingly and intentionally, for the purpose of evading
the filing with the Internal Revenue Service of a
Currency Transaction Report (IRS Form 4789), as re-
quired by Title 31, United States Code, Section
5313(a), structured and assisted in structuring, and
attempted to structure and assist in the structuring,
of a transaction with domestic financial institutions,
namely, by cashing five simultaneously-purchased and
sequentially-numbered cashier’s checks, each drawn on
National Security Bank in the amount of $5,000 and
payable to defendant JAMES E. WELLS, at the following
domestic financial institutions in the following
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Last modified: May 25, 2011