Case 4:20-cr-00082-DN-PK Document 1 Filed 07/23/20 PageID.

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FILED
2020 JUL 23 PM 3:45
CLERK
U.S. DISTRICT COURT
JOHN W. HUBER, United States Attorney (#7226)
TRINA A. HIGGINS, Assistant United States Attorney (#7349)
STEPHEN P. DENT, Assistant United States Attorney (DC 1034263)
Attorneys for the United States of America
20 North Main Street, Suite 208
St. George, Utah 84770
Telephone: (435) 634-4262 SEALED
stephen. dent@usdoj.gov

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH, CENTRAL DIVISION

INDICTMENT
UNITED STATES OF AMERICA,
VIOLATIONS:
Plaintiff, COUNTS 1-3: 18 U.S.C. §§ 1343 and 2
(Wire Fraud)
v. COUNTS 4-5: 18 U.S .C. §§ 912 and 2
(False Personation of an Employee of the
United States)
KURT JURGENS BAUER,
Case: 4:20−cr−00082
Defendant. Assigned To : Nuffer, David
Assign. Date : 7/23/2020
Description:

The Grand Jury charges:

I. BACKGROUND

At all times relevant to the Indictment:

1. KURT JURGENS BAUER was a resident of Kane County, Utah and Clark

County, Nevada.

2. Beginning in 2015, BAUER maintained a personal bank account ending in 1771 at

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Wells Fargo Bank. BAUER was the sole signer on this account and provided his

residential address in Mount Carmel, Utah as the address for the account.

II. THE SCHEME AND ARTIFICE TO DEFRAUD

3. Beginning sometime in 2011 and continuing until April 2020, in the Central

Division of the District of Utah, and elsewhere, BAUER devised, and intended to devise,

a scheme and artifice to defraud and to obtain money and property by means of false and

fraudulent pretenses, representations, and promises and omissions of material facts. In

executing and furthering the scheme, Defendant used email, interstate wire transmissions,

and the facilities and means of interstate commerce.

III. MANNER AND MEANS OF THE SCHEME AND ARTIFICE

4. Beginning sometime in 2011, BAUER represented to victims that he was on the

verge of receiving hundreds of millions-and even billions-of dollars. He solicited

payments from victims and, in exchange, promised that he would pay victims large

returns when he received the funds.

5. In furtherance of the scheme, BAUER told victims that the United States District

Court for the District ofNevada froze and was holding large sums of money that

belonged to him.

6. He told victims that the court required "bond" payments to secure the frozen

funds, and he solicited victims to make the payments. He often solicited payments on a

weekly basis.

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7. BAUER represented to victims that the court was going to release funds to him in

the near future. He promised that, once the court released the funds to him, victims would

receive large returns in exchange for their upfront payments.

8. BAUER solicited and received over $300,000 from victims, including at least

$200,000 from C.B., age 82, and L.B., age 80.

9. In reality, BAUER fabricated the information he provided to victims about his

wealth and the court process to release funds. BAUER had relatively little wealth, apart

from the money he fraudulently took from victims. He had no prospect of receiving large

amounts of money. No court was holding money to which BAUER was entitled. And

BAUER had no way of paying victims the promised returns.

10. The victim's "bond" payments were not sent to a court. BAUER spent the victim's

money on himself. He spent the money on expensive hotel bills, credit-card payments,

and restaurants, among other things.

11. To further the scheme, BAUER created false identities of a New York attorney, a

federal court employee, and a billionaire that he used to make misrepresentations to and

solicit payments from victims.

12. BAUER created phone numbers and email accounts for the false identities.

Unbeknownst to the victims, BAUER and his accomplices pretended to be the false

identities in phone calls, emails, and text messages with victims. Communications

between the victims and the false identities were actually between the victims and

BAUER or between victims and BAUER's accomplices.

13. Through use of false identities, BAUER and his accomplices made

misrepresentations about the frozen funds and court process to release the funds.

14. In furtherance of the scheme, BAUER and his accomplices impersonated federal

judges and a federal court administrator during communications with victims to convince

victims that the court process was real and persuade victims to continue making

payments.

COUNTS 1-3
18 U.S.C. §§ 1343 and 2
(Wire Fraud)

15. Between March 2017 and March 2018,

KURT JURGENS BAUER,

defendant herein, having devised and intended to devise the above-described scheme and

artifice to defraud, and for obtaining money and property by means of false and

fraudulent pretenses, representation, and promises, for the purpose of executing said

scheme and artifice to defraud, did cause to be transmitted by means of wire

communication in interstate commerce certain writings, signs, and signals, and did aid

and abet therein, each such use of wire communication being a separate count of this

Indictment:

Date
Count Wire Transmission
(on or about)
Wire transfer of $15,000 from C.B.'s Pahranagat Valley
1 Federal Credit Union account to BAUER's Wells Fargo
March 30, 2017
bank account ending in 1771.

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Wire transfer of $10,000 from C.B.'s Pahranagat Valley

All in violation of 18 U.S.C. §§ 1343 and 2.

COUNT4
18 U.S.C. §§ 912 and 2
(False Personation of an Employee of the United States)

16. On or about December 1, 2016, in the Central Division of the District of Utah, and

elsewhere,

KURT JURGENS BAUER,

defendant herein, did falsely assume and pretend to be an officer and employee of the

United States acting under the authority thereof, that is, an employee of the U.S. District

Court for the District of Nevada, and in such assumed and pretended character did falsely

demand and obtain money from J.M., and did aid and abet therein. All in violation of

18 U.S.C. §§ 912 and 2.

COUNTS
18 U.S.C. §§ 912 and 2
(False Personation of an Employee of the United States)

17. On or about December 9, 2016, in the Central Division of the District of Utah, and

elsewhere,

KURT JURGENS BAUER,

defendant herein, did falsely assume and pretend to be an officer and employee of the
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United States acting under the authority thereof, that is, an employee of the U.S. District

Court for the District of Nevada, and in such assumed and pretended character did falsely

demand and obtain money from J.M. and D.C., and did aid and abet therein. All in

violation of 18 U.S.C. §§ 912 and 2.

NOTICE OF INTENT TO SEEK FORFEITURE

Pursuant to 18 U.S.C. § 98l(a)(l)(C) and 28 U.S.C. § 246l(c), upon conviction of

any offense in violation of 18 U.S.C. § 1343, the defendant shall forfeit to the United

States of America any property, real or personal, that constitutes or is derived from

proceeds traceable to the scheme to defraud. The property to be forfeited includes, but is

not limited to, the following:

• A money judgment equal to the value of any property, real or personal,

• Substitute property as allowed by 28 U.S.C. § 246l(c) and 21 U.S.C.

/S/

JOHN W. HUBER
United States Attorney

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TRJNA A. HIGGINS
Assistant United States Attorney
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