JESSICA S. SMITH, BarNo.

10272
Assistant Attorney General
SEAliI D REYES, Bar No. 7969
Utah Attomey General
160 East 300 South, Fiffh Floor
P.O. Box 140872
Salt Lake City, Utah 84114-0872
Tel: (801) 366-0225
Email : j essicasmith@agutah. gov
Atlorneysfor the State of Utah

IN TIIE FOTJRTH JUDICIAL DISTRICT COURT IN AND X'OR

urAH coUNTY, STATE O['UTArr

STATE OF UTAH,
CRIMINAL INFORMATION
Plaintiff,

vs.

.IENNIFER CLEGG, Case No:

DOB: September 13,1976
Judge:
Defendant.

The undersigned, upon oath, states on information and belief that the above-identified

defendant has committed the following crimes:

COI]NT 1
COMMUNICATIONS X'RAUI)
ø lhlrd4egreefelony
(2015 ASACC Travel Expenses)

Commenoing on or about March 4,2075, in Utatr County and the State of UtaJ¡

defendant did devise a scheme or artifice to defraud or to obtain money, properly or anything of

value by means of false or fiaudulent pretenses, representations, promises, or material omissions,

and communicated directly or indirectly with any person by any means for the purpose of

executing or concealing the scheme or artifice. The total value of the property, money or thing
 This is in
obtained or sought to be obtained by the scheme ot artifice was less than $5,000-

violation of utah code Ann. 76-10-1801, a third-degree felony.

couNT 2
COMMT]IUCATIONS FRAUI)
a second-degreefelonY
(Liaison Hotel)

Commencing on or about August 2015 in Utah County and the State of Utatr, defendant

of value by
did devise a scheme or artifice to defraud or to obtain money, property or anything

omissions, and
means of false or fraudulent pretenses, representations, promises, or material

purpose of executing
communicated directþ or indirectþ with any person by any means for the

obtained or
or concealing the scheme or artifice. The total value of the property, money or thing

sought to be obtained by the scheme or artifice exceeded $5,000. This is

in violation of Utalt

Code Ann. 76-10-1801, a second-degree felony'

couNT 3
COMMT]NICATIONS FRAUI)
a second-degreefelonY
(CLACO PaYments)
of Utah,
Commencing on or about November 4,2015, in Utah County and the State

property or anything of
defendant did devise a scheme or artifice to defraud or to obtain money'

promises, or material omissions,

value by means of false or fraudulent pretenses, representations,

and commr¡nicated directly or indirectly with any person by any means for the purpose of

propedy, money or thing

executing or concealing the scheme or artifice. The total value of the

This is in violation
obtained or sought to be obtained by the scheme or artifice exceeded S5,000.

of Utatr Code Ann. 76-10-1801, a second-degree felony'

2
 COUNT 4
PATTERN OF T]NLAITT'UL ACTIVITY
a second'degrcefelonY

That commencing in or about 20l4,in the State of Utah, defendant did engage in

conduct, which constituted the commission of at least three episodes of unlawful

activity as

proceeds derived,
defined in Utatr Code Ann. $ 76-10-1603. The defendant: (1) received any

directþ or indirectly, from a pattem of r¡nlawful activity in which he participated as a principal,

used or invested, directly or indirectly, my part of that income, or the proceeds of that income, or

the proceeds derived from the investment or use of those proceeds, in the acquisition
of any

pattern of unlawful
interest in, or the establishment or operation of, any enterprise; (2) through a

activity, acquired or maintained, directly or indirectly, any interest in or control of any

or participate,
enterprise; or (3) was employed by or associated with any enterprise to conduct

directly or indirectly in the conduct of that enterprise's affairs through a pattern of unlawful
r¡nlawfi¡l
activity, or (4) conspired to violate any of the above-mentioned provisions. The alleged

acts which constitute the pattern of unlawful activity include, but are not limited
to, the acts as

described above in counts I through 3. These acts include three or mote acts of unlau¡firl activity

(Communications Fraud) as defined in Utah Code Ann'

g 76-10-1602. These acts are second degree and thfud-degree felonies in violation of Utatr Code

Ann. $ 76-10-1603.5.

EXECUTED on this 14-dav of R l"m u'...-, , 2019.

J
AUTHORIZED for presentrrent and filing on this 1fu*tof FEBRUARY 20lg-

SEAÌ{ D. REYES
UtahAttorney General

Attomey General