t INIl't'I) S'I'A'[ES DIS'I'RICT COUR'I'IOTT TIIE DISTITICT OF COLU}IBI.,\

Ilolding a Crinrinal Term(irand.lury Sworn in on IIal'21,201{

UNI'f I'D S1'A'I'}]S OI. AMERICA,

l)o1.r(;l.As I t t'G HES,Also known as Doug Hughes,

I)cferrdant.

Case. 1 :1 5-cr-00063Assigned To : Kollar-Kotelly. ColleenAssign. Date . 5l2Ol2O15Description: INDICTMENT (B)

'l-he Crand Jury charges that

crili\ilN"\t. No.

VIOLATIONS: ,19 tl.S.C. S 16-106(bX7)(Oprating as an AirmanWithout an Airman'sCertificate)

{e u.s.c. s 16306(b)(5)(^)(Owning an Aircraft that isKnorvingly' Operrted Whrnthc A ircraf: is NotRcgistered).19 tl.S.C. $$ ,16307 and,l0l 03(b) (Violation ofNational Defense Airspace)

l8 t I.S.C. $ l73l (VehiclcFalscly Labeled as PostalCarricr)

INDICTMIiNT

cot.\t'o\[

4e rj.s.c. $ 46306(d)(l),28U.S.C. $ 2.161(c), and 21U.S.C. $ 853(p) (CriminalForfeiture)

FILED { OPEN COURTMAY 2 O zOE

CLERK, U,S. DISTRICT GOURTDISTRICT OF COLUMBIA

on or abour April I 5. 20 I 5, within rhe Disrricr ot columbia, DouG l,As HUCi HES, alsoknoul as [)oug Hughes. knr-rwingly and willhrlly served as an aimran rlithoLrt an airman'scertilicate authorizing him ttl serve in that capacitv.

(Opcrating as an Airman Without an Airman's Certificate, in violation ol'Title '19.United States Code, Section 46306(bX7))

COUNT TWO

C)n or about April I5, 201i, within the Districl of Columbia. DOUGLAS HUGHES, also

knorvn as Doug I lughes, o''vned an aircraft eligible tbr rcgistration by the Federal Aviation

Aclministration under 49 tj.S.C. $ 44102. and knou'ingly and willl'ully operaled the aircraft u'hen

thc aircrali wi$ not registered under 49 LI.S.C. $ 441 03.

(Owning an .A.ircraft that is Knowingll'Ope rated When the Aircrafl is NotRegistcred, in violation ofl'itle 49, Unitecl States Code, Section 46306(bX5XA))

COT]NT THREE

On or about April 15, 2015. within thc District of Columbia and elsewhere, DOUCLAS

HUGHES, also kno*r as Dough tlughes. *hile piloting a gyrocoptcr, did knowingly and

willt'ully, and *'ithout larvt'ul authority, conduct flight operations in the rcstrictcd airspace

known as thc Washington, D.C., Metropolitan Area Special Flight Rules Area (DC SI]RA) in

viofation ot''l'itle 14, Code olFedcral Rcgulations, Section 93.331 ct seq.,a regullrion

prescribed under 49 U.S.C. g 40103(bX3).

(Vkrlation of National Defense Airspace, in violation of 'l itlc 49, United States Code.Sections 46307 and .101 03(b))

COUNT POUR

On or about April 15.2015, rvirhin rhe Disrricr of Columbia, DOUGLAS HUCHES, also

knowr rrs Doug Ilughes, rvhilc piloring a gyrocoprer, did knowingly and willlully, and without

lawt'ul authority. conduct llight operations in restricted airspace known as the washington, D.c..

Metropolitan Area Flight Rcslricred Zonc (I)c FRZ) in vi,lation ol.'litle 14, code of I.edcralRegulations,Section93.S3latseq.,aregulalionprescribcdunder4g[J.S.C.g40l03(bX3).

(Violation of National Defense Airspace, in violation ol'fitle 49, United States Code.Sections 46107 and 401 03(b))

(IOIINT IIIVT]On or about April 15, 2015, rvithin the District ol'Columbia. DOIJGLAS HUGHES. also

known as Doug IIughes. while piloting a gyrocopter. did knowingly and willlirlly, and without

la* lul autliority, conduct tlight operations in the restricted airspace knoun as the Prohibited

Area ['-56 (P-56) in vio]ation ofl itle 14, Code of]cderal Regulations. Scction 73.81 cl .\eq..31

Federal llegister I 3422 ( 1966). as amended by 76 Federal Registcr 9i0l (201 I ). a regulation

prescribed under 49 l.J.S.C. S 40103(bX3).

(Violation ofNational Dcfcnse Airspace, in violation ol"Iitle 49, [Jnitcd Statcs Code,Sections 46307 and 401 0ll(b))

COUNT SIX

On or about April 15, 201 5, rvithin the District of Columbia, DOUCLAS I'IU(iHES, alsoknown as Doug Ilughes, knowingly and lvillf'ully operated and owned a vehicle and convoyance.

and placed and attached words. letters. and characlers on the vchicle and conveyance ol'like

imporl to "Unitsd States Mail," to wit, the logo ancl emblem olthe [Jnited States Postal Scrvicc,

when the vehicle and conveyance was not used to carry, [Jnited States NIail.

(Vehicle Falscly Labeled as Postal Carrier, in violation ot'Title 18, United StatesCode, Scction l73l )

r'oRFE l'IU RE A Ll.EG,\TION

l. Upon conviction ol'the oft'enses alleged in Counts One and/or Tlvo, the defcndantshall fbrl'cit to the United States any aircrafl and propcrty whose use related to thc violations in

thosc counts, pursuant to 49 u.s.c. $ 46j06(dXI). 'l'he property subjecr ro tbrlciture includesthe gyrocopler, and materiais and itenrs arlachcd and related thereto. or found therein, rhat was

recoverccl on April 15,2015, and rvliich was Uown to the Wcst Front Lawn of the United States

Capitol Building.

2. I l'any ol' the property clcscribed above as being subjcct to tbrfeiture, as a result of

any ael or omission of the dcl'endant:

a. cannol be located upon the exercise ofdue diligencel

b. has been translcrred or sold lo, or dcposited with, a third party;c. has bccn placed beyond thejurisdiction ofthc Court;

tl. has been srrbstantially dilninislred in value; ore.hasbeenconrmingledrvithotherpropertyt}ratcannolbedivicledu'ithottt

difficultY;

the defendant shall forf'eit to the united States any othcr property of the dcfendant, up to thc

value of the property describcd irbovc, pursuant to 2l U.S.C. S 853(p)'

(Criminal Forfeiture, pursuant to Title 49, United States Code, Section 46306(dXl),Title 28. United Sates code, Section 2461(c), and Title 2l , t.lnited States code, Section8s3(p))

A TRTJF] BILI-:

FORt]PERSON.