In an offer of proof filed by Assistant U.S. Attorney Michael T. Wolfe, the government stated it would have proved at trial the following:
A Federal Bureau of Investigation agent responded to a call from Blackfeet Law Enforcement dispatch in the early morning of March 17, 2011, reporting that a female individual had been assaulted by CROSSGUNS.
The agent went to the Blackfeet Community Hospital to see the victim and then spoke with the treating physician. The physician would have testified that the victim had extensive “systematic” bruising on her body, and bruising/swelling on her face and ear. He also would have testified that the blows to the victim’s face resulted in extreme physical pain and protracted and obvious disfigurement. A physical exam had revealed extensive bruising around her eyes; one eye completed filled with blood; lips swollen; bruises on her neck, arms, chest, and back; and her entire left ear was swollen full of fluid. Both her hands were swollen and bruised.
The victim stated that CROSSGUNS hit her seven or eight times in the face with his fists. CROSSGUNS also hit her in the head, neck, arms, hands, and back and threatened to break her arm.
CROSSGUNS faces possible penalties of 10 years in prison, a $250,000 fine and three years’ supervised release.
The investigation was conducted by the Federal Bureau of Investigation.
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