Case 1 :1 1 -cr-00067-TH "SEALED* Document 2 Filed 05/04/11 Paoe 1 of 18

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IN TI{E UNITED STATES DISTRICT COI'RT
FOR TFIE EASTERN DISTRICT OF TEXAS MAY C 4 2OII
BEAI,IMONT DTVISION
, MALAND. CLERK
UNITED STATES OF AMERICA u"oou,o
DEPUTY
J
vs. J CRIMINALNO. l:1l-CR- $ J
.CAI,'WNGARYWAIKER $
Iralg fieailf;eJy'
INDICTMENT

THE UNITED STATES GRAND JURYCHARGES:

Counts One - Three (Violation: 18 U.S.C. S134f

Mail Fraud; 18 U.S.C. S2
Aiding and Abetting)

From in or about September 2008, to in or about December 2010, in the Eastern

District of Texas and elsewhere, Calvin Gary Walkeq defendanl irnowingly devised and

intended to devise a scheme and artifice to defraud and to deceive the Beaumont lndependent

School District by the submission offalse and fraudulent invoices for electrical supplies and

materials never purchased or said invoices being inflated beyond the actual cost and

contracted mark-up by means offalse and fiaudulent pretenses and representations knowing

at the time that such preterses and representations would be and were false when made, said

scheme so devised and intended to be devised as follows:

Introduction

Calvin Gary Walker, defendan! doing business as Walker's Electric Company, was

chosen by the Beaumont Independent School District @ISD) through a competitive bidding
 Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 Page2of 18

process in August 2008 to exclusively provide electrical services to BISD which could not

be provided by the staff electricians. As part of the written contract with BiSD' the

defendant was to provide eiectrical supplies and materials at cost plw a tenpelcent mark-up.

Acklitionally, any use of subcontractors for an electrical project was aiso to be provided at

cost plus a ten percent mark-up. similarly, any rental equipment needed for an electrical

project was also to be provided at cost plus a ten percent mark-up. The contract between

BISD and Calvin Gary Walker, defendant, doing business as Walker's Ele.ctric Company,

was renewed in 2009 for an additional year by the BISD board of trustees and was again

awarded to the defendant and his company by competitive bid in 2010 under the same
terms

and conditions-

The Scheme

calvin Gary walker, defendant, doing busiaess as walker's Electric company,

would submit invoices to BISD for costs of materials, supplies, and subcontractor services

which were routinely false and fraudulent in that the cost arnounts were inflated far beyond

the actual costs incurred by defendant. Such Walker's Electric Company invoices to BISD

for payment were sometimes accompanied by suppiier invoices for materials which were

altered or fabricated to reflect amolnts larger than the actual costs ofmaterials, supplies, and

subcontractor services. As a further part of said scheme to obtain payments from BISD on

the invoices submitted to BISD for supplies and materials, Calvin Gary Walkel defendant

would also attach wa.lkey's Electric Company checks made payable to various suppliers in
 Case 1:'11-cr-00067-TH -SEALED* Document 2 Filed 05/04/1 1 Page 3 of 18

the inflated amounts which were never actually pfesented to or negotiated by such suppliers,

Aware ofthe intentionai misrepresentations in the documentation submitted to BISD, Calvin

Gary Walker, defendant, also fraudulently invoiced an inflated ten percent mark-up based

upon the fraudulent material and supply costs.

In addition to the above false and fraudulent submissions to BISD, Calvin Gary

Walker, defendant, also fraudulently invoiced charges for bucket tuck lentals and the

related ten percent mark-up when, in fact, as the defendant well kneq he owned said bucket

truck equipment, and did not incur any rental costs.

As a result of said scheme and artifice to defraud, calvin Gary walker, defendant,

received approximately $3,700,000 or more in firnds from BISD in excess ofthe actual
costs

incurred and the related ten percent mark-up, causing a loss to BISD of the same anount.

on or about the dates listed below, in the Eastem District of Texas and elsewhere,

Calvin Gary Walker, defendant, aided and abetted by others known and unknown to the

gand jury, for the puryose of executing the aforesaid scheme and altifice, did knowingly

cause to be delivered by the United States Postal Service or by commercial interstate carrier

according to the directions thereon, a letter conlaining a checig for the amount listed below,

as a payment for materials or supplies not provided to BISD, addressed to walker's Electric

Co., 3710 Roland Road, Beaumont, TX 77708'

 Case 1 :1 1-cr-00067-TH .SEALED" Document 2 Filed 05/04/11 Page 4 of 18

Count Date of Mailing Amount of Check BISD Amount of False

Project Material Costs

May 1,2009 $ 82,700.00 Ozen HS SoftbalV $ 647,000

Baseball Lighting

2 April 30,2010 $ 79,385.0i SmithMiddle $ 18,000

School repairs

It:Jy 22,2010 $1s7,674.68 Amelia/Caldwood $87,000

Portable Buildings

All in violation of 18 U.S.C. $$ 1341 and 2.

Counts Four- Nine (Violation: f8 U.S.C. S1343

Wire Fraud; 18 U.S'C. 52
Aiding and Abetting)

The grandjury realleges the introduction and scheme and artifice described above in

the indictment in Counts One tlrough Three and incorporates the same by refelence.

on or about the below dates, in the Eastem Distict of Texas and elsewhere, calvin

Gary Walker, defendant, aided and abetted by others known and unknown to the grand jury,

for the pu4rose ofexecuting or attefiipting to execute the aforesaid scheme and artifice, did

knowingly cause to be transmitted in interstate and foreign commerce, by means of a wire

communication, certain signs, Signals, and sounds, narnely, electronic mailings or emails to

BISD of invoices containing inflated amounts for materials, supplies and subcontractor

services, and electronic tansmissions to other entities, as described below, which caused or

facilitated the payment of funds to defendant and his company:

 Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 Page 5of 18

Count Date Wire

Nature of BISD Amount of False
Transmission Project Materials Costs
February24,2009 Facsimile fiom Walker Ozen SoftbalV 5647,000
Electric to Goidleaf Baseball lighting
Financial, Ltd.

Febrmry 26,2009 Emails tolfrom Walker Ozen Softbaly $647,000

Electric toGoldleaf Baseball lighting
Financial, Ltd.

March20,2009 Electronic file transfer Ozen SoftbalV $647,000

by Summit Electric Baseball lighting
between Beawnont, Texas
and Albuquerque, New Mexico

Apil24,2009 Electronic file transfer Regina HowelV $ 1, I 83 ,000

by Summit Electric South Park campus
between Beaumont, Texas
and AJbuquerque, New Mexico

8 August 20,2009 transfer

Electronic file Regina HowelV $343,000
by Sunlnit Electric South Park campus
between Beaumont, Texas
and Albuquerque, New Mexico

November 30, 2010 Email of invoice ftom Soulh Park $ 85,000

Calvin Walker to BISD Stadium lighting

AIl in violation of 18 U.S.C. $$ 1343 and 2.

CountTen (Violation: 18 U.S.C. $2314

Interstate Transportation
ofFunds by Fraud)

On or about the lSth day of December, 2009, in the Eastem District of Texas and

elsewhere, Calvin Gary Walker, defendant, did cause to be transported and transfered in
 Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 Page6of 18

interstate cormerce fiom the State of Texas to the State ofNew York, money, in the form

ofa business check, No. 565676, in the amount of$138,596.70, by depositing the check into

an account maintained by the defendant at Capital One, N.A., knowing such check to have

been taken by fraud that being a scheme to inflate electrical maintenance invoices submitted

to the Beaumont Independent School District for paymen! inciuding an invoice for materials

used at Dunbar Elementary School, of which, as the defendant well knew, was false and

aaudulent in that the amount ofmaterials invoiced had been inflated beyond the conkactual

amount of cost plus ten percent maxk-up.

All in violation of 18 U.S.C. $ 23 14.

Counts Eleven -F ourteen (Violatiop: 18 U.S.C. $2314

Ilterstate Transportation
of Funds by Fraud)

On or about tle dates listed belo% in the Eastem District of Texas, Calvin Gary

Walker, defendant, did cause to be transported and transferred in interstate cofirnerce from

the State of Texas to the State oflouisiana, money, in the form of business checks ofa

value of$5,000 or more as listed below, by depositing the checks into an account maintained

by the defendant at Capi'ral One, N.A., knowing such checks to have been taken by fraud, that

being a scheme to inflate elecftical maintenance invoices submitted to the Beaumont

Independent School District for paym.en! which, as the defendant well knew, were false and

fraudulent in that the amount ofmaterials invoiced had been inflated beyond the contractual

amount of cost plus ten percent maxk-up,

 Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 PageTof 18

Count Date Check No. Amount BISD Project

li May 29,2009 557268 $ i,285,064'00 Regina/South Park

12 Ju1y30,2009 559382 $ 160,110.50 BinghamElementary

13 March5,2010 569M2 $ 119,051.02 FrenchElem'trailen

14 hily22,2010 575639 $ 157,674'68 Amelia/Caldwood

AII in violation of 18 U.S.C. $ 2314.

Counts Fifteen - Sixteen (Violation: 18 U.S'C' 5666

Fraud upon Programs
receiving federal fu nds)

On or about the dates listed below, in the Eastern Distriot of Texas' Calvin Gary

walker, defendant, being an agent ofthe Beaumont Independent School Distict, Beaumon!

January
Texas, a locai government or organization receiving in the one year period begiruring

obtain by fraud'
1, 2008, federal benefits in excess of $10,000, did steal, embeufe and

propedy worth at least $5,000 under the care, custody, and control of
the Beaumont

Independent Sohool District, in that the defendant submitted an invoice

fol the cost of

and fraudulently
materials for the repair of the following BISD facilities which was falsely

inllatedintheapproximateamountslistedbelow,anduponwhichthedefendantreceived

payment:

Count Date ofBISD Amount of Check BISD Amount of False

Check Project Material Costs
Invoiced

15 October 16,2008 S 5gg!757.26 MLK Middle School $ 91'000

hurricane rePairs
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16 October16,2008 5599,757.26 SmithMiddleSchool $167'000

hurricane rePairs

AII in violation of 18 U.S"C. $ 666(aXlXA).

Counts Seventeen-Twenty-four (Violation: 18 U.S.C. $666

Fraud upon Programs
receiving federal funds)

on or about the dates listed below, in the Eastem District of Texas, Calvin Gary

walker, defendang being an agent ofthe B eaumont Independent school

Distict, Beaumonq

Texas,alocalgovemmentororganizationreceivingintheoneyearperiodbegimingJanuary

zoag, federal benefrts in excess of $10,000, did steal, embezz|e and

obtain by ftaud'
L
property worth at least $5,000 urder the care, custody, and control of the Beaumont

Independent school District, in that the defendant submitted invoices

fol the cost ofmat€rials

or labor for the repair of the tbllowing BISD facilities which were
falsely and fraudulenfly

received
inflated in the approximate amounts listed below, and upon which the defendant

palment:

Count Date of BISD Amount of Check BISD Amount of False

Check Project Material (Labor)
Costs Invoiced

11 April 3,2009 $ I,153,300.00 Ozen HS SoftbalV $ 647,000

(initial PaYment) Baseball Lighting

18 April30,2009 $82,700.00 Ozen HS SoftbalV same as Count 17

(frnal payment) Baseball Lighting

i9 May 29,2009 $ 1,285,064.00 Regina Howell $ 588,000

temporary campus
 Case 1:11-cr-00067-TH.SEALED" Document2 Filed 05104111 Page I of 1B

20 May 29,2009 $1.285.064.00 SouthPark $ 594,000

temporary campus

JuIy30,2009 $ 160,110.50 Bingham-Blanchette $ 145,000

Elementary School

22 September 10, 2009 $ 1,592,839.10 Regina HowelV $ 343,000

South Park
rcmporar7 campuses

23 September 10,2009 $ 1,592,839.10 ReginaHowelV $ 83,200

SouthPark (labor)
temporary camPuses

24 December i 8. 2009 $ 138,596.70 Dunbar Elem. trailers $ 112,000

All in violation of 18 U.S.C. $ 666(a)(1XA).

Counts Twent!'-five - Thirtv (Violation: 18 U.S.C. $666

Fraud upon programs
receiving federal funds)

On or aboul the dates listed below, in the Eastem District of Texas, Calvin Gary

Walker, defendant, being an agent ofthe Beaumont Independent School District, Beaumon!

Texas, a local govemment or organization receiving inthe one year period beginning January

1,2010, federal benefits in excess of $10,000, did steal, embezzle and obtain by fraud,

property worth at least $5,000 under the care, custody, and control of the Beaumont

Independent School District, in that the defendant submitted invoices for the cost ofmaterials

for the repair of the following BISD facilities which were falsely and fraudulently inflated

in the approximate amounts listed below, and upon which the defendant received payment:
 Case 1:1't-cr-00067-TH
-SEALED* Document2 Filed 05/04/1 1 Page 10 of 18

Count BISD
Date of Amount of Check BISD Amount of False
. Check Project Material Costs

25 March5,2010 $ 119,051.02 FrenchElementarv $27'000

temP. classrooms

26 Api129,2010 $ 79,385.01 SmithMddle $ 18'000

School repairs

27 1u1y22,2010 $157,674.68 SouthParkstadium $ 20'000

28 luly 22;2010 8 157,674.68 Amelia/Caldwood $ 87,000
Portable Buildings

29 October2l,2010 $164,435.40 Installgeneratorat $ 35,000

BISD Administration

30 December 3, 2010 $ 499,000.00 South Park M.S. $ 85,000

stadium lights
.
All in violation of 18 U.S.C. $ 666(aX1)(A).

Count Thirtv-one (Violation: 18 U.S.C. S666

' Fraud upon programs
receivin g federal funds)

On or about the 16th day of October, 2008, in the Eastern District of Texas' CaMn

Gary Walker, defendant, being an agent of the Beairmont Independent School District,

Beaumont, Texas, a local govemment or organization ieceiving in the one year period

beginning January 1,2008, federal benefits in excess of$10,000, did steal, embezzle and

obtain by fraud, property worth at least $5,000 under the care, custody, and control of the

Beaumont Independent School Distric! in that the defendant submitted two invoices for the

cost of bucket truck rentals of $1 12,000 for the repair of Smith Middle School and King

10
 Case 1:1 1-cr-00067-TH .SEALED* Document2 Filed 05/04/11 Page11of1B

Mddle School which was false and fraudulent in that the defendant did not rent said

equipment or invoice the equipment at cost, and upon which the defendant received payment

in that aurount.

All in violation of 18 U.S.C. $ 666(aXl)(A).

Count Thirty-two (Violation: 18 U.S.C. 5666

Fraud upon programs
receiving federal funds)

On or about the 10th day of September, 2009, in the Eastern District of Texas, Calvin

Gary Walker, defendant, being an agent of the Beaumont lndependent School District,

Beaumont, Texas, a local govemment or organization receiving in the one year period

beginning January i, 2009, federal benefits in excess of $10,000, did steal, embezzle and

obtain by fraud, property worth at least $5,000 under the care, custody, and control of the

Beaumont Independent School District, in that the defendaot submitted an invoj.ce for the

cost of bucket truck rentals of $546,000 for the electical s]'sterr construction of Regina

Howell and South Park temporaxy campuses which was false and fraudulent in that the

defendant did not rent said equipment or invoice the equipment at cost, and upon which the

defendant received payment in that amount.

All in violation of 18 U.S.C. $ 666(aX1XA).

CountThirty-three (Violation: 18 U.S.C. $1957

Money Laundering)

On or about the 1 lth day of Septemb er, 2009, in the Eastem District of Texas and

elsewhere, Calvin Gary Walker, defendant, did klowingly engage and attempt to engage
 Case 1:1'1-cr-00067-TH -SEALED* Document2 Filed 05/04/11 Page 12 of 1B

in a monetary transaotion in criminally derived property ofa value greater than $ 10,000 and

which was derived from a specified unlawful activity, that monetary transaction being the

negotiation of a check ftom the Beaumont lndependent School District in the amount of

51,592,839.10 by the defendant into the J.P. Morgan Chase Banlg which said monetary

transaction involved the proceeds of specified unlawful activily, that is, wire fraud as

described in Count 8 of this indictuent ani the theft of fimds as described in Coimts 22, 23

and 32 ofthis indictnent which is adopted herein, conduct puoishable under the laws ofthe

United States.

All in violation of 18 U.S.C. $ 1957(a).

Count Thirtv-four {Violation: 18 U.S.C. 51957

Money Laundering)

On or about the 8th day of September, 2009, in the Eastem District of Texas and

elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage

in a monetary transaction in criminally derived property of a value greater than $ 10,000 and

which was derived from a specified unlawfui activity, that monetary hansaction being the

purchase of a 2010 Mercedes S5F, 4 door, VIN WDDNG7BB0AA28863 1, in the amount of

$117,000, which said monetary transaction involved the proceeds of specified unlawful

activity, that is, the theft of fu:rds described in Counts 7,4,5,6,7,11 - 12, and 15 - 21 ofthis

indictuent which is adopted herein, conduct punishable under the laws of the United States.

All in violation of 18 U-S.C. $ 1957(a).

12
 Case 1:11-cr-00067-TH"SEALED* Document2 Filed 05104111 Paqe 13of 1B

CountThirty-five (Violation: 18 U.S.C. $1957

Money Laundering)

On or about the 27st day of September, 2009, in the Eastern District of Texas and

elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage

in a monetary transaction in criminally derived property ofa value greater than $ 10,000 and

which was derived ftom a specified unlawful activif, that monetary transaction being the

purchase ofa Transamerica Preferred Choice Fixed Annuity Contract 02TPC047 479 for the

amount of$1,600,000 by the defendant using fimds from the JP Morgan savings account

nurnber *****+7080 of defendant which said monetary ftansaction involved the proceeds

of specifred unlawful activity, that is, the theft of funds described in Counts I,4, 5,6,7,8,

11 - 12,15 - 23, and 32 of this indictnent which are adopted herein, conduct punishable

under the laws of the United States.

Al1 in violation of i8 U.S.C. $ i957(a).

Count Thir8-six (Violation: 18 U.S.C. $1957

Money Laundering)

On or about the 7th day of Octobet,2009, in the Eastem District of Texas, Calvin

Gai-y Walker, defendant, did knowingly engage and attempt to engage in a monetary

transaction in criminally derived property of a value greater than $10,000 and which was

derived from a specified unlawfr{ activity, that monetary transaction being the purchase of

a uact of land for $175,000 on Pleasure Island, Port Arthur, Texas, described as Tract 31A.'

Lafitte's Landing, which said monetary transaction involved the proceeds of specified

1J
 Case 1:11-cr-00067-TH.SEALED* Document 2 Filed 05104111 Page 14 of 18

unlawful activity, tlat is, the theft of funds as described in Counts l,4,5,6,7,11 - 12,and

15 - 21 of this indictment which is adopted herein, conduct punishable under the laws ofthe

United States.

All in violation of 18 U.S.C. $ i957(a).

Connt Thirtv-seven (Violation: 18 U.S.C. 51957

Money Laundering)

On or about the 28th day of October, 2009, n the Eastem District of Texas and

elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage

in a monetary transaction in criminally derived property of a value greater than $ 10,000 and

which was derived from a specified uniawfill activity, tlat monetary transaction being the

purchase ofa Transarnerica Preferred Choice Fixed A:rnuity Contxact 02TPC080685 for the

amount of $1,800,000 by the defendant using frrnds ftorn the JP Morgan savings account

number *****{'7080 of defendang which said monetary transaction involved the proceeds

of specified unlawfirl activity, that is, the theft of fiuds described in Counts 1, 4 through 8,

11 - 12, 15 - 23, ard 32 ofthis indicfinent which is adopted herein, conduct punishable under

the laws of the United States.

All in violation of 18 U.S.C. $ 1957(a).

NOTICE OF INTENTION TO SEEK CRIMINAI FORFETTURES

As a result of committing one or more of the offerses alleged in Counts 1 - 37 of the

indictnent Calvin Gary Walker, defendan! did use or intend to use personal property to

commit said offenses and shall forfeit to the United States such property pursuant to 18

14
 Case 1:11-cr-00067-TH .SEALED* Document 2 Filed 05/04/11 Page 15 of 18

U.S.C. $981(a)(lXC), $ 982 (aXa), and28 U.S.C. $ 2461(c), includingbutnotlimitedtothe

following:

1. Personal Property

a. MONEY JIIDGMENT, being asum ofmoney equal to $3,700,000.00 in United States

currency rqxesenting the amount of proceeds obtained as a result of the above fraud
offenses, in violation of I 8 U.S.C. $ $ 666, 1341, 1343, 2314, and 1957.

b. The following assets or funds representing proceeds obtained as a result ofthe above
fraud offenses, in vioiation of 18 U.S.C. $$ 666, 1341, 1343,2314, and 1957:

A Trarsarnericd Preferred Choice Fixed Annuity Contract 02TPC 047 47 9, pwchned

for $1,600,000 on or about September 21, 2009, using funds from the JP Morgan
savings account number ***!k**7080 of Calvin Walker;

A TransamericaPrefened Choice Fixed Amuity Contract 02TPC080685 purchased

for $1,800,000 on or about October 28,2009, using frnds from the JP Morgan
savings account numbef, *x**'r*7080 of Calvin Walker;

A 2010 Mercedes S5F, 4 door, \IIN WDDNG7Bts0AA288631, purchased on or

about September 8,2009, fromMercedesBenz ofHouston, Greenway, inthe amormt
of $1 17,000;

Tbree BISD checks in the amounts of $9,743.86, $1O,325.34, nd$499,000, andthe

funds they represent, seized from the defendant on or about December 7 ,2010.

2. Real Property

A parcel of land purchased on or about Octo ber'7,2009 described as Tract 31A of

a Replat of Lots numbered Thirty-one and Thirty-two (3 1 &32) ofLafitte's Landing
Phase Two, a 106.97 acre subdivision out of and a part of the N. Coleman Survey A-
12 and the Dennis Gahagan League, Abstract No. 123, in the City of Port Arthur,
Jefferson County, Texas, as the same appears upon the map or plat thereof, on file and
of record in Vo1.16 page 309 Map Records of Jefferson Cotmty, Texas;

3, Substitute Assets

If as a result of any act or omission by defendan! any of the property described

15
 Case 1 :1 1 -cr-00067-TH -SEALED" Document 2 Filed 05/04/11 Page 16 of 18

above:

(a) cannot be located upon the exercise of due diligence;

(b) has been transferred or sold tq or deposited with, a third party;
(c) has been piaced beyond the jurisdiction of the court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be divided without
difficulty;

it is the intent ofthe United States, pursuant to Title 2 I , United States Code, Section 853 (p),

incorporated by reference by 18 U.S.C. $981(aX1XC) and $ 982 (a)(a), and 28 U.S'C' $

Zail@),to seek forfeiture of any other property of defendant up to the value ofthe above

forfeitabie properly, including but not linited to all properfy, both real and personal owned

by defendant.

By virnre of the commission of the aforementioned offenses charged in this

Indictnent by the defendan! any and ail interest the defendant has in the above-described

property is vested in the United States and hereby forfeited to the United States for its use or

for any other disposition in iG discretion pursuant to 18 U.S.C. $981(aX1XC) and $ 982

(a)(4), and 28 U.S.C. $ 2461(c).

'RAND J['RY FOREPERSON

JOHNM. BALES
UNITED-STATES ATTORNEY

ASSISTANT I'NITED STATES ATTORNEY

-to
 Case 1:11-cr-00067-TH -SEALED- Document 2 Filed 05104111 Paqe 17 of 1B

IN TTM UNITED STATES DISTRICT COI'RT

FOR THE EASTERN DISTRICT OF TEXAS
BEAI'MONT DTVISION

LINITED STATES OF AMERICA 6

$
VS. t CRIMINAINO. t:11-CR-
!
CALVINGARY\MAIKER O

NOTICE OFPENALTY

Counts One - Three

Violation: 18 U.S.C. $ 1341 (Mail Fraud); 18 U.S.C. $2 (Aiding andAbetting

an Offlense)

Penait: Not more than twenty (20) years imprisonment; a fine of not more
than $250,000, or both. A terrn of supervised release of not more
than five (5) years.

Soeciai Assessment: $100

Counts Four - Nine

Violation: 18 U.S.C. g 1343 (\Mire Fraud); 18 U.S.C. g 2 (Aiding and Abetting

an Offense)

Penalty: Not more than twenty (20) years imprisonment; a flne of not more
than $250,000, or both. A term of supervised release of not more
than five (5) years.

Special Assessment: $100.00

Counts Ten - Fourteen

Violation: 18 U.S.C. $ 2314 (nterstate Transportation of Money by Fraud)

Penaltv: Imprisonment of not more than ten (10) years, a fine not to exceed
$250,000.00, or both. A term of supervised release ofnot more tha:r tbree (3)
years rnay be imposed.

17
Case 1:11-cr-00067-TH "SEALED" Document2 Filed 05104111 Page lBof 18

Snecial Assessment: $100.00 for each count.

Counts Fifteen - Thirtv-two

Violation: 18 U.S.C. $ 666(a)(1)(A) (Fraud upon Programs receiving federal

funds)

Penalty: Imprisonment of not more than ten (10) years, a fine not to exceed
$250,000, or both; a temr of supewised release of not more than tl'lree
(3) years.

Special Assessment: $ I00.00

Counts Thirty-three - Thirtv-seven

Violation: 18 U.S.C. $ 1957 (vloney Larmdering Transactions Greater

than $10,000)

Penalty: Not more than ten (10) yean imprisonment; a fine of not more than
$250,000 or twice the value ofthe criminally derived property, or both;
a term of supervised release ofnot more lhan tlree (3) years'

Soeciai Assessment: $100.00

i8