Case 3:12-cv-00893-D Document
11-1
Filed
05/31/1.2
Page 1 of 55 PageiD
60
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VERIFICATION
AFFIDAVIT
U.S. DISTRICT COURT
. . 1 ·
f
I .
·
:hfO.RTiffiRN
DISTRICT
OF
TEXAS
I, Donald B. Sherman, Special Agent
of
the Federa Bureau o
n T . e s t i ~ a r r o n : ; -
FILED · .
Dallas, Texas, being duly sworn, states the following:
MAR
2 6
2012
BACKGROUND
CLERK.
U.S.
D~COURT
I have been employed as a Special Agent
of
the Federal B reau
8f
Deputy
Investigation (FBI) for twenty years. I have been assigned to the Dallas
Divir;s.;.;io..;;;n
_______
all
ofthat
time. I have participated
in
all
ofthe
normal methods ofinvestigincluding, but not limited to the use
of
electronic surveillance, visual surveilinterviews ofwitnesses, search warrants, confidential informants, pen regist
wire
taps, and undercover agents. I have personally directed and participateinvestigations
of
violations
of
Title 18, United States Code, Sections 1956 a d1957, Laundering
of
Monetary Instruments and Engaging in MonetaryTransactions in Property Derived from Specified Unlawful Activity; violations
of
Title 18, United States Code, Section 152, Concealment
of
Assets in Bankruptcy;violations
of
Title 18, United States Code, Section 201, Bribery
of
Public Officials
and
Witnesses; Title 18, United States Code, Section 666, Theft or BriberyConcerning
Progr(!.ms
Receiving Federal
FU:nds;
Title 18, United States Code,Section
19
51,
Interference with Commerce by Threats. or Violence; Title 18,
United
States Code, Section 371, Conspiracy to Commit Offenses or to Defraud
United
States; and Title 18, United States Code, Section 2, Aiding and Abetting. This affidavit is submitted for the limited purpose
of
supporting andverifying a Complaint for Forfeiture
of
$229,590.00
in
United States currency
Certified a
true
copy
ofan
instrumenton file
in
my
office
on
~ -
2-le
-11
·
Clerk, U.S. District
Court,
Northern
i•
trict of Texas
.·
By
Depu~
Case 3:12-cv-00893-D
Document
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05/31/12
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seized
from a safe in the home
of
Dallas County Commissioner John Wiley Price.Therefore, I have not included each and every fact known to
me
concerning thisinvestigation, all individuals and entities involved, or all potential charges which
may be
considered based upon all known facts. Instead, I have set forth only thosefacts, charges, and individuals and entities which I believe are necessary to supporta
reasonable belief
that the $229,590.00 in United States currency
is
property
"involvedin"
a Conspiracy
to
Commit Money Laundering and a Conspiracy
to
Engage
in Monetary Transactions in Property Derived from Specified Unlawful
Activity
under
18
U.S.C. § 1957 in violation
of
18
U.S.C.
§
1956(h) and therefore
subject
to forfeiture pursuant to
18
U.S.C.
§
981(a)(l)(A) as well as a Conspiracyto violate 18 U.S.C. § 152 [Bankruptcy Fraud] and a Conspiracy
to
violate
18
U.S.C.
§
666
[Theft or Bribery Concerning Programs Receiving Federal Funds]
which makes
the property subject to forfeiture pursuant
to
18
U.S.C. §
98l(a)(l)(C).
I
make
this verification for
and.
on
behalf
of
the United States
of
America.
The
statements contained in this Affidavit are based, in part, on information
provided by
other Special Agents
of
the
FBI
and the Internal Revenue Service -
Criminal
Investigative Division (IRS-CID). The statements are also based on my
experienceand
training as a Special Agent and information obtained through theexecution
of
search warrants,
the
analysis
of
bank records, the examination
of
public records, examination
of
e-mail records, physical surveillance, witnessinterviews,
the
analysis
of
toll records,
pen
registers, and other sources that will
2
Case 3:12-cv-00893-D
Document
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not
be disclosed at this time to protect the ongoing criminal investigation. I haveread the Complaint for Forfeiture and the factual matters
in
it are true and correctto the best
of
my knowledge, information, and belief.
FACTS SUPPORTING
FORFEITURE
The Seizure
1.
On
June 27, 2011 at approximately 9 a.m., FBI agents executed a searchwarrant at
510
E.
5th
Street in Dallas County, Dallas, Texas which is theprimary residence
of
John Wiley Price
who
is the sole resident there.2. Within the house, agents located a safe containing $229,590 inUnitedStates currency along with jewelry and numerous expensive watches withbrands such as Jacob & Co., Icelink, Breitling, Marc Jacobs, Versace,Chanel, Corum Boutique, Cartier, Rolex, Technolex, Glashutte, PhilipStein, Le Vian, and Joe Rodeo.3.
Both
the cash
and
the watches were seized as evidence and the cash wasreferred for administrative forfeiture proceedings.
Administrative Forfeiture
4.
The
FBI initiated administrative forfeiture proceedings against the$229,590.00 in United States currency seized from a safe in the
home
of
Dallas County Commissioner John Wiley Price.
3
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John Wiley Price Affidavit Pt. I
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