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John Wiley Price Affidavit Pt. II

John Wiley Price Affidavit Pt. II

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Published by: The Dallas Morning News on May 31, 2012
Copyright:Attribution Non-commercial

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05/31/2012

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Case 3:12-cv-00893-D Document 11-2 Filed 05/29/12 Page 1 of
62
PageiD 115
~DALT~
~~
f2vv5~3
FIRST AMENDED VERIFICATION AFFIDAVIT
'r----"·r-:'-;
DISTRICT COURT
I,
Donald
B.
Sherman, Special Agent
of
the Federal Bureau
ofinyestigc:t>ti~RN
DISTRTCTOFTEXAS
. FILED
Dallas, Texas, being duly sworn, state the following:
BACKGROUND
'~
2 9
2012
1
CLERK, 4-S..:..DISTRICTCOUR'l'
I have been employed
as
a Special Agent
ofthe
Federal Bureau
~-...:YIL~----
Deputy
Investigation (FBI) for twenty years. I have been assigned to the Dallas Divisionall
of
that time. I have participated in all
of
the normal methods
of
investigation,including, but not limited to, the use
of
electronic surveillance, visual surveillance,interviews
of
witnesses, search warrants, confidential informants, pen registers,wire taps, and undercover agents. I have personally directed and participated ininvestigations
of
violations
of
Title
18,
United States Code, Sections 1956 and1957, 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[hereafter "Bankruptcy Fraud"]; violations
of
Title
18,
United States Code,Section 20
1,
Bribery
of
Public Officials and Witnesses; Title
18,
United StatesCode, Section 666, Theft or Bribery Concerning Programs Receiving FederalFunds; Title
18,
United States Code, Section 1951, Interference with Commerceby Threats or Violence; Title
18,
United States Code, Section 3 71, Conspiracy toCommit Offenses or to Defraud United States; and Title
18,
United States Code,Section 2, Aiding and Abetting.
.'.;'
 
Case 3:12-cv-00893-D
Document
11-2
Filed
05/29/12
Page
2
of 62
PageiD
116
This affidavit is submitted for the limited purpose
of
supporting andverifying a First Amended Complaint for Forfeiture
of
$229,590.00 in UnitedStates currency seized from a safe in the home
of
Dallas County CommissionerJohn Wiley Price and $230,763.47 from the sale
of7001
Grady Niblo Road,Dallas Texas by Price. Therefore, I have not included each and every fact knownto me concerning this investigation, all individuals and entities involved,
or
allpotential charges which may be considered based upon all known facts. Instead, Ihave set forth only those facts, charges, and individuals and entities which Ibelieve are necessary to support a reasonable
belief
that the $229,590.00 in UnitedStates currency from Commissioner
Price's
safe in his residence and the$230,763.47 from his sale
of7001
Grady Niblo Road is property "involved in" aConspiracy to Launder Monetary Instruments ("Money Laundering") and aConspiracy to Engage in Monetary Transactions in Property Derived fromSpecified Unlawful Activity under
18
U.S.C.
§§
1956 and 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 Conspiracy to violate
18
U.S.C. § 152 [BankruptcyFraud] and a Conspiracy to violate
18
U.S.C. § 666 [Theft or Bribery ConcerningPrograms Receiving Federal Funds] which makes the property subject to forfeiturepursuant 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 informationprovided by other Special Agents
of
the FBI and the Internal Revenue Service -
2
 
Case 3:12-cv-00893-D Document 11-2 Filed 05/29/12 Page 3 of
62
PageiD 117
Criminal Investigative Division (IRS-CID). The statements are also based on myexperience and 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 willnot be disclosed at this time to protect the ongoing criminal investigation. I haveread the First Amended Complaint for Forfeiture and the factual matters in it aretrue and correct to the best
of
my knowledge, information, and belief.
FACTS SUPPORTING
FORFEITURE
The Seizure
of
the $229,590.00
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.
2.
510
E.
5th
Street in Dallas County, Dallas, Texas
is
the primary residence
of
John Wiley Price who is the sole resident there.3. Within the house, agents located a safe containing
$229,590.00
in UnitedStates currency.4. The safe also contained 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.
5.
Both the cash and the watches were seized
as
evidence and the cash wasreferred for administrative forfeiture proceedings.
3

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