P. 1
DurkeeInformation_0327201219063400 (1)

DurkeeInformation_0327201219063400 (1)

|Views: 12,474|Likes:
Published by tvanoot

More info:

Published by: tvanoot on Mar 28, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

03/28/2012

pdf

text

original

1 2 3 4

5 6
7

BENJAMIN B. WAGNER United States Attorney JOHN K. VINCENT PHILIP A. FERRARI Assistant U.S. Attorneys 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2700

ORIGINAL
FILED
MAR Z 7 2012
CLERK, U.S. DISTRICT COURT EASTERN DISTRICTOF CALIFORNIA
DEPUTY CLERK

~------~~~~-------

8 9

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
1.

2= 1 2 - CR - 1 2 3
UNITED STATES OF AMERICA, Plaintiff,
v.

CASE NO. VIOLATIONS: 18 U.S.C. Mail Fraud (5 counts)
§

1341 -

KINDE DURKEE, Defendant.

1. N E Q R M 8: 1: 1. Q N COUNTS ONE THROUGH FIVE: [18 U.S.C.

s

1341 - Mail Fraud]

The United States Attorney charges: KINDE DURKEE, defendant herein, as follows: I. Introduction The State of California Fair Political Practices Commission At all

(FPPC) was formed by the Political Reform Act of 1974.

relevant times, the FPPC regulated campaign financing and spending in state political races, developed forms which certain candidates and officeholders in the State of California were required to file,
1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

prepared manuals and instructions, and investigated alleged violations of the Political Reform Act. 2. The Federal Election Commission (FEC) was formed by At all relevant times, the FEC was an independent Its duties included to disclose publicly finance

Congress in 1975. regulatory agency.

information for federal officeholders and candidates, and to enforce the provisions of the law such as the limits and prohibitions on contributions. 3. KINDE DURKEE registered Durkee & Associates as a DBA with

the California Secretary of State on April 19, 2000. 4. KINDE DURKEE registered Durkee & Associates as a domestic

limited liability corporation (LLC) with the California Secretary of State on September 22, 2003. KINDE DURKEE was listed in that filing
&

as a "Member/Manager/Partner" of Durkee 5.

Associates.

At all relevant times, Durkee & Associates and KINDE DURKEE

specialized in providing accounting and campaign reporting services to political committees for state or federal offices, including political candidate campaign committees and non-profit organizations. These services included: - maintaining financial records of, and for, the committees or organizations i - keeping track of the contributions to, and expenditures by, the committees or organizations; and - filing necessary FPPC forms with the California Secretary of State in Sacramento, or the necessary forms with the (FEC), which reported, among other things, contributions, contributors, expenditures, and the overall financial condition of the candidate campaign committees or the organizations for whom a filing was
2

1 2
3 4 5 6 7 8 9

required.
6.

At all relevant times, KINDE DURKEE frequently served as

the committee treasurer for the committees for which services were provided. As such, she signed the campaign disclosure forms for

state officials and organizations which were submitted to the California Secretary of State in Sacramento as required by state law. KINDE DURKEE prepared and submitted, and caused the preparation and submission of, campaign disclosure forms for federal officials to the FEC. 7. At all relevant times, KINDE DURKEE often acted as the

10 11 12
13 14 15

custodian of records for the financial records of those clients who held federal office. As such, she maintained records for all

contribution to the campaign committee, as well as the committee's disbursements. 8. At all relevant times, KINDE DURKEE and Durkee & Associates These accounts included

16 17 18 19 20 21 22 23 24 25 26 27 28

maintained bank accounts for their clients.

ones into which campaign contributions were deposited and from which client expenditures were made. KINDE DURKEE, either alone or with

another employee of Durkee & Associates, was a signatory on the bank accounts. Over the years, KINDE DURKEE has had signature authority

on approximately 700 bank accounts, including those for political campaigns. 9. At all relevant times, KINDE DURKEE was paid for the KINDE DURKEE was required to specify how much she

services rendered.

was paid in filings made to the California Secretary of State or the FEC. 10. At all relevant times, Durkee & Associates had employees

that assisted in providing the accounting and campaign reporting
3

1 2 3
4 5

services. 11. At all relevant times, KINDE DURKEE operated Durkee &

Associates and exercised control over the activities of its employees. II. The Scheme to Defraud 12. From in or about January 2000 to in or about September

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

2011, in the State and Eastern District of California and elsewhere, KINDE DURKEE did devise and intend to devise and participate in a material scheme and artifice to defraud clients of Durkee & Associates, and to obtain money from them by means of materially false and fraudulent pretenses, representations, and promises. III. Manner and Means To further the scheme and artifice to defraud, defendant KINDE DURKEE did the following over the years: 13. KINDE DURKEE routinely misappropriated client funds by

moving without authorization substantial sums of money out of client accounts, including political campaign accounts, into Durkee & Associates' or into other clients' accounts. 14 .. KINDE DURKEE submitted and caused to be submitted false information to the California Secretary of State and the FEC in that she did not report these money transfers in and out of ~ccounts on the reports that she submitted or caused to be submitted to the California Secretary of State in Sacramento or the FEC on behalf of her clients. As a result, many of her clients believed that their

campaign accounts had more money in there than they actually held. 15. accounts: - to pay her personal expenses, including mortgage payments
4

KINDE DURKEE used the money transferred from client

1 2 3 4
5

and American

Express

charges; expenses, including payroll; and

- to pay business

- to repay unauthorized accounts. A. 16. Jerome Horton

withdrawals

from other client

6 7 8
9

At all relevant committee Horton. December

timrs, KINDE DURKEE

was the treasurer

of

the campaign Member Jerome

for California

State Board of Equalization

17. without account

Between

2006 and April

2008, KINDE DURKEE paid campaign's bank were

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

authorization to Durkee

over $200,000

from the Horton

& Associates.
on the Horton

Almost

none of these payments disclosure

accurately

reported

campaign

forms that

KINDE DURKEE Secretary 18. DURKEE

filed and caused to be filed with the California

of State. Between approximately September 2007 and March 2010, KINDE bank on the

repaid

approximately

$90,000

to the Horton were accurately

campaign reported

account. Horton

None of these repayments disclosure

campaign

forms that KINDE DDRKEE Secretary of State.

filed and caused

to be filed with the California 19. In approximately

June 2010, when KINDE DURKEE

was aware with the that

that she was under Horton campaign

investigation

by the FPPC in connection

filings,

she repaid at least some of the money from the Horton account federal campaign $30,000

she had misappropriated money

by misappropriating approximately to Re-

from three different from Feinstein Sanchez;

accounts:

$25,000

for Senate; and $15,000

from the Committee

elect Loretta

from the Committee

to Re-elect

Linda Sanche z . 20. None of the foregoing transfers
5

from federal

campaigns

was

1 2 3 4 5 6 7 8
9

reported

by KINDE DURKEE

in the federal disclosure

forms that she of those clients. the repayment of to

filed and caused In addition, money

to be filed with the FEC on behalf did not accurately disclosure report

KINDE DURKEE Horton's

in Jerome

form that she filed and caused of State.

be filed with the California B. 21. Senator 22. records campaign Feinstein

Secretary

for Senate times, Dianne Feinstein was a United States

At all relevant

for the State of California. At all relevant for the financial committee. times, KINDE DURKEE records was the custodian Feinstein's for all of

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

of Senator Dianne records

As such, she maintained committee,

contributions disbursements. 23. maintained committee. contributions made. 24.

to the campaign

as well as the committee's

At all relevant bank accounts

times, KINDE DURKEE. and Durkee .for Senator Dianne included Feinstein's

&

Associates

campaign

These accounts

ones into which

campaign expenditures were

were deposited

and from which client

At all relevant

times, KINDE DURKEE

filed and caused Dianne

the

filing of the necessary Feinstein's 1. 25. without campaign

disclosure

forms for Senator

committee

with the FEC. of $18,000 caused,

The Misappropriation

On approximately

March 2, 2010, KINDE DURKEE of three checks, for Senate,

authorization,

the deposit Feinstein

~ach for $6,000 into a

on the account Durkee

of Dianne

to be deposited

& Associates'

bank account. covered other personal covered and business payment of

26. expenses

The $18,000 deposit of KINDE DURKEE.

The deposit
6

a mortgage

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

$2,596.39 for KINDE DURKEE's residence in Long Beach, CA; a payment of $3,168.11 to Sprint; and a $10,000 payment for "payroll," which covered payments to, among other things, Durkee & Associates' employees and a 401k plan. 2. 27. The Misappropriation of $40,000

On approximately May 6, 2010, KINDE DURKEE caused, without

authorization, the deposit of two checks, each for $20,000 on the account of Dianne Feinstein for Senate, to be deposited into a Durkee & Associates' bank account. 28. The deposit eventually covered a mortgage payment of $3,400

for KINDE DURKEE's condominium in Long Beach, CAi a payment of $6,633 to Anthem Blue Crossi a payment of $1,038 to Kaiser Permanente; a payment of $1,613 to a self-storage companYi payments to two employees of Durkee
&

Associates i and a $12,-000payment for

"payroll," which covered, among other things, payments for bank fees and payments to several employees of Durkee & Associates. 3. 29. The Misappropriation of $23,000

On approximately July 7, 2010, KINDE DURKEE caused, without

authorization, the deposit of two checks, one for $8,000 and the other for $15,000, each on the account of Dianne Feinstein for Senate, to be deposited into a Durkee & Associates' bank account. 30. The deposit eventually helped to pay a $30,000 bill to The bill included

American Express on approximately July 7, 2010.

charges to a variety of entities, including the Los Angeles Dodgersi Union 76; Amazon.com.; Turners Outdoorsmani Harbor Freight Tools; Disneylandi and Trader Joe's. 4. 31. The Misappropriation of $75,000

On approximately July 19, 2010, KINDE DURKEE caused,
7

1 2 3
4

without

authorization,

the deposit Feinstein

of three checks, for Senate,

each for $25,000 into a

on the account Durkee

of Dianne

to be deposited

& Associates'
The deposit

bank account. covered a mortgage in Burbank, payment of $5,500 for Durkee of $2,555.53

32.

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

& Associates'
to a credit Associates' 33.

office building card companYi employees,

CAi a payment

and multiple

payments

to Durkee

&

as well as a payroll transfers

company. Feinstein were

None of the foregoing to a Durkee disclosure

from the Dianne bank account

for Senate account reported on federal

& Associates'

forms for that campaign

committee

which KINDE DURKEE C. 34. united Committee

filed and caused to be filed with the FEC. to Re-elect Loretta Sanchez Sanchez was a member of the of

At all relevant Congress

times, Loretta

States

representing

the 47th congressional

District

California. 35. At all relevant committee times, KINDE DURKEE entitled Committee acted as the treasurer to Re-elect Loretta

of the campaign Sanchez. 36. without account

On approximately

March

5, 2010, KINDE DURKEE ofa

caused,

authorization,

the deposit

check for $10,000 on the Sanchez to be deposited

of the Committee

to Re-elect

Loretta

into a Durkee 37. Cross. 38. Sanchez federal DURKEE

& Associates'

bank account. of $7,476 to Anthem Blue

The deposit

covered a payment

The $10,000 transfer

from the Committee bank account

to Re-elect

Loretta on

to a Durkee disclosure

& Associates'

was not reported which KINDE

forms for that campaign

committee

filed and caused

to be filed with the FEe.
8

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

D. 39.

Feinstein for Senate/Committee to Re-elect Loretta Sanchez On approximately April 20, 2010, KINDE DURKEE caused,

without authorization, the deposit of two checks, each for $15,000, one on the account of Dianne Feinstein for Senate and the other on the account of the Committee to Re-elect Loretta Sanchez, to be deposited into a Durkee & Associates' bank account. 40. The two deposits covered a number of checks, including ones

to Chase Card Services, one to cover the fees for KINDE DURKEE's mother at a senior residential facility, and ones payable to several employees of Durkee & Associates. The deposits also covered

approximately $750 in bank fees for non-sufficient funds checks. 41. Neither the $15,000 transfer from the Feinstein for Senate

campaign committee nor the $15,000 transfer from the Committee to Reelect Loretta Sanchez to a Durkee & Associates' bank account was reported on federal disclosure forms for those campaign committees which KINDE DURKEE filed and caused to be filed with the FEC. E. National Popular Vote 1. 42. Misappropriation of $100,000

At all relevant times, National Popular Vote (NPV) and

National Popular Vote Institute (NPVI) were non-profit organizations whose specific purpose was to study, analyze, and educate the public regarding its proposal to implement a nationwide popular election of the President of the United States. 43. At all relevant times, KINDE DURKEE was listed in official

filings as the Chief Financial Officer of NPV and NPVI. 44. At all relevant times, KINDE DURKEE maintained records

concerning contributions to, and expenditures by, those entities. She also exercised control over funds of NPV and NPVI.
9

1

45. without National

On approximately authorization, Popular

April

27, 2010, KINDE DURKEE

caused, of

2 3 4
5

a check for $100,000 on the account into a Durkee

Vote to be deposited

& Associates'

bank account. 46. American The deposit Express, Health covered a number of checks, employees of Durkee including ones to Kaiser

6 7 8
9

several

& Associates,

Foundation sufficient

Plan, Chase, and nearly

$600 in bank fees for non-

funds checks.
2.

Misappropriation

of $80,000 caused, Popular into

10 11 12 13 14 15 16 17 18 19 20 21
22

47. without

On approximately authorization,

March 17, 2011, KINDE DURKEE

two checks on the account

of National

Vote, one for $65,000 and the other for $15,000, to be deposited a Durkee 48. Item Check Check Check Check Check Check Check Check Check Check 49.

& Associates'
The deposit Amount $3,000 $1,000 $1,000 $1,000 $25,000 $1,500 $5,000 $3,000 $3,000 $10,000 Neither

bank account. covered the following items:

Payee Michael D. Antonovich Susan Davis for Congress Foster for Treasurer 2014 Black Caucus

Stop LA Oil Tax No on Prop 0 California Equality Legislative

Network Educational Solutions

California

23 24 25 26 27 28

Center for Civic Participation National Durkee
&

Popular Vote Associates nor Durkee withdrawals.

KINDE DURKEE

& Associates

informed

NPV

or NPVI of these unauthorized

III
10

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

F.

Dianne Feinstein, Loretta Sanchez, and Linda Sanchez At all relevant times, Linda Sanchez was a member of the

50.

United States Congress representing the 39th Congressional District of California. 51. At all relevant times, KINDE DURKEE acted as the treasurer

of the campaign committee entitled Committee to Re-elect Linda Sanchez. 52. On approximately June 10/ 2010, KINDE DURKEE caused,

without authorization, the deposit of three checks, each for $10,000, one on the account of Dianne Feinstein for Senate, another on the account of the Committee to Re-elect Loretta Sanchez, and a third on the account of the Committee to Re-elect Linda Sanchez, to be deposited into a Durkee & Associates' bank account. 53. The deposit helped to cover a $25,000 payment to American

Express, a loan payment of $2,855.72 on KINDE DURKEE is residence in Long Beach, a payment to Kaiser Foundation Health, and nearly $600 in bank fees for non-sufficient funds checks. 54. Neither KINDE DURKEE nor Durkee & Associates reported the

$10,000 transfer from the Feinstein for Senate campaign committee, the $10,000 transfer from the Committee to Re-elect Loretta Sanchez, or the $10,000 transfer from the Committee to Re-elect Linda Sanchez to a Durkee & Associates' bank account on any of the federal disclosure forms for those campaign committees which KINDE DURKEE filed and caused to be filed with the FEC. G. 55. Lou Correa for State Senate 2010 From 1998 to 2004, Lou Correa was a member of the

California State Assembly representing Central Orange County. 56. From 2004 to 2006, Lou Correa was a member of the Orange 11

1 2 3
4

County Board of Supervisors. 57. California 58. From 2006 to the present, State Senate representing Lou Correa was a member the 34th District. acted as the treasurer of the

At all relevant committees

times, KINDE DURKEE for Lou Correa. September

5
6

of the campaign 59. without

On approximately authorization,

29, 2010, KINDE DURKEE of

caused,

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
28

a cashier's

check in the amount

$207,751.39,

which was drawn on a certificate for State Senate,

of deposit

account into a

in

the name of Lou Correa Durkee

to be deposited

& Associates'
These

bank account. combined with other funds, Feinstein for

60. including Senate, Item Check Check Check Check Check Check Check Check 61. campaign Committee

funds were subsequently deposit

a $25,000

from the account items:

of Dianne

to cover the following Amount $2,000 $2,000 $5,000 $30,000 $15,000 $72,000 $7,000 $150,000 Payee Richardson Richardson Warner Committee National

for Congress for Congress Linda Sanchez

for Congress to Re-elect Popular Vote Institute

Susan Davis for Congress National Popular Vote

Friends of Steve Pougnet filed and caused the filing of numerous false

KINDE DURKEE disclosure Campaign

forms

(entitled California

Form 460s - Recipient 2010

Statement.) for Lou Correa Secretary of State.

for State Senate

with the California reported campaign

The Ending

Cash Balance in the

in the forms was vastly higher account. 12

than what was actually

1

62.

KINDE DURKEE

filed and caused the filing of a disclosure Secretary of State for the Lou Correa for the

2 3 4 5 6 7 8 9 10
11

form with the California State Senate campaign

committee

which did not report committee

as required

$207,751.39 transfer

from that campaign

to a Durkee

&
the for

Asso.ciates' bank account. filing of a disclosure Senate campaign

KINDE DURKEE also filed and caused

form with the FEC for the Dianne

Feinstein the

committee

which did not report as required committee to a Durkee

$25,000 transfer Associates'

from that campaign

&

bank account. Solorio
1.

H.

for Assembly

2010 of $300,000 Jose Solorio was a member of the

The Misappropriation

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

63. California 64.

From 2006 to the present, State Assembly At all relevant committee

representing

the 69th District. was the treasurer 2010. caused, of

times, KINDE DURKEE

the campaign 65. without

for Solorio October

for Assembly

On approximately authorization,

1, 2010, KINDE DURKEE check in the amount account

a cashier's

of $300,000,

which was drawn for Assembly account. 66. These

from a money market

in the name of Solorio

2010, to be deposited

into a Durkee

& Associates'

bank

funds were subsequently items: Payee Committee Merchant Durkee Durkee
& &

combined

with other funds to

cover the following Item Check Check Check Check Check Amount $125,000 $32,000 $21,000 $25,000 $15,000

to Re-elect Account Associates Associates Account 13

Loretta

Sanchez

(Durkee & Associates)

Merchant

(Durkee & Associates)

1

67. ultimately 68. ultimately

A portion covered A portion covered

of the $32,000 check to the Merchant several checks to Durkee

Account employees.

2
3

& Associate's

of the $25,000 check to Durkee payments to American Express,

& Associates

4 5 6 7 8 9 10
11

one in the amount of The payments of entities, Robbins; Ulta; to

$16,854.76 and another American Express Union

in the amount of $679.03. charges from a variety (gift cards); Ariel's

covered

including: Turners TIVO,

76; Amazon.com Deckert

Baskin Grotto

Outdoorsman;

Surgical;

at Disneyland; in

Inc.; Bixby Animal

Clinic;

and the Aquarium

of the Pacific

Long Beach.
2.

The Misappropriation October

of $377,181.24 8, 2010, KINDE DURKEE check in the amount of in the name caused,

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

69. without

On approximately

authorization,

a cashier's

$377,181.24, which was drawn from a money market of Solorio Associates' 70. for Assembly 2010, to be deposited

account

into a Durkee

&

bank account. These funds were subsequently items: Payee Durkee
&

combined

with other funds to

cover the following Item Check Check Check Check Check Check Check Check Check Amount $45,000 $45,000 $60,000 $40,000 $25,000 $25,000 $5,000 $6,000 $5,000

Associates to Re-elect Loretta Sanchez

Committee

Beth Krom for Congress Susan Davis for Congress Merchant Merchant Durkee Durkee CAL ACE
& &

Account Account

(Durkee & Associates) (Durkee & Aaaoc Lat.e s )

Associates Associates

-

LA Efforts

14

1 2 3

Check Check 71.

$20,000 $10,000 The $45,000

Durkee Durkee

& Associates & Associates
into a Durkee

4
5

check which was deposited was ultimately

&

Associates' DURKEE's

bank account

used to cover fees for KINDE facility, and to pay at least

6 7 8 9 10
11

mother

at a senior residential

three of Durkee 72. ultimately payments

& Associate's

employees. Account were including

The two $25,000

checks to the Merchant for a number of Orange ($5,000).

used to cover payments

of things, County

to the Democratic

Foundation

- Voter Guide

($13,000) and National 73. Associates' payment Burbank. 74. Associates' The $20,000

Popular Vote

12 13 14 15 16 17 18 19 20 21
22

The $6,000 check which was deposited bank account helped

into a Durkee

&

to cover a portion office

of the mortgage building in

of $5,500

for Durkee

& Associates'

check which was deposited covered a negative

into a Durkee

&

bank account

balance

in that account in the

and was also used to cover a payment amount of $1,284.59. KINDE DURKEE disclosure Campaign committee

to American

Express

75. campaign Committee campaign Ending

filed and caused the filing (entitled California for the Solorio

of numerous

false

forms

Form 460s - Recipient for Assembly of State. higher 2010 The than what

Statement)

23 24 25 26 27 28

with the California reported

Secretary

Cash Balance

in the forms was vastly bank account.

was actually 76.

in the campaign's

KINDE DURKEE

filed and caused the filing of a disclosure Secretary of State for the Solorio for the

form with the California Assembly 2010 campaign

committee

which did not report 15

as required

1 2 3
4

$300,000 committee

transfer

or the $377,181.24

transfer

from that campaign

to a Durkee

& Associates'

bank account.

IV. Summary 77. There were at least 50 victims scheme described dollars of this scheme. KINDE DURKEE As a result caused a loss

5 6 7
8

of the fraudulent exceeding

herein,

$7 million

to her clients. V. Mailings

78. Eastern

On or about the dates set forth below, District of California and elsewhere,

in the State and of

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

for the purpose

executing artifice

and attempting to defraud,

to execute

the aforementioned

scheme and place and for deposit by any

defendant

KINDE DURKEE

did knowingly

cause to be placed mail matter

in any post office or authorized by the united any matter States Postal

depository Service,

for delivery

and cause to be deposited private or commercial

to be sent or delivered

interstate

carrier,

and cause to be delivered to the directions

by United thereon, Count 1

States mail or such carrier the mail matter Date 7/19/10 specified

according

below: Delivered To

Mail Matter FEC Form 3 Report of Receipts and Disbursements for Dianne Feinstein for Senate Form 460 for Lou Correa for State Senate for the period 7-1-10 to 930-10 Form 460 for Lou Correa for State Senate for the period 10-17-10 to 12-31-10 Form 460 for Solorio for Assembly 2010 for the period 10-1-10 to 16

Senate Office of Public Records 232 Hart Senate Office Building Washington, DC 20510 California Secretary State Sacramento, CA California Secretary State Sacramento, CA California Secretary State Sacramento, CA of

2

10/6/10

3

1/31/11

of

4

10/21/10

of

1

10-16-10
5

2
3 4
5

2/2/11

Form 460 for Solorio for Assembly 2010 for the period 10-17-10 to 12-31-10 of Title 18, United

California Secretary State Sacramento, CA Sections 2 and

of

All in violation 1341.

States,Code,

6 7 8 9

BENJAMIN B. WAGNER United States Attorney Date: March~, 2012

10
11

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
28

17

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->