SUPREME COURT OF THE STATE OF NEW YORK KINGS COUNTY THE PEOPLE OF THE STATE OF NEW YORK -againstEDDIE

CALDERON-MELENDEZ, Defendant. GRAND JURY No. 1156-2012 INDICTMENT No.

INTRODUCTION Defendant EDDIE CALDERON-MELENDEZ was the founder and Chief Executive

Officer of the Williamsburg Charter High School ("WCHS") from 2004 through in or about March 2009. WCHS is a charter high school located in Kings County with approximately 1,000 students. In or about August 2009, defendant EDDIE CALDERON-MELENDEZ became the

Chief Executive Officer of the Believe High Schools Network ("Network") located in Kings County. The Network was a charter management organization that entered management agreements with WCHS and the newly created Believe Northside and Believe Southside Charter High Schools (collectively, "the Charter High Schools"), all located in Kings County. During all relevant times to this Indictment, defendant EDDIE CALDERON-MELENDEZ resided in Kings

County and worked for and received compensation from entities located in Kings County. From in or about 2005 through in or about 2010, defendant EDDIE CALDERONMELENDEZ has received approximately $1.4 million in compensation, over $500,000 of which he received in tax year 2009. EDDIE CALDERON-MELENDEZ has not filed required New

York State Tax Returns for tax years 2005 through 2010 and has failed to pay at least $70,000 in taxes owed to New York State and New York City for tax years 2005 through 2010. In response to a subpoena from the Office of the New York Attorney General, defendant EDDIE

CALDERON-MELENDEZ and 2008.

produced false New York tax returns for tax years 2005, 2006, 2007,

As Chief Executive Officer ofWCHS and the Network, defendant EDDIE CALDERONMELENDEZ had a WCHS corporate credit card to be used exclusively for expenses related to the Network and the Charter High Schools. In or about December 2009 and January 2010, defendant EDDIE CALDERON-MELENDEZ stole over $1,800 from WCHS when he charged

over $1,800 to the credit card while on a personal trip to Europe. In an effort to conceal this theft, defendant EDDIE CALDERON-MELENDEZ entries in a business record of WCHS. COUNT ONE THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of REPEATED FAILURE TO FILE PERSONAL INCOME AND EARNINGS TAXES, in violation of New York State Tax Law § 1802(a) [in effect 19852009], committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the county of Kings and elsewhere, on then made and caused to be made false

or about April 15, 2008, being required under Article twenty-two of Chapter sixty of the New York State Tax Law to file such a report or return, with intent to evade payment of personal income tax imposed under Article twenty-two, willfully failed to file a return for three consecutive taxable years and had an unpaid tax liability with respect to each of the three consecutive years, specifically: the defendant failed to file a return and had an unpaid tax liability for the 2005 taxable year, for the 2006 taxable year, and for the 2007 taxable year.

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COUNT TWO THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of REPEATED FAILURE TO FILE PERSONAL INCOME AND EARNINGS TAXES, in violation of New York State Tax Law § 1808, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the county of Kings and elsewhere, on

or about April 15, 2011, being required under Article twenty-two of Chapter sixty of the New York State Tax Law to file such a report or return, with intent to evade payment of personal income tax imposed under Article twenty-two, willfully failed to file a return for three consecutive taxable years and had an unpaid tax liability with respect to each of the three consecutive years, specifically: the defendant failed to file a return and had an unpaid tax liability for the 2008 taxable year, for the 2009 taxable year, and for the 2010 taxable year. COUNT THREE AND THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of CRIMINAL TAX FRAUD IN THE THIRD DEGREE, in

violation of New York State Tax Law § 1804, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the county of Kings and elsewhere, on

or about April15, 2009, being required under Article twenty-two of Chapter sixty of the New York State Tax Law to file such a report or return, with intent to evade payment of personal income tax imposed under Article twenty-two, willfully failed to file a return and paid the State and a political subdivision of the State, in a period of not more than one year, in excess often thousand dollars less than the tax liability that was due.

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COUNT FOUR AND THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of CRIMINAL TAX FRAUD IN THE THIRD DEGREE, in

violation of New York State Tax Law § 1804, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the county of Kings and elsewhere, on

or about April 15, 2010, being required under Article twenty-two of Chapter sixty of the New York State Tax Law to file such a report or return, with intent to evade payment of personal income tax imposed under Article twenty-two, willfully failed to file a return and paid the State and a political subdivision of the State, in a period of not more than one year, in excess often thousand dollars less than the tax liability that was due. COUNT FIVE AND THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of CRIMINAL TAX FRAUD IN THE FOURTH DEGREE, in

violation of New York State Tax Law § 1803, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the county of Kings and elsewhere, on

or about April 15, 2011, being required under Article twenty-two of Chapter sixty of the New York State Tax Law to file such a report or return, with intent to evade payment of personal income tax imposed under Article twenty-two, willfully failed to file a return and paid the State and a political subdivision of the State, in a period of not more than one year, in excess of three thousand dollars less than the tax liability that was due.

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COUNT SIX AND THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of TAMPERING Penal Law §215.40, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the County of Kings and elsewhere, in WITH PHYSICAL EVIDENCE, in violation of

or about September 2011, with the intent that it be used and introduced in an official proceeding and a prospective official proceeding, knowingly made, devised, and prepared false physical evidence, specifically: a New York State tax return for the 2005 tax year. COUNT SEVEN , AND THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of TAMPERING Penal Law §215.40, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the County of Kings and elsewhere, in WITH PHYSICAL EVIDENCE, in violation of

or about September 2011, with the intent that it be used and introduced in an official proceeding and a prospective official proceeding, knowingly made, devised, and prepared false physical evidence, specifically: a New York State tax return for the 2006 tax year. COUNT EIGHT AND THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of TAMPERING Penal Law §215.40, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the County of Kings and elsewhere, in WITH PHYSICAL EVIDENCE, in violation of

or about September 2011, with the intent that it be used and introduced in an official proceeding and a prospective official proceeding, knowingly made, devised, and prepared false physical evidence, specifically: a New York State tax return for the 2007 tax year.

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COUNT NINE AND THE GRAND JURY, by this Indictment, accuses defendant EDDIE CALDERONMELENDEZ of the crime of TAMPERING Penal Law §215.40, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the County of Kings and elsewhere, in WITH PHYSICAL EVIDENCE, in violation of

or about September 2011, withthe intent that it be used and introduced in an official proceeding and a prospective official proceeding, knowingly made, devised, and prepared false physical evidence, specifically: a New York State tax return for the 2008 tax year. COUNT TEN AND THE GRAND JURY, by this Indictment, further accuses the defendant EDDIE CALDERON-MELENDEZ of the crime of GRAND LARCENY IN THE FOURTH

DEGREE, in violation of Penal Law §155.30, committed as follows: Defendant EDDIE CALDERON-MELENDEZ in or about December 2009 and January

2010, in the County of Kings and elsewhere, stole property, specifically: approximately $1,858.09 in expenses for a personal trip to Europe which were charged to a Williamsburg Charter High School credit card. COUNT ELEVEN AND THE GRAND JURY, by this Indictment, further accuses the defendant EDDIE CALDERON-MELENDEZ of the crime of FALSIFYING BUSINESS RECORDS IN THE

FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: Defendant EDDIE CALDERON-MELENDEZ, in the County of Kings and elsewhere, in

or about January 2010, with intent to defraud, made and caused a false entry in the business records of an enterprise, and his intent to defraud included an intent to commit another crime and to aid or conceal the commission thereof, specifically: email from EDDIE CALDERON6

MELENDEZ falsely stating that charges he incurred on a Williamsburg Charter High School credit card while on a personal trip to Europe would be reversed by the vendor and notation that such charges were erroneous and would be credited.

ERIC T. SCHNEIDERMAN NEW YORK STATE ATTORNEY GENERAL

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