AO 91 (Rev.

0Z0S) Criminal Complaint

{.Jmflted States Distnflet Court

for ttre
-Western
District of New York

Uniteal States of America

CaseNo. rs,l.l,tt-
llflL
v

GEORGEMOSES,

Defenda*

CRIMINAL COMPLAINT

I, the complainant in ttis case, state tiat the following is true to the best of my knowledge and belief

On or about the dates of July 25,2018 and July 31,2018, in the County of Morroe, in the Westem District
ofNew York, the defendant violated Title 18 U.S.C. $ 1001, said offenses described as follows:

There is probable cause to beteve that the defendant, GEORGE MOSES, did knowingly violate Title 18, United
States Code, Section 1001, by making false statements to Special Agents ofthe FBI.

This Criminal Complaint is based on these facts:

E Continued on the attached sheet.

Cotrplaiflail\ sigruture
Daniel A. Ciavarri, Special Agent,
Federal Bureau of Investigation
Pinted n@?re ond title

Sworn to before me and signed in my presence.

Date: October 23 , 2018 {\\c,,'u, d?a^at*-

ludge\ sighature

HONORABLE MARIAN W. PAYSON

City and State: Rochester. New York UMTED STA{ES ]\4AGISLRATE ruDGE
Pinted rcrie a4d title
 AFFIDAVTT IN SUPPORT OF CRIMINAL COMPLAINT

State of New York )

County of Monroe ) ss
City of Rochester ) /?-ng-'ltcu
I, Daniel A. Ciavarri, being duly sworn, depose and say:

INTRODUCTION

1. I am a Special Agent of the Federal Bureau of Investigation (FBD and have

been so employed for over 7 years. I have been trained to investigate, and have participated

in investigations o{ a wide range of federal crimhal violations, including fraud and public

comrption. I am empowered by law to conduct investigations of, and make arrests for,

offenses against the United States.

This affidavit is made in support of a criminal complaint charging GEORGE

.2.
H. MOSES C'MOSES) with violating Title 18, United States code, Section 1001 by making

false statements to Special Agents of the FBI. The false statements were rnade in a mattel

within the jurisdiction of the executive branch of the Govemment of the United States.

3. The factual information supplied in this affidavit is based on my own

investigation in this case, including witress interviews and reviews of records, my experience

and background as an FBI Special Agent, and information provided by other law enforcement

officers engaged in the investigation. Because I am submitting this affidavit for the limited

purpose of securing a criminal complaint, I have not set forth eadr and every known fact
lmown to me relating to this investigation. Rather, I have set forth only those facts that I

believe are recessary to establish probable cause to believe that GEORGE H. MOSES did

knowingly violate Titte 18, United States Code, Section 1001'

BACKGROI]ND

Defendant, dre RIIA andtle RIIC

4. MOSES resides in Rochester, New York and is the chairman of the Board of

Commissioners of the Rochester Housing Authority ("RIIA) and a board member of the

Rochester Housing Charities ('RHC). He was the chairperson of the board of the RHC

from in or about March 2015 to the fall of 2015 -

5 - The RrIA is located in Rochester, New York. It provides housing opportunities

and services for the Rochester community. It oversees approximately 2,500 public-housing

units, millions of dollars and subsidies for tens of thousands of people. The RHA has an

affrual contract with the United States Deparnnent of Housing and Urban Development from

which it receives millions of dollars.

6. The RHC is located in Rochester, New York. On or about March 20, 2013,

the RIIA formed the RIIC to assist in advancing the purposes of the RIIA. On or about

February 12,2014, the Intemal Revenue Sewice granted RHC tax exempt status as a not for

profit entity.

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 Washington, D.C. Firm - Carital Connection Partners LLC

T.]hza:.3,CapitalCorrnectionParbrersLLCC.CCP)wasformedasalimited

liability company in Washington, D.C. Its alleged mission was to plovide premier business

and consulting services to govemment entities and organizations wishing to conduct business

involving Washington, D.C. and the Fedelal govelnment. CCP is now deftmct and i6
only

client was the RHC. Lisa Ransom was one of the three partnels that made up CCP,
which

had no other emPloYees.

Arlam McFadilen and Caesar Development LLC

8. From on or about octobel 14, 2014, to on or about December 20, 2014' Adam

McFadden was the Interim Executive Director of the RHA. On or about January 23 , 2015 '

McFadden incorporated caesar Development LLC as a limited liability company.

Conkacts

g. on or about July 7 , 2015, the RHC enteled into an $87,500 oDe year contract

wift ccP (,the RHC and CCP Contract"), which provided that CCP would perform various

services for the RHC, including (a) advocating at the local, state and federal level of

govemment for policy and legislation, reviewing best practices, and issuing presentations to

elected officials, and (b) finding self sufficient resources to include creating entrepleneurial

opportunities and workforce development, developing revenue streams for residents, and

applying for federal home loan bank grants.

10. On or about July 8, 2015, McFadden, on behalf of his company, Caesar

Development LLC, executed a conEact with CCP entitled tire Pass Through Funding ald
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Services Agreement (the "McFadden Pass Through Agreement"), which provided that CCP

would pass ttrrough 75% of the funds it received from the RHC to Caesar Development LLC.

FAISE STATEMENTS

11 . On July 25 , 2078, Special Agents of the FBI, including your affiaat, intervievred

MOSES at the RHA regarding the RHC and CCP Contract and the McFadden Pass Through

Agreement. During that interview, MOSES made the following false statements:

(a) When asked how RHC leamed of CCP, Moses stated he could
not recall specifically who brought CCP to the attention of the
RHC.

(b) When asked whether he knew if CCP had any subcontractors

doing work under the RIIC and CCP Contract, Moses stated that
he was unaware of any sub-conEactors that CCP utilized to
execute the RHC and CCP Contract and he would have been
aware if any existed as he was reviewing the work product
related to the contract.

12. On July 31, 2018, Special Agents ofthe FBI, including your afEant, interviewed

MOSES at the United States Attomey's Office in Rochester regarding the RHC and CCP

Conrract and the McFadden Pass Through Agreement. During that interview, MOSES made

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 the following false statements:

(a) When told that McrFadden and his company received money
from the Rt{C and CCP Contract, Moses stated that he was
surprised that McFadden and Caesar Development LLC
received such money.

(b) When discussing a meeting held between CCP and the boards of
the RHA and RHC on December ll , 2075 , Moses stated that he
was surprised that McFadden was also at the meeting.

13. The evidence discussed below establishes that when he was interviewed by

Special Agents of the FBI, MOSES knew the following:

(a) That McFadden had brought CCP to the attention of MOSES

and the RIIC.

(b) That McFadden and his company, Caesar Development LLC,

were allegedly to perform work on behalf of CCP in connection
with the RHC and CCP Contract.

(c) That McFadden received money ftom the payments received by

CCP from the RHC and CCP Contract.

(d) That McFadden would be at the December ll, 2015, meeting

with CCP at the hotel in Rochester.

PROBABLE CAUSE

14. During the time that McFadden was Interim Director of the RHA, MOSES was

the Chairperson of the Board of Commissioners of the RHA. While Interim Dfuector,
McFadden advised MOSES that McFadden wanted to get the RHC up and runaing.

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 15. In early January 2015, McFadden contacted Lisa Ransom at CCP to discuss CCP

entering into a contract with the RHC. McFadden and Ransom had been prior
acquaintances. At this time, MOSES did not have a prior relationship with anyone of the

tlree partrrers of CCP and did not know of CCP's existence.

16. Between on or about January I , 2015 , and March 25, 2015 , MOSES engaged in

hundreds of telephone calls with McFadden.

17 On or about March 25,20t5, MOSES, as board chairpeison, caused the RIIA

Board of Commissioners (a) to appoint him as one of the three new board members of the

RHC, and (b) to approve a loan by the RHA to the RIIC in the amount of $300,000. At ttris

time, the RIIC only consisted of tfuee board members, and had no employees or executive

staff.

18, On or about May ll, 2015, MOSES had at least two telephooe calls with

McFadden, presumably to discuss approving the hiring of CCP by the RHC at the RHC board

meeting the next day.

19 . On or about May 12, 2015, at the RHC board meering, MOSES and the other

two board members agreed that RIIC would hire CCP to perform various services for the

RHC. MOSES knew at the time that the RHC had not received a formal bid for the contract

from CCP nor from any other company because no company ever provided a forrnal bid.

20. One of the other two RHC board members stated that MOSES introtluced and

suggested the hiring of CCP to the other two RHC board members. The otler two board

members had not known of CCP until MOSES advised them of CCP. Thus, because MOSES

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 had no prior knowledge of nor relationship with CCP, and because the other two board

members fust leamed of CCP from MOSES, there is probable cause to believe that MOSES

first leamed of CCP from McFadden and then brought CCP to the attention of the other two

board members. By bringing CCP to the attention of the other two board members, MOSES

brought CCP to the attention of the RHC.

21. On or about May 27, 2015, MOSES had two telephone calls with McFadden,

during which it b reasonable to assume that they discussed the RHC and CCP Contract and

the McFadden Pass Through Agreement.

22. On or about May 28, 2015, at approximately ll:.42 a.m., McFadden emailed

MOSES drafts of the RHC and CCP Contract and the McFadden Pass Through Agreement.

As stated above, the McFadden Pass Through Agreement provided that McFadden's

company, Caesar Development LLC, would be receiving 7 5o/o of the money the RHC would

be paying to CCP under the terms of the RHC and CCP Contract.

23. Between on or about May 28, 2015, the day MOSES received the drafts of the

two contracts, and July 6, 2018, the day before the RHC and CCP Contract was executed by

the RHC, MOSES had almost daily telephone calls with McFadden.

24. On or about July 7,2015, the RHC executed the RHC and CCP Contract. At

that time, MOSES knew that CCP would be payng 7 5o/o of the money it received from the

RIIC to McFadden's company, Caesar Development LLC. MOSES concealed McFadden's

involvement in the RHC and CCP Connact ftom both boards of the RHC and the R[IA.

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 25. On or about July 8, 2105, McFadden, on behalf of his company, Caesar

Development LLC, executed the McFadden Pass Through Agreement. MOSES and

McFadden had a telqrhone call on that date.

26. On or about August 3, 2015, although the RHC and CCP Contract had only

been entered into less than a month earlier, the RHA on behalf of the RHC paid CCP $43,750,

which represented the first installment payment under the terms of the RHC and CCP

Contract. At this time, MOSES was board chairperson of the RIIA and a board member of

theRHC.

27. On or about August 8, 2015, CCP paid $32,812.50 to Caesar Development

LLC, which represented 7 5% of ttre funds CCP had just received from the RHA.

28. On or about h:try 22,2015, MOSES and aoother RHC and RHA board

member, submitted to the RIIA board of commissioners a copy of fraudulent RHC board

minutes from the May 12,2015, RHC board meeting. The board minutes falsely stated the

RHC had received three formal bids before selecting CCP as the low bidder. The board

minutes also failed to identiff McFadden's company, Caesar Development LLC, nor state

that Caesar Development LLC would be receiving most of the funtls from the RHC and CCP

Contract.

29. On or about December 10, 2015, two members of CCP traveled to Rochester

and met with McFadden and MOSES at a local restaurant. Prior to that meeting, MOSES

and McFadden had at least three telephone calls that day.

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 30. On or about December 11,2015, the two members of CCP along with

McFatltlen attended a meeting with the RHC and RHA board members at a hotel in

Rochester. There is probable cause to believe that MOSES knew that McFadden would be

attending this meeting and that he was not surprised to see McFadden at the meeting.

31. Prior to the RHC's second $43,750 payment to CCP by the RHC in December

2015, McFadden regularly spoke with MosES and sent him emails during and in which they

discussed the second installrnent payment by the RHC to CCP. MOSES tnew that

McFadden's company, Caesar Development LLC, wogld be receiving funds from t}is second

payment.

32. On or about December 23, 2015, the RHC paid $43,750 to CCP, which

represented the second installrnent payment undel the terms of the RIIC and CCP Contract.

At this time, MOSES was board chairperson of the RIIA and a board member of the RHC.

. 33. OnoraboutDecerfierz4,20l5,CCPpaid$32,812-50toCaesarDevelopment

LLC, which rep resented 7 5o/o of the funtls CCP had just received from the R[IC.

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 CONCLUSION

34. Based on the foregoing, I respecfrrlly submit that there is probable cause to

believe that GEORGE MOSES did lnowingly violate Title 18, United States Code, Section

1001, by making false statemens to Special Agents of the FBI.

?* f, /,---
---
Daniel A. Ciavarri, Special Agent
Federal Bureau of Investigation

Swom to before me this

z3 dayofOctober20l8.

rY1uiu.i?^,rr-.
HON. MARIAN W. PAYSON
United States Magrstrate Judge

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