COMMONWEALTH OF POLICE CRIMINAL COMPLAINT PENNSYLVANIA GOMMONWEALTH OF PENNSYLVANIA. COUNTY OF:PHILADELPHIA. vs. ‘Magisterial District Number. MDJ: Hon, PHILA ARRAIGNMENT COURT DEFENDANT: (NAME and ADDRESS): ‘Address: 1301 FILBERT STREET CHRISTEN, Ss wooos PHILADELPHIA, PA 19107 ae Mie Rare cid 4700 CITY AVENUE, APARTMENT 6306 PHILADELPHIA, PA 19131. = mae NGIG'ExtraattcnyCode, Type Cl FFebony Fut Ti Citidemewrar Suroundng Sites Di 2Febny ud [Hi seloy Pend, Extadion Deter, Dlademeana No Exradton 3 Febny Soriundg States») AMldemsarc Ful i Etedereunor Ponds Ce Foiny Noe. Cetedenearor Utes Ceasers Pec xen Som Tai led Patt vedenn Kanter | CompuRY Nomba? Ieee] Reqs Lao Sonos? wx fotf org 36721 Gyes BNO ewer | p08 02/02/1985 [ros aaeios —/ Go-Gatondans) ED Bi wate Fis Name Tie Naso ‘stems ‘on Ciremste | axa Byesnerry — Pip See = HAIR COLOR Trew Gay Caco reanuin) — Chaovanay Chacon Crusirai Clana mm Bleixisiy Cows ores) — Claas) Chacctuiveay Chan fares) Cra) Clow ser sete Tiaikene) CB) BRO) LOW ona Taw ean Ome Chuan awe) Clemicns Cr putes) 13008 eon Dives Gino Lecation, MeGHTObeh | [en amber L panied] CI VES_BENO ae [a ER ca ‘Stale ] Faamat | Registration ComiVon. 4] School | Ol NCIC Vah. Coda] ap. [Bom | rari, 7 | Som ol eto a Year| Make Woda! ‘sye ‘Color eae Office of the atiorney for the Gammonweaith Ci Approved [1 Dieapproved because; ‘The atoroy fore Gonmmonnealh may require hal he Galant, aren warartafidavl, ar both be approved bythe aomey forthe Gommonveaih paar to ing, Sas PaR.Crim?, £07), -SDAG JAMES PRICE pe Fiat hae wnt be Coan) S50 ry oe Co, oy |, SUPERVISORY SPECIAL AGENT MATTHEW SMITH. __ 805 ‘ace of an) {PSPRIPCETE asad Aa Wanbar Baas WY of PENNSYLVANIA OFFICE OF ATTORNEY GENERAL pAg222400 “ently Department or Agency Rapeseriad snd Pots Subdlalsn) (Paice Agwnay OFT Namba do hereby state (check appropriate box) 4. Bl accuse the above named defendant who lives at he address sel forth above DL accuse the defendant whose name is unknown to me but who is described at ‘CT accuse the defendant whose name and popular designation or nickname are unknown to me and whom Ihave therefore desianated as John Doe of Jane Doe wilh violating the penal laws of the Commonwealth of Pennsylvania at PHILADELPHIA in PHILADELPHIA Ist) ‘on or about JANUARY 2019 - DECEMBER 2019 County (County Gade) {Otense AOPC 412A ~ Rev. 12/21. Page tof ¢ah POLICE CRIMINAL COMPLAINT OFNILIveSean Numniber ‘Complain Number | incident Number 36721 [eer Toast woops ‘The acts committed by the accused are described below with ach Act of Assembly of statute allegedly Violated, i ‘appropriate. When there is more than one offense, each offense should be numbered chronologically. {Settorth brief oummary of th ors suf to advan th dandant ofthe nature cf the offonaes) charged, A iaon to the statues) alogechy te ert cn ns rr ham ou a ct open) uri of sn) woe siegeat Tachoate Tova enone | Cl atenrt ae i Conspiracy Number of Victims Age 60 or Oldar a@ {i [ot 53 (ete 18 1 Fi_ [2399 [23H : a 7a Sale Cl — Ca I ac — HE Rana Cate — UCAS Ta noo ae Di intrstate satetyzene | Werk Zone Salute Descripion incu the naite of Halil or onance) cure Orintonw ‘ats of the accused associated with tis Offense: it challbeunlawdfor any person employed by o astodated wath eny enterprise to conduct or partlpate, rect or betes, nthe conduct of such enkerprise's aflars through a pattem of racketeering act, To wit: Christen Woods va the Dit 395 hesincareurantrough a pte of rackaerng. Tnehoate | C Atomet Tr Soiictatlon Ti conspi ‘tance | sora ‘a fee”) [namtarer tine an cer 18 [a FL 2399 23H aN Sa CO intentata Safety Zon Wer Zoro ‘Statule Description (Include the name of statute or ordinance); Corupt Organizations “Adis of the accused associated with this Offenser it chal be udawful fer any peson to canpre to wlate any ofthe provisions of parapraphs i 2, fst. Tow: Cen Wont an Tray Hare va ne Dati 190 athe uncrManepnkConsrcion and evecpment || Corporation Monroe Trahaat | ET Apt Tisaiaiaton i conap Offense | 14907 fous Eta |. [Mamter ot vein Ag 6 or Oder _—_ Pee zr Se SRS Ti Gass Gai oe rou Ten PennbOT bal] AA] ce ERC ae ‘Cintate | Cl eatin Ti Wek zaie i | o [3 [sit [As aes i Fi 2399 [234 | | i ‘Statute Description (include the name of statute or ordinance); Dealing in Proceeds of Unlawful Activities | “Acs of the accused ascoclated with this Offense: A person canis a felony ofthe ft degree I the person conduc a fhanciel rensecton Under any ofthe folowing creurstances: To avoid a transaction reprting requirement under State or Federal aw, To wit: Csten Woods and Tracy Hardy | ‘conapted te commit ancl transactions to Manayirk Censiuction and Development Corporatloy/Mocroe Press na anne to avid artpaign france ‘reporting requlements, i AOPG 412A Rev. 12/24 Page & of 6C3 POLICE CRIMINAL COMPLAINT Basket Number: Dale Fed GUL NeSean Number [Complaint Number Esser haie wae Tat Ss Woops. The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, If ‘appropriate, When there is more than one offense, each offense should be numbered chronologically (Set forts brief summary of he facia sufcoot to advlae the dafenan ofthe nature of tho offense(s) charged. A citation tothe salutes) altegey Sistem, ct acand ns array eve, you et oa the specie secon) an taneecvon) fe its or Sonne} Sogo tea) Ineheaie [T] Afamot Tsien U Gieepeser Number of Vitims Age 69 or Oldar ee 3 Fi. [2399 Tose Se SE —— age —— Ge a a STR iterate 1 sate Zane 1 Witk Zone ‘Statute Description (include the name of statute or ordinance): Dealing in Proceeds of Unawul AAVRES ‘Reis of the accused associated with this Offense: A peron Ganrits a felony ofthe first degree Ifthe person conducts efnancil vansacton Under any ofthe felling creurtances: To avo a transaction rearing requicement under Stale o Federal av. To wit: Cretan Woods engaged in a ‘course of conduct lo avod necessary reporting recuremens pursuant inthe Penryivania Election Code ae United States Department of Labor mandated Migs. 7 Trchoata | Cl Atamet Ti Saletan ] Bi eon Oftense | 199004 ieaoea [Prose Number of Visine Age 0 oor —_ ao 3922 AL 18 i F2__ | 2399 BH | ee ee 1D iieatate Satay Zone Di Werk zone ‘Statute Description (include the name of statute or ordinance). Theft by Dexpion ‘Frais of ie accused associated with this Offense: A parson & gully of tft ihe Inertonally obtains o withholds property of anober by ‘deception, A person decelves If he iteiionaly: creates or rainforcesaflse pression, inducing fis Impressions as to law, vale, Intention or other state ‘of mind; but deception as to a pees intention to perform promise shal nt be bverred fom the fac alone that he id not subsequent perform the promise, To wit: Dlshct L199 fund in excess of $350,000. Chrsten Woods and Tracy Hardy deceived the Executive Board and Members of Distct 1199 by Way of fraudulent bds/estimates and inated fraudulent veces. Tehoale | Cte m a (oimrse [Ofer OTora Ome Number Vista Age 80 or ote O [6 3922 pat 18 1 F2 2399 23H eee = Se FA os THEIE Oa Gda—~ VeRO oiappicabisy Shan i iteiate sete Zone Werk Zone ‘Statule Description (include the name of statute or ordinance): The by Deception ‘als of tha accused associated with this Offense: A peson gully of theft he intentional cbtans or whalds propery oY ancther By ‘deception A person decelves ff intentional: creates oF referees @ false pression Including false ipressons as ofa, value, tention or other state ‘of mind but deception asf a persis Intention lo perform a promise shal not be inferred fom the fact sone that he ld not eubsequeni perfor the fi, Toys 58 es ne of 15050, seg te ete Bont of DATE G5 yw of tg ede ad i estimate AOPC 412A — Rev. 12/21, Page 3 of §E] POLICE CRIMINAL COMPLAINT Date Filed? [ONC hwScan Number | Complaint Nomber — | incident Number 1 L I 36721 | Fae 7 water Tae CHRISTEN Is woons. ‘The acts cornmiied by the accused are described below with each Act of Assembly or statute allegedly violated, I appropriate, When there is more than one offense, each offense should be numbered chronologically. {ot fort bref summary oft facta sufclort oadvae th Catondant ofthe nature ofthe ofenao(s) charge. A con lo he statis) alagedly ‘lid witout more oot sfc a suremary nse, you must he the apecie nection) and mutaeeon(s) of the tales) or ennance() Megeaty vile Tachoate | HI Atempt Saletan ee (Se Oar [oe TEP] [meena anwar F2__ [2399 [23H eae — Res ese Cae —— TERRA Te nue tetera Di setey Zone 1D Work Zone ‘Statute Description (include the name of siatote or ordinance): The by Faure io Make Required Depaston of Funds a [7__]3927 ‘Aels ofthe accused associated with thls Offense: A person who obtains property upon agreaen, or subjectto @ known legal obigtin, (0 ‘make species payments or ober dapostion, whether fram such property ors proceed o om he own property to be reserved in equalent amet, 6 uf of thet he intenioraly Gens with the property obtained as hs own and falls to make the tequred payment or dspaton. The foregoing apples otwstandlng that & may be impossible to deny partcular property as belonging to te vcim atthe tine of the faBure ofthe actor to me the ‘ecard payment cr dispostion To WR: Ofsbct 11996 unon funds unoufilywttzed by Cviten Vioods. [Tene] Cpa Cr Sstetaton BI Gonsniacy [Renter vit ge cr o [gs 3925 A 18 [a Fo 2399 2H tee eae Sa a ea —Neie otenes code “ean coe Tuan Clawete | Cleastyzne | Won zoe ‘Siatute Description (include the name of statute or ordinance): Recaivig Stain Property ‘Aaks ofthe accused associated with this Offanse: A pacn is gully of taf he itentonaly receives reais, or sposes of movable propery of another knowing rat thas been site, or beeving that has prababy been stolen, unies the propery Is received, retained, oF dspased with intent to | tee the one To WE Dict 1190 uo Rrdsn acs of 00, Cin Wa a Tay May gpd a chee in ech the *xeetve Board of Ds 1185, in oer to reco approyal for nf aed Frauen Inicesestinates Tachoate | C Atay Sonanaion Sona aes [Or eri OU conapinioy Number ot Victims Age 60.07 Oldar_ a [9 [3925 A [eeeeis i F2__ | 2399 23H a SSE aa cams —— eae ome ae RR Penpoor Daa = ree oa [eins | Eleatyze [CW 2am ‘Statule Description (Include the naire of statute or ordinance); Ressvng Stolen rosety ‘Rals ofthe accused associated with thie Offense: A pasos gully of tet Whe inttnalyrecdes, rains ot depoes of movabla property ‘of ater knowing that has been stl or befeing that X has pekaby been sclen, unless the property receive, rele, ox isposed wh intent restore tothe ower: Tow: Distt 11S8C unon Ads fy excay of $350,000, Cvisten Weds engeged ih scheme to deci the ecuive Boardct | ‘ic 11986 oxer to cee appro erated se reuculert vlcs/estinates, AOPC 412A - Rev. 12/21. Page 4 of 6+a POLICE CRIMINAL COMPLAINT Bate Filed! | OTNiLiveSean Number eer incident Number 36721 Sl First Taide: Tiast S51 CHRISTEN, 5. | wooos ‘The acts cottmitted by the accused are desoribed below with each Act af Assembly or statute allegedly violated, if ‘appropriate, When there js more than one offense, each offense should be numbered chronologically. {Satforth abo ummary of a nett nuicteat to advise the dafondant ofthe nature ofthe offenests} charg. A ciao t hosts) allegedly hewlett nn sary ako ant a pce eet ne eno) Ua ear Tnchoate | Cl Afanot ior a ems | fasora Oneen Oe ] [amperarwcuna agen ercuer a [10 [3921 [a_i is 1 [rs [2399 [23 | tua — “mas FR el —— Ca Gah a Cae & a Ce ‘Slatule Description (inclide the name of statue or orchnanco) Teh by Owl Taig or Depeon ‘Rats ofthe acciised associated with tis Offensar A persons gulty of theft he unlawfully ies, or eerceesuniavtl cert over, movable ropety of another wth intent to deprive him thereof, To wl: $3,000 n District 1199C union fund issued to police action commltees without the _Bppvovalor author ofthe Eecive Board of Disc 1199¢. Troha | OT Aiea Ti sates Sa reposts [5 Meet sate BE Covapiscy | Number of Victims Age 60 oF Older ee 4101 AQ 18 1 Mi 2399 234 a viene ee | Cinewite | | Ch SaltyZoue | C1 Werk Zone Salute Description (hcude the nara of sate or ordnancey Foae7 ‘Acts of the accused associated with this Offense: A peor is gulty of forgary wit tata defaud or mur anyone, or wth krowiedge Tha he Is ecltating a fraud or irr tobe perpetrated by anyone, the eco: malas, completes, executes, authenticates, issues of ansfers any writing 0 that Te puxpors tobe the actof another wh didnot authorize that actor to have bean executed at a tine ot place orn a numbered Sequence oer than was sequen fact the case, oto be a copy f an orignal when no such anal ete, To wit: Csen Woods and Tracy Hardy Va fraudulent and fale idjestmat in the mame of Gressen Properties Tachoato | UT Aim TT seater Ti conepia Srtewe | Cfeanta seme feo [Number of vets Ade 0 cr Ofer _ ao [a2 [aion A218 1 [mi [2309 2H Saki a Sa TE ORs a VERSE : JD tnertate Safety Zone Cl Work Zone ‘Statute Description (inckide the name of statute or ordinance): Forgery ‘Adis of the accused associated with this Offense: Apes i gully of ergery if wit intent to defaud er ire anyone, or with knowledge that he & acting 3 aud or iury tobe perpetrated by anyone, the actr: makes, completes, exectes, authenticates, sues or transers any wing so tha IR purports tobe the at of another wh didnot authorize that at, orto have been executed ata te or place cr na numbered sequence other then wasn fact the cas, o° tobe a copy ofan erignal hen no such crignal existed. To WE: audit and flv Bcs/estmate Inthe name of Gressen Properties AOPC 412A - Rev. 12/21. Page Sot &$85 PoLice CRIMINAL COMPLAI ‘Docket Number: ] ‘Date Filed: ‘OTWiLiveSean Number ‘Complaint Number | Incident Number 36721 ada cat s | wooos 2. Lask that @ warrant of arrest or a summons be issued and that the defendant bs required to answer the charges I have made, 2, I verify thatthe facts set forth in this complaint are true and correct to the best of my knowledge ar information and belie ‘This verification Is made subject to the penalties of Section 4804 of the Crimes Cade (18 Pa.C,S. § 4904) relating to ‘nswom falsification to authorities 4. This complaint consists of the preceding page(s) numbered _/ through £ . 5. | corti that this fling complies wth the provisions ofthe Case Recoris Pubile Access Policy ofthe Unified Judicial System ‘of Fennsyivania thal require fling confidential information and documents differently than non-confidential information and documents. ‘The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth of Pennsylvania and were contrary to the Act(s) of the Assembly, or in violation of the statutes cited. (Before a warrant of arrest can be issued, an affidavit of probable cause must be completed, sworn to before the issuing authority, arid attached.) fy 214 Se Pays (Dale) (ear palure of 7} “ ANONOW, onthin date May} Do9y | cet thatthe complain as been prop completed and vere. [An afi of probable cause must be complated betcra @ warrant can be 1ssusc. Vogiatora) Datel Coun Numba) issuing Author) (Wogiatr issuing Aes AOPC 412A — Rev. 12/21 Page & of 6En] POLICE CRIMINAL COMPLAINT. Bockat Wamber: Dats Fed? | OTNILveScan Number | Complaint Number | Incident Number L 36721 Fist Wide: Task CHRISTEN Ss wooos AFFIDAVIT of PROBABLE CAUSE Your Affiant, Supervisory Special Agent Matthew Smith, Pennsylvania Office of Attorney General (hereinafter ‘OAG), Bureau of Criminal Investigation, being duly sworn, does depose and say: ‘The Pennsylvania Office of Attorney General has been involved in an investigation into offenses in violation of the criminal laws of the Commonwealth, The OAG's investigation has utlized the Statewide ‘Investigating Grand Jury and as a result, the Fiftieth Statewide Investigating Grand Jury issued Presentment No, 8, on April 19, 2024, This Presentment was accepted by the Order of the Honorable Lillian Harris Ransom, Supervising Judge. The Presentment attached to this Affidavit and incorporated herein by reference, recommends charges be filed by the Attorney General or her designee against the defendant, ‘Your Affiant has reviewed the Presentment and finds the factul findings described therein correspond to the OAG investigative findings. Your Affiant has reviewed the sworn testimony given by witnesses before the Grand Jury and finds that it Is consistent with the information contained within the Presentment. Your Afflant has reviewed the evidence presented to the Grand Jury and finds that it comports with the results of the OAG investigative efforts and findings as to the allegations contained in this compiaint. Your Affiant states, based upon the above facts, there Is probable cause to believe that the defendant, Christen Woods, committed the acts detalled above in violation of Pennsylvania law and respectfully requests that an arrest warrant be Issued. igsp metas Sent 4, ‘BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN ‘THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, J CERTIFY THAT THIS FILING COMPLIES WITH THE PROVISIONS OF THE CASE RECORDS PUBLIC ACCESS POLICY OF THE UNIFIED JUDICIAL SYSTEM OF PENNSYLVANIA THAT REQUIRE FILING CONFIDENTIAL INFORMATION AND DOCUMENTS DIFFERENTLY THAN NON-CONFIDENTIAL INFORMATION AND DOCUMENTS. Dr Hs signature o tart) ‘Swom fo me and subscribed before me day or 2s ——____ mae , Magisterial District Judge My commission expires first Monday of January, 20 34 SEAL ‘AOPC 444¢ ~ Rev. 12/24 " Page tof |INTRODUCTION ‘We, the members of the Fitith Stuewide Investigating Grand Jury, having received and reviewed evidence regarding violations of the Pennsylvania Crimes Code ocourring in Philadelphia County, Pennsylvania, pursuant to Notice of Submission of Investigatian No, 14, do hereby make the following findings of fact end recommendation of charges. OVERVIEW ‘The Grund Jury conducted an investigation into e scheme orchestrated by Christen “Chis” Woods and Tracy Hardy to sieal in excess of $150,000 from the District 1199C union ia Philadelphia in 2019, Woods, the head of Distict 11990, ead Hendy, » Philadelphia political conmutast, mbited flee bids to the union to ensure Hatdy’s newly created and unlicensed construction company was «warded « heavily-inflated bid to renovate a portion of the union hall. ‘The money was then funneled from the construction company to Hardy's politcal consulting company, Monroe Press, to find political work for Woods's chosen candidates for the 2019 Democratic primary election, Woods also used union funds to pay fraudulent invoices from Hardy's consulting company in order to provide financial support for candidates endorsed by ‘Woods. Woods and Hardy utilized financial transections in order to conceal their theft from the union and to citoumvent Pennsyivania campaign finance law and U.S, Departmect of Labor union -eporting requirements, The two also personally benefited ftom their fraud,SINDINGS OF FACT District 1199C is « subsidiary anion of the National Union of Hospital and Healthcare Employees and represents thousands of healtheare workers throughout tho greater Philadelphia axea Its headquarters is located at 1319 Locust Street in Philadelphia, which members refer to ea ‘their union hall, Henry Nicholas, who founded the union in the 1970s, served as the union's fong running president until 2019. According to the District 1199C by-laws, the union must bave one President, one Secretary- Treasurer, two Executive Vice-Presidents, and as many Vice-Presidents as deemed peoessary by the Executive Board. Per union financlal statements, there were two vice presidents in 2019, The Executive Board is comprised of these officers and several other no salatied voting members wiho ate elected ftom the wnion’s membership. The Executive Boatd is required to meet twice a month and “approve and authorize the disbursement” of the union’s fonds, _Woods was hited by Nicholas in 2013 and served as Bxecutive Vice-President (EVP) of District 1199C until 2019, Through his position, he was second in command since he wes the BVP of the hospitals division which held more members than the other EVP"s division. The Grand Jury heard testimony from Distriot 1199C administrators that Woods waa Nicholas’s chosen suocessor, Officets and aéiminiatzatirs testified that although Nicholas was the president, it was Woods who ‘was running the day-to-day operations of the union in the years leading up to 2019 due to Nicholas’s advanced age and declining heslth, In a statement provided to Office of Attorney General Supervisory Special Agent Matthew Smith (SSA Smith) the General Counsel for District 1199C stated that Woods was effectively acting as president and making substantial decisions for ‘the union fn the years leading up to 2019, Jn May 2019, Nicholas was elected as President and Woods as EVP during the May 2019 officer election, Shortly thereafter, Woods moved the Executive Boart! to appoint him as Acting,President, Email communicstions in days prior to and after the clection revealed that Woods was working on organizational charts forthe uoion which identified him as the person in charge, with xno mention of Nicholas: District 1199C Org Chart eal {sz | [rcs] ait 2 ‘The Grand Tuy heard testitiony fiom sevetal officers who indicated that Woods hed disputes with Marguerite Stanford, the ution’s longtime Secretary-Treasurer, The testimony revealed that Woods and Stanford feuded about union funds and the way in which Woods wanted to conduct union business, including frequently seeking immediate payments of submitted inyoices, Prior to the 2019 union election, Woods sought to replace Stenford, Woods’s chosen replacement was ultimately elected as Sectetary-Treasurer in May 2019. ‘The Executive Boatd typically approved the union’s budget in the falyinier ‘of the year preceding the upcoming fiscal year, The Executive Board meeting minutes for 2018 indicated, 3however, that no budget was approved for 2019, Inher appearance before the Grand Jury, Stanford testified that exeoutive board mectings in 2018 und 2019 were often canceled and she never presented the budget, Per'the by-laws, the Executive Boed is required to meet at least 24 times ‘por year, The Grand Jury reviewed executive board meeting minutes which revealed that only three meetings were held in 2018 and eleven were held in 2019. The 2019 budget was never presenited to the Executive Bourd until September 19, 2019, The Grand Jury investigation found ‘that Woods operated the day-to-day operations of the unio with little to no input fromm the Bxeoutive Board, ‘The Grand Jury gathered various other recotds, including recotds from District 1199C, District 1199¢’s banking institutions, and tts auditing accountant. A'review of these records established that dutitg 2019, Woods directed the spending ofa substantial amount of union funds ‘without the authority of the Executive Board and, at times, deceived the Executive Board and the union's gnarl membextip trough rmnaletaoivity tat he engnged in with Hardy, Several District 1199C administrators testified that Woods was close friends with Hardy, ‘2 well-knowa-Philadelphia politioal operative, Hardy owns and operates Monroe Press, Inc., & pollticel consulting business located in Philadelphia, The Grand Jary reviewed text messages and cellular telephone records thet clearly indicated that Woods.and Hardy wete in constant contact ‘throughout 2019, Hardy hnd worked with District 1199C on their ennual get-out-the-vote (GOTV) political events, Emails exchanged between Hardy and Woods also demonstrated Hardy's {inyolvetnent in these events during the 2018 ganeral election. In the fall of 2018, Hardy opened Maneyimk Construction and Development Corporation (Manayunk Construction”) along mith Tim Kovacs. The Grand Jury learned that Hardy is nether 4 Licensed contractor nor a tradesman, and had no known experience in construction, Kovacsappeared before the Grand Jury and testified that he believed that he and Hardy started Manayunk Constristion with the intention of buying houses tnd “flipping” them; however, this never caine to fiition. Kovacs also indicated they sought to become a union affiliated company, but they could not afford the necessary bonds, Their business asrangement, as desctibed by Kovacs, was for Hardy to be the financier and Kovacs fo provide the labor asa licensed contractor. Kovacs testified that Manayunk Construction was not a licensed contracting company in Philadelphia. Kovacs stated that work done through Manayunk Construction had te be performed by his own licensed company, Tim Kovacs General Contracting. District 1199C was the only client of Manayunk ‘Construction throughout 2019, according to the business's bank records” Yet, as later detailed in this presentment, Kovacs only performed a smell fraction of the work District 1199C paid Hardy to perform in 2019, ‘The investigation revealed that Woods directed District 1199C to pay Manayunk Construction and Monroe Press over $320,000 in union funds in 2019 in connection with more than 20 separate invoices, More than $230,000 of this amount represented payment for consrustion and maintenance work peered a the union hall The ion’ ancl disclosure paperwork revealed that District 11996 had previously only paid Hardy, through Monroe Press, approximately $10,000 in 2017 and 2018 for “promotional items,” ‘ll of Manayunk Canstructon’s revenue, fom the ime of ts fommation through the end of 2019, was desived solely ftom Distt 1199C, The Grand Jury beard from officers, executive board members, and administrators of District 1199C who served in 2019. Many of these individuals weto unaware that Hardy was associated with Manayunk Construction ot of the full extent of the vnion’s payments to Hardy's companies.Bar Renovation Fraud Scheme; ‘The Grand Jury reviewed a January 20, 2019 e-mail that Handy sent from his Monroe Press. ‘email address to Woods at his union email address, Attached to this email were two documents ‘Hom Mansyaek Construction.) an invoice in the amount of $1,688 and 2.) a $47,490 eatnate to renovate the bar atea of the union hall. That same day, Woods submitted a check voucher request, along with the invoice, to the Secretary-Tyeasurer for payment. District 1199C, in turn, issued a check to Manayunk Construction for $1,688 on Tanuaty 31, 2019. ‘Tho seond atchment tothe Janay 30 emul yas abid fora Distt 11990 renovation "project and is incorporated below,Manayunk Construction & Development Corporation To ‘Ar Cals Wood APSCLE LOCKL (1950 318 Waste Piadlpl,Po 1007 hip To: AFSCMEE LOCAL 11590, 1119 Wale Sep ‘Mindi (9107. Be 3ot27 HoT SO a517 Ps 2679002830 Cal 25.778 1068 avoir No8504 Swen ID: 199 InvoiceSSA Smith informed the Grand Jury that the physical mailing address listed for the company was not legitimate, the website for the company contained a misspelling of the word “construction,” and the website link was not a valid internet address, ‘Three weeks after Hardy emailed the estimate, a District 1199C execative meetiag was hold on February 21, 2019. According to individuals present atthe meeting, and as memorialized {n the meeting’s minutes, Woods informed the Executive Boatd that he was gathering bids fram ‘various companies to renovate the union's ber atea, Stanford, the Secretary~Treasurer atthe time, informed the Grand Jury that che was typically responsible for gathering bids for renovations to the union hall, but that Woods took direct oomtro{ over the process. ‘The Grand Jury learned that just moments before the February 21 meeting, Hardy sent ‘Woods three bar renovation bids via eiuail, One bid was from Maneyuak Construction, which increased ite bid to $139,790, The line items for this bid Wore almost entirely identical to the previous one, but the cost of each ftom was increased by thousands of dollars, “Lhe othar two bids ‘were purportedly submitted by two different companies and represented “competitive” bids. Upon inspection, however, the Grand Jury observed that theso latter two bids were facially fraudulent and were submitted in order to ensure thet Maitaytink Coostruction’s new, much higher bid was, atl the lowest ané and therefore enabled the company to be awatded the contract, The following are the three bids with the obvious issues identified by the Grand Jury notated:‘Thelettetbead is | { “Tim Kovaios”isapelied | | District 1]99C’s address "|| The invoice states the same style three different ways (Tim |] is 1319:Looust St, The payments ate to be sent utilized by Monroe || Kovacs co-owns ‘wrong address is used on || to Manayunk Press: : ‘Manayunk Construction), |} all three invoices. This | Construction. The bank same incorrect address is || account listed is also typically used 00 Mt Hardy's other invoices, |} Constructions bank nocovint @ @ a . 1 N voo t\e mete BU To: Carter Bae” arsemeLocat ti}ge Biase! 4249 Walt street Phiadelpia, Pe 19107 near eansw at oncwscranoy wn] tery | mate fs aovmynanacesor ovens rs fseassus t Tan Tf WER TOTAL ARAARO CTR Bons n oe ove q fac rooa ss639 1: snare af WL aKANO RAN [asena7 z eBaEA Tore fons PA conMERICAL SE saris z canrarean olor ets eran stuaarae q nas raiser : raw fiaarsae a AON CERETRUCTONA DEVRAPFEN subtotal [siearneoo anno anew | Sau EMITTANCE stoner oe 2882 Fomine Dect ‘iasarade Gece le ouverte ‘TIM KOVACS CONTRACTING {4090 Pda 18127Tavoioe utilizes the ‘same incorrect address noted inthe other “Gressen” is misspelled in the “Ship To” line ‘The phone number is the same number from Manayuck Consteuction’s Invoice iwowan 12568 fnvolebate 25/19 [custamerio _sab0c 40Invoice ante: Sip te ace No:404 ‘ie Ce Woe APSCME LOCAL 1980 ‘ABO LOCAL 11986 Hl Suet 1 [DU Waknt Seem Pidgin 0167 Codes TLE Paap 1108 Jn addition to these a ured flags and indicia of ftand, the Cand Jury alsa learned that. all of the metadata for the three estimates weto authored by “Press,” the same author of all of the other invoices from Manayunk Construction and Monroe Press that Hardy sent to Woods. The nGrand Jury also observed that all three bids were in the form of Microsoft Word documents and could be easily edited. . ‘The Grand Jury leamed that Gressen Properties is an aotoal company located in the Philadelphia area, SSA Smith spoke with representatives of the company who confirmed that the company never submitted the above bid, Representatives further advised that they do not pecform * this typo of work, ‘Kovacs informed the Grand Jury that he submitted on estimate-of approximately $40,000 * to Hardy to perform the bar renovation at the union hall, Kovacs testified that his estimate closely rmistored the first bid that Hardy hed sent to Woods in January 2019, However, Kovacs stated that he did not oeate any ofthe subsequcat bids forthe bar renovation that Hardy submsited to Woods including the second Manayunk Construction bid or the “Tim Kovaics” bid. Kovacs Imew that Hardy and Woods were fiiends and that Woods wies Hardy’s Distiot 1199C oontact, Kovaos ‘farther testified that he was aware that Hardy was preparing false bids to submit to District 1199C {in order to rg the bidding proces so that Manayenk Construction would be awarded the work, Kovacs provided a company name, Gressen Properties, to essist Hardly with the creation of the false bids, Kovacs asserted that he was not made aware ofthe inflated $139,790 price forthe bar renovation, oven during his conversatin with Hardy about eating the false bids. Kovecs testified he did not peform any of the work on the projeot, nor was he aware that Hardy had moved forward with the renovation until after it was finished. The Grand Jury leamed that there was no evidence that Kovacs received any of the proceeds from the bar renovatioa, In addition, the Grand Jury Joamed: that Hardy sent an email communication to Kovecs on August 30, 2019 wherein be specifically stated that he did the union hall job project on his own without any help from Kovacs, 12‘The Grand Jury learned that on March 18,2019, Woods directed Kim Kinsler, an executive sssistant, to conduct an Bxeoutive Board teléphone poll to approve the renovation of the District 1199C bar. Kinsler testified that Woods provided her with physical copies of three bids and she typed the companies and their bid amounts on the below E-Board polling record; 1199C RXECUTIVE BOARD POLLING ot ‘March 18 2019 ‘Quetian) Approval: Refurblah 1199C Talon Bae Ares upon revlew of (3) blda (Manayunk Constaston $5000 ne Repri SMTasonRn IeAES Kinsler, at Woods's direction, cointacted the board members to collect their votes and ‘Manayunk Construction was awarded the contract, Though the amounts of each bid desoribed in the 1199C Brecutive Board Potting document match each of the bids Hardy emailed to Woods, the names do not match; Hardy created two sham bids, ftom “Tim Kovaics” and Gressen Properties, Atsome point before Woods rasmitted the bids fo Kinsler, he apparently realized that the "Koval" bid as to obilousy false, since Kovacs was Hardy's partner at Manayunk Construction, Beoause the documents were ia Microsoft Word format, the “Tim Kovaics” bid was apparently altered to “Kirk Richards,” to preserve the illusion thet this was actually an Independent bid separate from Manayunk Construction. Tntotal, District 1199C pald Hardy a total of $141,421.84 for the bar renovation. The chart below summatizes the payments, Cheek wack Amount Check 4049 — Manayunk $5,208.50 Construction 134PAROID | Checkc# 4065 ~ Manayunic $41,596.40 Construction . S709 | Check 4072 - Manayunk $6,596.94 Construction Total Sai 4 Despite the alteady inflated price, Manayunk: Construction received additional payments for the work on the renovation, On Aptll 29, 2019, Hardy emailed Woods an invoice totaling $12,680.84, The invcice stated that the work was for “Looal Healt Care Union Hall Bar Area,” ‘Woods submitted a check voucher request and he signed the check the next day, On May 9, 2019, Hardy sent Woods an invoice via emall for varios bar and building supplies that totaled $11,561.32, Once again, Woods submitted a check voucher request sad then'signed tho issued cheak, On May 21, 2019, Hardy sent Woods an email with the subject line “Outstanding Work Ordet.” Attached was an involes for $17,509, A check voucher request was aubchitted and a check ‘was issued and signed by Woods that same day, ‘With respect to the $9;500 for “permit fees” and “union services” in the second bid from Manayunk Construction, the Grand Jury leamed there were no permits issued ftom the Philadelphia Department of Licenses and Inspections related to any of the work perforred, inching the clecroe plumbing, and gas tine work that were normally required. Though the line tem also ialuded “union services” Manayunk Consvuston was not 1 unjon-atilisted ‘construction company.and the individual hired to conduct most of the work was not a union labore, | ‘The Grand Jury reviewed records and heard testimony from individuals who worked on the renovation project, The work and cos of the work performed oa the bar area was in ine with the intial estimate of $47,490 less thea one thi of the inflated cost Woods paid out o Hardy, 4In total, Woods irestd Distt 11990 to pry Hardy ove $150,00 forthe bar renovation, The investigation revealed that a primary motivation behind the fraudulent activity was to deoretly pay Hardy for political services, not cosstruotion servises, and to provide funds and resources to ‘support Hasdy and Woods’ chosen political candidates in the 2019 Democratio primary election, ‘Though providing political fuads was one clear reason, Hardy and Woods both personally profited from the scheme as well, as discussed below, 1d Unveported Electior ‘The year 2019 was a municipal election year and Distiet 1199C endorsed a slate of ‘candidates in the primary eléction, There was one candidate endorsed by District 1199C with whom Wood shared strong eonnections, Th Grand Jury Teamed that unions can provide political assistance during an election cycle in two significant ways, The firsts galvanizing membership to conduct telephone banking, eanvassing, and other get-ont-the-vote (GOTV) activities. The second fs that unioos may provide dret financial politcal support tough the use of Political Action Committees (PACS), Union members may provide finds to PACs which can then be wiiized to directly donate to political candidates or other PACS, However, Pennsylvania law does not permit ‘unloins to coordinste and directly fund political campaigns fiom their general coffers. PACs must be funded by separate contibutions from the members, In 2019, District 1199C had a substantial number of members who could perform GOTV activities; however, they did not have significant PAC funds, and could not legally move general ‘ands into a PAC, One ivitaess familiar with poliice and District 1199C testified thatthe union's PAC was a “nothing” PAC, In the two months before the 2019 Democratic primary election, District 11990’s PAC account never contained more then approximately $3,500, Accordingly, 1sDistrict 1199C was eubstantially ited in ts ability to legally provide financial conixibations to essiat their endorsed candidates” campaigns ; The Grand Jury tavestigation revealed that Woods was oleerly aware of the lack of funds ~ in the PAC account, On December 11, 2018, Woods sont an email to several union administrators titled “2019 PAC Fund Conttibutions” wherein he proposed that they should ask members to donate to the PAC fund, Woods wrote “I know it?s never easy to ask the members to have more deductions come out of thére take home pay but we hve to dare to be great and get stronger politically statewide on both sides of the bxidge.” A review of the District 1199C PAC fimd bank aboount revealed that there was no significant increase inthe funds coming into the account after this email, ‘The Grand Jury investigation revealed that Woods utilized District 11990’s membership ues to find political work, which i illegel, Witnesses fimiliar with Philadelphia politics testified ‘that Hardy had a long and successful career ag a political operative and consultant, However, there ‘was no indication on the LM-2 financial disclosure form, a federally mandated form submitted to ‘the U.S, Department of Labor, that he wes ever paid as «politcal consultant before 2019, Yet, on November 1, 2018, Hardy sent Woods an e-mail titled “election operations."! Attiched was a {$6,500 invoice from Monsoe Press for “Campaign services, coordinating, supervising regional operations.” A check was subsequently ismued to Hardy from District 11990's general fund, Yet oon the LM2 form, it was indicated that this payment to Montoe Press was for ‘promotional items” with no mention of political activity, ' The 2018 general election was held on November 6, 2018, 16‘The Grand Jury finds that Manayunk Cobsteuction was largely a finaticial pass-through for Monto Press, Hardy owned bank sccouols for both, tthe ame ban, When finds were pe to ‘Manayunk Construction from District 1199C in 2019, Hlerdy almost immediately transferred most of them to the Monxoe Press bank socount, where the money was often commingled with payments ‘froma campaigns for political work, as demonstrated by the following table: ‘Table of Seleet Maviayunk Construction Bank Aecount Activity Dale Deposit “Transfer Amount WaaAOis | Disvict 1199C Checks 01s $4,116 WI5/A015 Transfer to Monroe [$4,110 5 Press WIRD | Distelet 1199C Checks 4049 $53,208 Manayunk Construction Deposited. Directly into Monroe Press, Account MISAOS | — Diskiot 1199C Check 4054 $9.73, 4/19/2019 | Distriot 1199C Checks 4062 $5,000 “4722/2019 “Fioster to Momos | $5,182 ree a ———————————— 4/25/3019 | Distict 1199C Cheol 4065 $41,596 4/25/2019 | District 1199C Checks! 4068 $200 47672019 ‘Transfer to Monroe | $41,700 Press aAO/R019 | Distick 1195 Check 4071 312,586 ‘SPAY “Transfer to Monmoe | $12,783 Press BoROIS | Distict 11950 Checks 07 $45,596 5/8/2019 “|” Transfer to Monroe | $46,586 Press ‘GFA | Distict 1199C Check 1054 a S154 T2019 Transfer © Monroe | $15,591 . Press ‘The Grand Jury's Investigetton found that the thming of pertinent polttioal ematis and messages along with the submission of invoices for work on the bar renovation revealed «. conspiracy to provide Hardy with funds for political consulting and other political ‘work. 7‘Communications uncovered during the investigation indicated that Woods supported providing Hardy with pay and resources for work on the upcoming 2019 democratic primary. ‘The Grand Jury reviewed a series of text messages sent in a group-ext among Hardy, ‘Woods, and two other individuals associated with other unions. On February 25, 2019, Hardy ‘texted this group @ pies to be appointed to Philadelphia Mayor Jim Kenney's re-election campaign, ‘Hardy wrote: After our conversation yesterday, I hnd to review all the angles, For me running Kennedy’s{sie] re-election stuff tops it all. If 'm the field direotor with a real budget this helps (two other candidates running in 2019 Philadelphia elections) as well assets sme up for the presidential This also send a message to our commumity that you and ‘Woods are joined atthe hip to move our folks forward. If is perceived that I am one of the best then you guys should put the best in position to win and in the best position to bring resources to our people... You guye should lot me go or let me fly, I've bean in tho game for oyer 25 years demand the vse tat T aked for because I pt in the time and I deliver every single time, ‘Woods responded to the above text messago with “I 100% back your play,” When one. person responded that “es long as we win,” Hardy responded by sfating, “We will I promise that Just need iny team to give me the resoutces and manpower and we will all win.” The Grand Jury heard from individuals who were a part of this text message exchange who testified thet Hardy ‘was not awarded the position with Kenney’s campaign. (On March 12, 2019, a special election was beld in Philadeiphia for the 190" Legislative istriot, That same day, Haidy sent Woods an e-mail titled “campaign GOTV” with an attached Montoe Press invoice for “Campaigh services, coordinating, supervising regionsl operations” in the amount of $1,500. The invoice was paid though the union's PAC fund which had sufficient funds atthe time to cover the expense. On Marci 18, 2019, Woods seat a text to Hardy end the other ualoc-affiliated individuals and wrote, “Fellas now that the special electio is behind us can we meet to disouss this coming 18primary on Wednesday @12 noon? At 1199C" A meeting was agreed upon and Handy seat the following text message that same day: “We aro all filends and colleagues ifsc) when we get together we sometimes lose focus of what the a gender{sic] is so let's stick to what time table ‘Someone tulcng notes and have afsic] Agenda laid out so we all leave with homework.” ‘The above text exchange occured on the same day that Woods directed Kinsler to conduct the polling for the bar renovation bids, The other union-affiliated individuals indicated tat they had various meetings with Woods to coordinate political stratees between their unions leading ‘up to the 2019 Democratic primary election, In their testimony, they stated that Hardy attended those meetings as Woods's and District 1199C's political consultant. These other individuals testified they weie not aware of, nor involved in, how Woods pad for Hardy's services, Payments for additional work on the bar area also coincided with other political activity and messages, On April 26, 2019, Hardy sent Woods an email titled “GOTY plan” stating “here isthe plan for e-day that wo need funded." Attached to the emai was a document detailing Montoe. Press's sevies forthe Detsocriticpximary election a tice tag of $10,000 per candidate and requesting a check by May 1. Three days later on April 29, Hardy sent Woods an invoice via email ‘which detailed approximately $10,000 worth of work on the bar renovation. including eleottical ‘wotk ("Remove electrical panel search for ine and remove”), gas line work (“Repair shut off valve and pipes”), and plumbing work (“replaced water/dtain ines”), Woods submitted a check voucher ‘request that same day and then signed a check issued to Manayunk Construction by District 1199C. Onthe motning of May 21, the day ofthe primary election, Had sent Woods an email ‘which stated, “please process this final order,” Attached was a Word document titled “1199C BAR, INV3." This invoice, however, specified that a $17,509 payment was to be made to Monroe Press, ‘The invoice commingled charges for t-shirts, bar construction work, and political consulting, Once 19