UNITED STATES
DISTRICT COURT WESTERN DISTRICT OF
TEXAS EL PASO DIVISION
UNITED STATES
OF
AMERICA, Plaintiff, ANTONIO REYES, Defendant THE GRAND JURY CHARGES
THAT:
§
§ §
§
§ §
§ § § §
JUDGE
KATHLEEN
CARDONE
2873
NOy 6
p
3:
1ESTp
JSTRICTCOU
Rv
OF
SEALED
INDICTMENT
EP- 13-CR- [Violation:
Count
One:
Title
18
U.S.C.
§
1343, 1346
and
1349,
Conspiracy
to
Commit Wire Fraud
and the
Deprivation
of
Honest Services.I
Introduction
At
all
times relevant
to
this Indictment:
E1.
3CR2384
1.
Defendant,
ANTONIO REYES,
was employed
by
the County
of
El
Paso, Texas and serving the citizens
of
El
Paso County, Texas.
2.
Vernon s
Texas Statutes
and Codes Annotated, Penal Code, Section 36.02
(a)(I),
provides:
A
person commits
the offense
of
bribery
if
he
intentionally
or
knowingly
offers, confers, or
agrees
to
confer on anothei, or solicits, accepts, or agrees to accept from another
any
benefit
as
consideration
for the
recipient s
decision, opinion, recommendation, vote, or other exercise
of
discretion
as a
public servant...
COUNT ONE
(Title
18
U.S.C.
§
1343, 1346
and
1349)
The
Introduction
set
out above
in
this Indictment
is
incorporated
by
reference
in its
entirety
as
if
fully set out herein.
Case 3:13-cr-02384-KC Document 3 Filed 11/06/13 Page 1 of 3
Beginning
on
or
about
March
30,
2011, and
continuing thereafter
until on or about April
15,
2011,
in
the
Western District
of
Texas
and
elsewhere, the defendant,
ANTONIO REYES,
knowingly conspired
and agreed with other
persons both known
and
unknown
to the
Grand Jury,
to
commit
the
following offense, that
is,
Wire Fraud,
in
that the defendant conspired with others known
and
unknown
to
the grand
jury
to
knowingly devise
a
scheme and artifice
to
defraud
the
County
of
El
Paso, Texas, and
the
citizens
of
El
Paso County, Texas living and voting
in
El
Paso
County, Texas
of
the intangible right
to
honest services
of
a
public servant,
to act
and make
decisions
on
behalf
of
the
citizens
of
El
Paso County, Texas, free from bribery,
and to
obtain money and property by false and
fraudi1ilent
pretenses
and
representations,
in
that
the
Defendant,
ANTONIO REYES,
agreed
to
accept
and
accepted bribes
in
the form
of
cash money from persons known
to
the Grand Jury
in
exchange
for the
Defendant,
ANTONIO
REYES
preparation, filing
and
support
of
Motions
to
Dismiss
in
criminal cases pending against those persons known
to the Grand
Jury and for the purpose
of
executing
and attempting to execute such scheme and artifice the Defendant,
ANTONIO REYES,
and others known
to
the Grand Jury did
transmit
and cause
to be
transmitted
in
interstate commerce
on or
about the dates
listed
below,
by means
of
a
wire
communications,
as
dscribed
below,
a
writing,
sign, and signal for the
purpose
of
executing
such scheme and artifice
to
defraud:
Date Item Sent
Interstate
Transmission Method
March
31, 2011
Text Message
.
ElPas,
Texas through Sandy Springs, Short Messaging Georgia;
or
Snoqualmie, Washington
to Service (SMS)
El
Paso, Texas April
4,
2011
Text Message
El
Paso, Texas
through
Sandy Springs, Short
Messaging Georgia;
or Snoqualmie,
Washington
to
Service (SMS)
ElPaso,
Texas
April
8,
2011
Text Message
El
Paso, Texas through Sandy Springs, Short Messaging Georgia; or Snoqualmie, Washington
to
Service (SMS)
El
Paso, Texas
2
Case 3:13-cr-02384-KC Document 3 Filed 11/06/13 Page 2 of 3
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