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Text of Campbell indictment


Published on: 08/30/04

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

CRIMINAL INDICTMENT NO. 1:04-CR-424

UNITED STATES OF AMERICA v. WILLIAM C. CAMPBELL

 

UNDER SEAL Aug. 18

UNSEALED Aug. 30

THE GRAND JURY CHARGES THAT:

COUNT ONE (RICO)

1. At all times material to this Indictment:

 

Background

(a) The City of Atlanta ("the City") was a unit of local government and a political subdivision of the State of Georgia. The City received Federal assistance in excess of $10,000 during each of calendar years 1996 through 2001. The City provided services to its citizens through various departments and offices in the executive branch of the City. The executive branch of the City was headed by the office of the Mayor (the "Mayor"). The duties and responsibilities of the Mayor included supervision of all the executive officers and employees of the various executive departments and offices of the City.

(b) Defendant WILLIAM C. CAMPBELL ("CAMPBELL") was elected to serve as the Mayor in November 1993, and was re-elected in November 1997, after a runoff election. He held the position of Mayor from January 1994 through January 2002 and received an annual salary of approximately $93,000, as well as other City benefits.

(c) In discharging their public duties, the executive officers of the City, including the Mayor, were bound by certain laws, ordinances, ethical requirements and duties, including, but not limited to, the following:

(1) by virtue of their positions, the Mayor and other executive officers and employees of the City inherently owed a duty to provide honest services to the citizens of the City and to act in the citizens' best interests;

(2) pursuant to the Atlanta City Code, the Mayor was required to file annual Financial Disclosure of Income Sources Statements with the Municipal Clerk, wherein the defendant was obligated to disclose, among other things: (i) each source of annual income in excess of $1,000 in the preceding calendar year; (ii) whether the source of such income engaged in business with the City; (iii) a detailed description of the nature of such business; (iv) any benefits derived from transactions with the City; and (v) any gratuities given by a donor or from an official or employee.

(3) pursuant to the laws of the State of Georgia, the Mayor, as a public official, was prohibited from, among other things: (i) directly or indirectly, soliciting, receiving, or accepting or agreeing to receive a thing of value by inducing the reasonable belief that the giving of the thing of value would influence his performance or failure to perform any official action; and (ii) accepting a monetary fee or honorarium in excess of $101 for a speaking engagement, or other activity, which directly relates to the official duties of that public officer or his office.

(4) pursuant to the laws of the State of Georgia, the Mayor was required to file annual Financial Disclosure Statements with the Elections Division of the Secretary of State and the Municipal Clerk, wherein the defendant was obligated to disclose, among other things: each monetary fee or honorarium of $101 or less from speaking engagements or other activities which directly relate to the official duties of defendant or his office (fees greater than $101 are prohibited).

 

The Enterprise

2. At all times material to this Indictment, the City, including its various executive departments, offices and employees, was an "enterprise," as that term is defined in Title 18, United States Code, Section 1961(4), which was engaged in, and the activities of which affected, interstate commerce. Defendant WILLIAM C. CAMPBELL participated in the operation and management of the enterprise.

 

The Racketeering Violation

3. Beginning at least in approximately 1996, and continuing until at least January 2002, in the Northern District of Georgia and elsewhere, WILLIAM C. CAMPBELL, defendant herein, being a person employed by and associated with the enterprise identified above, namely the City of Atlanta, including its various executive departments, offices and employees, which engaged in, and the activities of which affected, interstate commerce, together with others known and unknown to the Grand Jury, unlawfully and knowingly conducted and participated, directly and indirectly, in the conduct of the enterprise's affairs through a pattern of racketeering activity, as set forth below.

Defendant CAMPBELL's Objective

4. It was defendant's objective to conduct and control the business and affairs of the City, directly and indirectly through City employees, through a pattern and practice of misconduct and illegal acts, including violations of the laws of the United States and the State of Georgia, for the personal, pecuniary and political benefit of himself and others.

 

The Means and Methods of the Racketeering Activity

5. The means and methods used by defendant in conducting the affairs of the enterprise through a pattern of racketeering activity included the following:

(a) causing payments to be made and other things of value to be given to defendant and others from individuals and companies doing business with and seeking business and licenses from the City, by inducing the reasonable belief that giving such things of value would influence defendant's performance or failure to perform any official action;

(b) devising and participating in a scheme and artifice to defraud the citizens of the City by depriving them of his good, faithful, and honest services as Mayor;

(c) failing to report and disclose, as required by the Atlanta City Code, State law, and defendant's inherent duty, cash payments and other things of value defendant received while serving as Mayor;

(d) causing, encouraging, soliciting and accepting illegal campaign contributions from individuals and companies for defendant's re-election as Mayor in 1997;

(e) participating in a scheme and artifice to defraud contributors to and creditors of the defendant's re-election campaign;

(f) recruiting and causing other individuals, including City employees, to, knowingly and unknowingly, participate in the pattern of racketeering activity.

 

The Pattern of Racketeering Activity

6. The pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), consisted of the following acts:

 

Racketeering Acts One Through Three

Corrupt Payments from Computer Contractors

7. From in or about 1997 through 2004, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, an elected public official of a municipality, aided and abetted by others known and unknown to the Grand Jury, knowingly and willfully, and directly and indirectly, solicited, received, accepted and agreed to receive things of value, i.e., payments of money from computer contractors, by inducing the reasonable belief that the giving of the thing of value would influence defendant's performance and failure to perform an official action.

 

Defendant's relationship with Computer Contractors

8. Since approximately 1986, defendant has known an individual who formed a company which served as a computer subcontractor on City contracts (the "Computer Subcontractor"). Defendant and the Computer Subcontractor regularly played golf together and otherwise socialized from 1986 through 2004.

9. Defendant has known an individual who owned a computer company (the "Computer Contractor") since approximately 1993. The Computer Contractor owned and operated a company which provided computer technology services primarily to government clients. From at least 1997 through 1999, the Computer Contractor's company sought and received contracts with the City.

10. In 1997, the Computer Contractor was a member of defendant's re-election campaign finance committee. The Computer Contractor hosted a fundraiser for defendant at his company's offices in October 1997, and he contributed to defendant's campaign for re-election.

11. In November 1997, the Computer Contractor solicited his employees to make contributions to defendant's re-election with the understanding that the Computer Contractor would reimburse them for their contributions. By doing so, the Computer Contractor exceeded the legal limits for contributions to defendant's campaign.

 

The Computer Contractor and Subcontractor Business with City

12. Approximately six months after defendant was re-elected as Mayor, in or about May 1998, the City's Commissioner of Administrative Services awarded the Computer Contractor's company a contract, without competitive bidding, which was worth over $1,000,000. The Computer Contractor's company employed the Computer Subcontractor's company as a subcontractor on the contract.

13. In or about 1999, the Computer Contractor's company pursued obtaining, without competitive bidding, another contract with the City to provide services to prepare the City's computer system for Year 2000 ("Y2K contract"). In or about March 1999, the City's Commissioner of Administrative Services terminated the contract of a company providing Y2K services to the City and selected the Computer Contractor's company as the replacement. In or about March 1999, the Computer Contractor's company began performing Y2K computer services. On or about August 13, 1999, the City executed a $1,000,619 Y2K contract with the Computer Contractor's company.

 

Payments to Defendant

14. Prior to the City's execution of the Y2K contract, in or about the Spring of 1999, the Computer Subcontractor had a conversation with defendant concerning the Computer Contractor and the Computer Subcontractor providing Y2K services for the City. In response to the Computer Subcontractor's inquiry about providing the Y2K services, defendant asked, "What's in it for me?" The Computer Subcontractor replied, "Whatever it takes." Defendant indicated to the Computer Subcontractor that he would look into the matter.

15. After the Computer Subcontractor told the Computer Contractor about his conversation with defendant concerning the Y2K contract, the Computer Contractor provided cash to the Computer Subcontractor to deliver to defendant. The cash was delivered following payments from the City to the Computer Contractor's company in June and July 1999. After the City executed the Y2K contract, the Computer Subcontractor made a third cash payment to defendant in August 1999 for which he obtained reimbursement from the Computer Contractor's company under a false invoice.

 

June Payment

16. On or about June 1, 1999, the City issued a check for $400,000 to the Computer Contractor's company in payment for Y2K services, which the Computer Contractor deposited into a company bank account on June 4, 1999.

17. On or about June 8, 1999, the Computer Contractor withdrew $25,000 in cash from a company bank account and gave it to the Computer Subcontractor to deliver to defendant.

18. On or about June 9, 1999, the Computer Subcontractor delivered the $25,000 in cash to defendant. When the Computer Subcontractor delivered the cash, defendant told the Computer Subcontractor that "no one else can know about this."

 

July Payment

19. On or about July 14, 1999, the City issued a check for $943,866.50 to the Computer Contractor's company which included payment for Y2K services. The Computer Contractor deposited the check into a company bank account on July 16, 1999.

20. On or about July 21, 1999, the Computer Contractor withdrew $20,000 in cash from a company bank account and gave it to the Computer Subcontractor to deliver to defendant.

21. On or about July 22, 1999, the Computer Subcontractor delivered the $20,000 in cash to defendant.

 

August Payment

22. On or about August 13, 1999, the City executed the Y2K contract with the Computer Contractor's company in the amount of $1,000,619.

23. On or about August 19, 1999, the Computer Subcontractor had telephone conversations with defendant and the Computer Contractor about providing more money to defendant and, following those conversations, the Computer Subcontractor withdrew $10,500 in cash from his bank account.

24. On or about August 20, 1999, the Computer Subcontractor gave defendant $10,000 in cash.

25. The signed Y2K contract was transmitted to the Computer Contractor on or about August 24, 1999.

 

Concealment of Payments

26. In or about 2000 and 2001, the Computer Contractor concealed from and falsely denied to law enforcement agents and a federal grand jury that he had made any payments to defendant or any illegal campaign contributions to defendant's campaign.

27. In or about October 2002, the Computer Contractor was indicted for giving false testimony to the grand jury regarding the reimbursement of his employees for making contributions to defendant's re-election campaign in 1997.

28. In March 2003, the Computer Contractor admitted to law enforcement agents that, in addition to illegal campaign contributions, he had also made cash payments to defendant through the Computer Subcontractor in 1999.

29. When the Computer Subcontractor was first interviewed in March 2003, he falsely denied delivering the cash payments to defendant from the Computer Contractor.

30. During 2003 and early 2004, the Computer Subcontractor continued to conceal the cash payments to defendant and communicated with defendant about the government's investigation of the matter. During conversations between defendant and the Computer Subcontractor in 2003, defendant offered to help the Computer Subcontractor financially during the investigation.

31. In or about January 2004, the Computer Subcontractor asked defendant through a mutual friend for financial assistance with the Computer Subcontractor's legal expenses incurred during the investigation.

32. Following the Computer Subcontractor's request, defendant arranged for a personal friend of defendant's to pay $10,000 for the Computer Subcontractor's legal fees.

33. On or about March 25, 2004, the date the Computer Subcontractor was to be compelled to testify before a federal grand jury, the Computer Subcontractor admitted to law enforcement authorities that he had delivered cash payments to defendant in 1999 in connection with the Y2K contract.

 

Racketeering Acts One Through Three

34. Bribery. On or about the dates set forth below, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed bribery, in violation of O.C.G.A. , 16-10-2 and 16-2-20, in that as an elected public official of the City, defendant directly and indirectly solicited, received, accepted, and agreed to receive a thing of value, i.e., cash payments identified below, by inducing the reasonable belief that the giving of the thing of value would influence his performance of and failure to perform any official action:

Racketeering Act Date Approximate Amount of Payment

One 6/09/99 $25,000

Two 7/22/99 $20,000

Three 8/20/99 $10,000

 

Racketeering Acts Four and Five

Corrupt Payments from the Consultant

35. From in or about at least 1996 through 2000, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, knowingly and willfully devised and intended to devise, and participated in, a scheme and artifice to defraud the citizens of Atlanta of their intangible right to the honest services of defendant by soliciting and accepting payments and financial benefits in cash and in kind, directly and indirectly, from individuals and businesses engaged in or seeking to do business with the City. It was part of the scheme that defendant concealed and failed to disclose to the City the payments and financial benefits he received from a consultant and other City contractors.

 

Defendant's Relationship with the Consultant

36. Defendant and an individual who acted as a consultant for City contractors (the "Consultant") have known each other for many years.

37. During defendant's campaign to be elected Mayor in November 1993, and to be re-elected Mayor in November 1997, the Consultant actively participated in fundraising for defendant.

38. On or about April 18, 1994, defendant appointed the Consultant as a member of the Civil Service Board, a three-year, part-time City position. The Consultant became the Chairperson of the Civil Service Board, which held hearings concerning adverse employment matters involving City employees. On or about October 13, 1997, defendant reappointed the Consultant to the same position.

 

The Consultant's Business with City

39. While working for the City, the Consultant solicited City business as a sub-contractor and consultant. The City had previously approved the Consultant's company as a Minority Business Enterprise ("MBE") in or about January 1990. Although the Consultant's company was dissolved on or about July 17, 1994, and had no physical location, equipment or employees, it continued to be an approved City MBE. The Consultant marketed his status as an approved MBE, as well as his access to and influence with defendant, to solicit payments and personal benefits for himself and defendant from City contractors.

40. From in or about at least 1995 through 2000, the Consultant solicited business from the City on behalf of himself and other City contractors and ultimately received payments related to numerous multi-million dollar City contracts, including: (1) the Chattahoochee Clearwell ("Clearwell") contract; (2) the modernization of the 1923 Hemphill water treatment filters ("Hemphill I") contract; (3) the modernization of the 1941 Hemphill water treatment filters ("Hemphill II") contract;(4) the ultraviolet disinfection equipment contracts at three City water treatment facilities; and (5) the City water privatization contract. The City awarded the Clearwell, Hemphill I and Hemphill II contracts to contractors associated with the Consultant.

41. From in or about at least 1996 through 2000, the Consultant's primary source of income was from contractors seeking or doing business with the City. The Consultant used his relationship with defendant to obtain large sums of money from the contractors for the Consultant's own benefit. During that time, the Consultant also provided defendant with thousands of dollars in cash and other benefits to influence defendant's performance and failure to perform official action concerning those contractors.

 

Air Conditioners and $10,000 Cash

42. From in or about early Summer of 1996 through September 1996, the Consultant arranged for a construction contractor on the City Hemphill I contract ("the Construction Company") to fund a $9,581 installation of two heating and air conditioning ("HVAC") units in defendant's home and to pay defendant $10,000 in cash.

43. In or about early Summer of 1996, the Consultant asked a Construction Company representative to install HVAC units in defendant's home without charge. Although the Construction Company representative initially refused the Consultant's request, they ultimately agreed to create a false invoice on a contract with another municipality to generate funds for the Consultant to give to defendant for the HVAC units.

44. In or about Summer of 1996, a Construction Company subcontractor on the Hemphill I contract met with the Consultant at defendant's house and subsequently installed the HVAC units for $9,581.

45. The Consultant also requested $10,000 from the Construction Company to provide to defendant at an upcoming campaign event for defendant. To generate money for both, on or about September 3, 1996, a second Construction Company subcontractor faxed a false invoice to the Construction Company in the amount of $19,760, which misrepresented that the invoice was for HVAC retro-fits on a contract with another municipality. The Construction Company representative then approved the false invoice and submitted it via facsimile from Atlanta to the Construction Company's Birmingham office for payment.

46. Based on the false invoice, on or about September 13, 1996, the Construction Company's Birmingham office mailed a check in the amount of $19,760 to a subcontractor in Atlanta. On or about September 18, 1996, that subcontractor provided three checks in the following amounts to the Construction Company representative: (1) $5,089.50; (2) $5,089.50; and (3) $9,581.

47. On or about September 19, 1996, the Consultant cashed the $9,581 check. With the help of a third subcontractor, the Construction Company representative converted the other two checks, totaling $10,179, to cash on September 19 and 20, 1996, and then provided $10,000 cash to the Consultant to deliver to defendant at the campaign event.

48. On or about September 20, 1996, the date the Consultant coordinated a campaign event for defendant in Atlanta, the Consultant gave defendant the $10,000 in cash.

49. At or around the same time, the Consultant gave defendant approximately $9,581 to cover the cost of the two HVAC units.

50. As the Construction Company and the Consultant had agreed, at the September 20, 1996 campaign event, defendant paid for the HVAC units by check, which he gave to the Construction Company subcontractor who had submitted the false invoice to cover the cost of the units, to deliver to the subcontractor who had installed the units.

 

Racketeering Act Four

51. Defendant committed the following acts of racketeering activity, any one of which alone constitutes Racketeering Act Four:

(a) Wire Fraud. On or about September 3, 1996, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed wire fraud, in violation of Title 18, United States Code, Sections 1343, 1346 and 2, in that he, for the purpose of executing the above-described scheme and attempting to do so, knowingly caused to be transmitted by means of interstate wire transmission from Atlanta, Georgia to Birmingham, Alabama, a false invoice in the amount of $19,760, which was used to generate funds to cover the cost of the HVAC units installed in defendant's home and a $10,000 cash payment to defendant.

(b) Mail Fraud. On or about September 13, 1996, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed mail fraud, in violation of Title 18, United States Code, Sections 1341, 1346 and 2, in that he, for the purpose of executing the above-described scheme and attempting to do so, knowingly caused an envelope to be placed in an authorized depository of the United States Postal Service and caused to be delivered according to the directions thereon, addressed to a Construction Company subcontractor, which envelope contained a payment of $19,760, which was used to generate funds to cover the cost of the HVAC units installed in defendant's home and a $10,000 cash payment to defendant.

(c) Bribery. In or about 1996, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed bribery, in violation of O.C.G.A. 16-10-2 and 16-2-20, in that as an elected public official of the City of Atlanta, defendant directly and indirectly solicited, received, accepted, and agreed to receive a thing of value, i.e., HVAC units and cash, by inducing the reasonable belief that the giving of the thing of value would influence his performance and failure to perform any official action.

 

Other Cash Payments and Benefits from the Consultant and Contractors

52. From in or about 1996 through 2000, the Consultant continued to solicit and receive payments from City contractors with the understanding that the Consultant would deliver some of the money and provide other benefits to defendant to influence his performance or failure to perform official action concerning those contractors.

53. On or about March 21, 1996, the Consultant received a $10,000 check from a subcontractor on the City Clearwell contract. A week later, on or about March 29, 1996, the Consultant coordinated a campaign event for defendant in Atlanta. On or about the same day, the Consultant paid defendant $10,000 in cash and he and defendant flew to New Orleans, Louisiana for another campaign fundraiser for defendant.

54. In or about February 1997, when a water filter company was seeking the Hemphill II contract, the Consultant requested an executive of that company (the "Water Filter Company executive") to exchange a $25,000 check for $25,000 cash with the understanding that the cash was to be used for the Consultant and defendant. After cashing multiple checks on or about February 14, 1997, under $10,000 to avoid IRS reporting requirements, the Water Filter Company executive provided the Consultant with $25,000 cash. The next day, the Consultant and defendant traveled to Memphis, Tennessee, a frequent destination of defendant's for gambling in nearby Tunica, Mississippi. A couple of weeks later, on or about February 28, 1997, the Consultant and defendant traveled to another gambling destination, Hollywood Casino in Robinsonville, Mississippi.

55. On or about March 4, 1997, the Consultant solicited another cash exchange from the Water Filter Company executive with the understanding that the cash was to be used for the Consultant and defendant. After cashing a check for $8,500, the Water Filter Company executive provided the Consultant with $8,500 cash.

56. On or about May 30, 1997, the Consultant paid defendant $4,000 in cash around the time of another campaign event.

57. From in or about July 1997 through September 1999, the Water Filter Company executive provided payments by hand delivery and by United States mail to the Consultant to facilitate business with the City. Specifically, on or about January 22, 1998, February 26, 1998, March 31, 1998, April 30, 1998, June 12, 1998, August 4, 1998, November 25, 1998, and September 9, 1999, envelopes containing Water Filter Company checks payable to the Consultant's company in the amount of $5,000 were mailed by the United States Postal Service and delivered to the Consultant in Atlanta.

58. In or about early 1998, the Consultant solicited additional money from the Water Filter Company with the understanding that the Consultant would provide some of the money and other benefits to defendant in connection with a sole-source contract on the Hemphill II project. The Consultant and the Water Filter Company executive agreed to inflate the cost of the contract to cover the payments to the Consultant. Ultimately, in or about April 1998, the City awarded a sole-source purchase order to the Water filter Company, which was inflated by $400,000. The Water Filter Company then made payments totaling $400,000 to the Consultant as the City paid the company.

59. On or about July 14, 1998, the Consultant received a check in the amount of $15,000 from another contractor which was seeking the Consultant's help in getting the multi-million dollar City water privatization contract. About a week later, on or about July 24, 1998, the Consultant solicited and received an additional $2,500 from that contractor to provide to defendant for gambling. The next day, on or about July 25, 1998, the Consultant paid for defendant's airline tickets and traveled with defendant to Memphis, Tennessee.

60. In or about August 1998, while the Water Filter Company was working on the Hemphill II project, the Consultant solicited and received $5,000 in cash from that company for a gambling trip with defendant. After an initial postponement of the trip, on or about October 1, 1998, the Consultant, defendant and the Water Filter Company executive flew to Memphis, Tennessee and then traveled to Tunica, Mississippi, where defendant stayed and gambled. The Consultant paid for defendant's airline tickets and his hotel in Tunica.

61. On at least eight other occasions, while seeking City business and receiving money from City contractors, the Consultant traveled with defendant from Atlanta to Memphis, Tennessee, on or about January 1, 1996, October 1, 1998, December 17, 1998, December 30, 1998, March 26, 1999, April 1, 1999, August 28, 1999, and September 20, 1999. The Consultant paid for defendant's airfare for at least six of those trips.

62. On or about January 5, 1996, August 4, 1998, October 23, 1998, December 23, 1998, March 24, 1999, and September 22, 1999, envelopes containing American Express bills, which included round trip air fare the Consultant purchased for defendant, were sent via the United States Postal Service and delivered to the Consultant, who subsequently paid the bills.

63. In or about January 1999, the Consultant solicited $5,000 to take defendant gambling from a contractor which had recently received the City water privatization contract.

64. In or about 1999 through March 2000, the Consultant and the Water Filter Company executive continued to discuss additional potential City projects with the understanding that money for the Consultant and defendant would be built into the contracts. In or about March 2000, the Consultant confirmed to the Water Filter Company executive that money had gone to defendant and that defendant was waiting to be told what the Consultant and the Water Filter Company needed concerning City projects.

 

Defendant's Failure to Disclose Cash and Benefits

65. Defendant failed to disclose to the City, or publicly to the citizens of the City, his receipt of money and other things of value from the Consultant and other City contractors.

66. On or about June 21, 2000, the Consultant was indicted on federal income tax violations involving money he had received from City contractors. Immediately after the indictment, on or about June 22, 2000, defendant publicly and falsely stated "I know virtually nothing about [the Consultant's] business life."

 

Racketeering Act Five

67. Defendant committed the following acts of racketeering activity, any one of which alone constitutes Racketeering Act Five:

(a) Mail Fraud. From in or about 1996 through in or about 1999, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed mail fraud, in violation of Title 18, United States Code, Sections 1341, 1346 and 2, in that he, for the purpose of executing the above-described scheme and attempting to do so, knowingly caused envelopes containing American Express bills, which included round trip air fare the Consultant purchased for defendant, to be placed in authorized depositories of the United States Postal Service and caused to be delivered according to the directions thereon to the Consultant in Atlanta, Georgia.

(b) Mail Fraud. From in or about 1998 through 1999, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed mail fraud, in violation of Title 18, United States Code, Sections 1341, 1346 and 2, in that he, for the purpose of executing the above-described scheme and attempting to do so, knowingly caused envelopes containing Eco-Tech checks payable to the Consultant's company in the amount of $5,000 to be placed in authorized depositories of the United States Postal Service and caused to be delivered according to the directions thereon, addressed to the Consultant in Atlanta, Georgia.

(c) Bribery. Between in or about at least 1996 through 2000, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed bribery, in violation of O.C.G.A. 16-10-2 and 16-2-20, in that as an elected public official of the City of Atlanta, defendant directly and indirectly solicited, received, accepted, and agreed to receive a thing of value, i.e., cash payments identified below, by inducing the reasonable belief that the giving of the thing of value would influence his performance of and failure to perform any official action.

Racketeering Acts Six and Seven

Corrupt Payments From Club Owner and Communications Contractor

68. Between in or about at least 1996 through in or about 1998, at Atlanta, Georgia, and elsewhere in the Northern District of Georgia, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, knowingly and willfully and directly and indirectly, solicited, received, accepted and agreed to receive things of value, namely payments of money from individuals and companies seeking business with and licenses from the City, by inducing the reasonable belief that the giving of the things of value would influence defendant's performance and failure to perform an official action.

 

Defendant's Relationship with his Special Assistant

69. Defendant has known an individual who defendant hired to be his Special Assistant (the "Special Assistant") since approximately 1985. 70. In or about 1993, defendant hired the Special Assistant to work on defendant's campaign for Mayor.

71. In or about 1993, the Special Assistant moved into a basement apartment in defendant's home and lived there for over six years, from in or about 1993 to in or about 1999.

72. Following defendant's election as Mayor in 1993, defendant hired the Special Assistant as an employee of the City and he acted as the Special Assistant to the Mayor from in or about January 1994, to in or about May 12, 1999.

73. The Special Assistant's office was within the Mayor's suite at City Hall. His official duties included opening mail and responding to citizen complaints. Defendant primarily used the Special Assistant, however, to perform personal tasks for defendant, many of which required trust and discretion, such as making deposits into defendant's personal bank accounts; delivering cash for payment of certain of defendant's bills; purchasing cashier's checks for defendant with cash; making hotel arrangements for personal friends; and transporting personal friends to and from the hotels.

 

Defendant's Relationship with Club Owner

74. In or about 1997, an individual who owned and operated adult entertainment clubs in Atlanta (the "Club Owner"), had and was seeking liquor licenses from the City.

75. Liquor license applications, renewals and revocations were reviewed by the City License Review Board, which made an advisory recommendation to the Mayor. The Mayor had sole discretion, however, over all liquor license applications, renewals and revocations.

76. On or about March 26, 1997, the Club Owner, who was operating establishments with liquor licenses issued by the City, applied for a new license for an adult entertainment club (the "New Club").

77. In or about 1997, the Club Owner was seeking defendant's assistance in connection with the liquor license application for the New Club and a renewal for an existing club (the "Old Club"). During that time, defendant was running for re-election as Mayor.

78. In or about July 1997, defendant and the Club Owner discussed the Club Owner's desire to obtain defendant's assistance with the liquor licenses. Defendant advised the Club Owner that, if the Club Owner would help defendant with his re-election, defendant would assist the Club Owner with liquor licenses after the election.

79. Following defendant's discussion with the Club Owner, defendant tasked his Special Assistant with collecting cash payments from the Club Owner. From in or about July 1997 through September 1998, the Club Owner made cash payments to the Special Assistant and to the defendant through the Special Assistant. The amounts of the individual payments for defendant varied between approximately $5,000 to $10,000 and totaled at least approximately $50,000. Defendant did not give the cash to his re-election campaign.

 

Political Pressure on Defendant

80. On or about September 24, 1998, the License Review Board recommended that the Old Club's license be renewed.

81. Although the License Review Board had recommended renewal, defendant encountered continuous political pressure to deny the Club Owner's liquor licenses.

82. By late February or early March 1999, defendant demanded that the Club Owner withdraw his application for a liquor license for the New Club or defendant would revoke the Club Owner's liquor license for the Old Club. In light of the money he had paid defendant and the Club Owner's investment in the New Club, the Club Owner refused to withdraw the New Club's application.

83. On or about March 4, 1999, the Club Owner's attorney sent a letter to defendant memorializing defendant's demand that the Club Owner withdraw his liquor license application for the New Club or defendant would revoke the Club Owner's liquor license for the Old Club.

84. On or about April 12 and 14, 1999, the License Review Board held a hearing on the Club Owner's application for the New Club's liquor license.

85. In or about early May 1999, the Club Owner advised a former Assistant City Attorney that he had paid money to defendant through the Special Assistant for defendant's assistance with his liquor licenses and that defendant had bowed to political pressure and failed to assist the Club Owner. In or about early May 1999, that information was conveyed to the City Attorney, who in turn advised defendant that the Club Owner had stated that he had paid defendant through the Special Assistant.

86. On or about May 10, 1999, defendant revoked the Club Owner's liquor license for the Old Club, in contravention of the Board's recommendation.

87. On or about the same day, the License Review Board publicly recommended that defendant deny the Club Owner's liquor license application for the New Club. On or about September 7, 1999, defendant denied the New Club's license.

Racketeering Act Six

88. Bribery. In or about 1997 and 1998, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed bribery, in violation of O.C.G.A. §§ 16-10-2 and 16-2-20, in that he knowingly and willfully and directly and indirectly, solicited, received, accepted and agreed to receive things of value, i.e., cash payments from an individual seeking licenses from the City, by inducing the reasonable belief that the giving of the things of value would influence defendant's performance and failure to perform an official action.

 

Payments From the Communications Contractor

89. At all times relevant to this Indictment, an individual who was the President of a communications company (the "Communications Contractor") sought to do business with the City.

$5,000 "Speaking Fee"

90. In or about 1996, while the Communications Contractor was doing business with the City, the Special Assistant arranged for the Communications Contractor to pay defendant $5,000 to speak to a group of the Communications Contractor's employees at lunch.

91. On or about June 26, 1996, defendant spoke to the Communications Contractor's employees at his company's office for approximately thirty minutes. At the conclusion of the speech, the Communications Contractor paid defendant $5,000 with a check drawn on the communications company account. Defendant endorsed the check and it was deposited into defendant's personal bank account.

92. Defendant did not disclose to and otherwise concealed from the citizens of the City that he had received $5,000 from the Communications Contractor.

 

Cash for Travel Expenses and Gambling Money

93. In or about 1996, defendant directed the Special Assistant to obtain money from the Communications Contractor to be used to pay for travel expenses for a personal friend of defendant.

94. The Special Assistant obtained approximately $1,000 from the Communications Contractor that was then used to cover part of the travel expenses for defendant's friend.

95. In or about December 1997, following the run-off election, defendant advised the Special Assistant that he was going on a gambling trip and asked the Special Assistant to obtain additional cash from the Communications Contractor.

96. At defendant's instruction, the Special Assistant went to the Communications Contractor's home, obtained approximately $4,000 in cash from the Communications Contractor, and delivered the cash to defendant. During this same time period, the Communications Contractor also provided cash to the Special Assistant.

 

Racketeering Act Seven

97. Bribery. In or about 1996 and 1997, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed bribery, in violation of O.C.G.A. §§ 16-10-2 and 16-2-20, in that he knowingly and willfully and directly and indirectly, solicited, received, accepted and agreed to receive things of value, i.e., payments of money from an individual and/or a company seeking business with the City, by inducing the reasonable belief that the giving of the things of value would influence defendant's performance and failure to perform an official action.

 

Racketeering Acts Eight and Nine

Campaign Fund Fraud

98. From in or about 1997 through 2002, in the Northern District of Georgia and else, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, knowingly and willfully devised and intended to devise, and participated in, a scheme and artifice to defraud the citizens of Atlanta of their intangible right to the honest services of defendant, namely by causing, encouraging, soliciting, and accepting illegal campaign contributions, and to defraud contributors to and creditors of defendant's re-election campaign. It was part of the scheme that defendant concealed and failed to disclose to the City and the electorate the illegal campaign contributions.

 

Illegal Campaign Contributions Using Names of Defendant's Family Members

99. On or about November 21, 1997, a series of five "straw" contributions made in the names of defendant's family members, all of whom resided in another state, were deposited into defendant's campaign account. The five $1,000 sequentially numbered cashier's checks were all purchased in Atlanta. The campaign disclosure form listing defendant's family members as contributors and their out-of-state addresses was completed and filed, even though the family members did not fund the contributions.

 

Illegal Campaign Contributions involving the Testing Contractor and the Development Contractor

100. Defendant has known an individual who owned and operated testing and drilling companies (the "Testing Contractor") for many years. The Testing Contractor was a close friend of defendant and they regularly gambled together.

101. The Testing Contractor had substantial business with the City. His wife owned and operated a concessions company, which also had significant business with the City from at least 1995 through 2002.

102. During defendant's tenure as Mayor, defendant directly, and through City employees, acted to benefit the Testing Contractor's and his wife's companies with respect to City business.

103. In or about 1997, the Testing Contractor was a member of defendant's re-election campaign finance committee. In that capacity, the Testing Contractor was expected to raise campaign funds for the November 4, 1997, general election as well as the run-off election that followed on November 25, 1997.

104. At all times material to this Indictment, an individual who owned and operated a development company (the "Development Contractor"), sought to sell a substantial amount of dirt to the City for the fifth runway expansion at the Hartsfield-Jackson International Airport (the "dirt project").

105. In or about June 1997, the Development Contractor was introduced to the Testing Contractor, who was known to have influence with defendant. The Development Contractor met with the Testing Contractor to find out how to facilitate the City's purchase of the Development Contractor's dirt. The Testing Contractor told the Development Contractor that he would have to raise substantial money for defendant's campaign.

106. During the general election, the Development Contractor and his companies contributed the maximum amount allowed by law during an election year. In addition, the Development Contractor asked others to make contributions to defendant's campaign and then illegally reimbursed them for approximately $40,000 in illegal contributions.

107. During the general election, in or about Summer of 1997, the Development Contractor met with defendant at the Testing Contractor's office. During their meeting, they discussed the dirt project.

108. In or about November 1997, during the time between the general election and the run-off, the Development Contractor again met with defendant at the Testing Contractor's office. During their meeting, defendant talked about the run-off and his need to raise more money. Defendant told the Development Contractor to raise $100,000 for the run-off election, which was only about two weeks away. Defendant told the Development Contractor that there was nothing defendant could do to help the Development Contractor if defendant was not re-elected.

109. In or about November 1997, the Development Contractor provided the Testing Contractor with the names of the Development Contractor's friends and family members to use for additional contributions to defendant's campaign.

110. Because the Development Contractor could not come up with enough names for the $100,000 in campaign contributions defendant solicited, on or about November 12, 1997, the Development Contractor provided the Testing Contractor with $30,000 to be used for contributions to defendant's run-off campaign. The Testing Contractor used the $30,000 to reimburse his employees for contributions to defendant's campaign.

111. On or about November 17 and 18, 1997, 84 cashier's checks and money orders, many sequentially numbered, totaling approximately $56,000, as well as the names and job descriptions of 29 purported contributors supplied by the Development Contractor, were processed and deposited into the campaign account.

112. As a result of defendant's request for the Development Contractor to provide $100,000 to defendant's run-off campaign, within a few days the Development Contractor funded over $86,000 in illegal contributions.

113. In or about December 1999, the Development Contractor was awarded an emergency sole source contract with the City for $2,000,000, although he ultimately did not get the larger dirt deal that he was seeking from defendant.

 

Defendant's Concealment of Illegal Campaign Contributions

114. On or about November 24, 1997 and January 5, 1998, defendant, aided and abetted by others known and unknown to the Grand Jury, filed Campaign Disclosure forms with the City Municipal Clerk that concealed the true nature of the campaign contributions made in the names of straw donors.

 

Racketeering Act Eight

115. Mail Fraud. On or about November 21, 1997, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed mail fraud, in violation of Title 18, United States Code, Sections 1341, 1346 and 2, in that he, for the purpose of executing the above-described scheme and attempting to do so, knowingly caused an envelope to be placed in an authorized depository of the United States Postal Service and caused to be delivered according to the directions thereon to the City Municipal Clerk, which envelope contained defendant's November 21, 1997 Campaign Contribution Disclosure Report.

Solicitation of Illegal Campaign Contribution

116. In or around 1997, defendant, aided and abetted by others known and unknown to the Grand Jury, solicited illegal campaign contributions from another company seeking to do business with the City.

117. In or around 1997, a contract management firm based in Arlington, Virginia (the "Management Firm"), began pursuing a contract with the City to remedy a problem with sewer overflows polluting the Chattahoochee River.

118. A representative of the Management Firm attempted unsuccessfully to get a meeting with defendant. The Management Firm representative was then introduced to the Testing Contractor as someone who could get him access to defendant. On or about August 19, 1997, the Management Firm representative and an associate met with the Testing Contractor who scheduled an appointment with defendant for the next morning.

119. The next morning, the Testing Contractor, the Management Firm representative, and an associate met with defendant in his office, and the Management Firm representative pitched his proposal to defendant. As the Management Firm representative, his associate and the Testing Contractor were leaving the office, defendant requested to speak with the Testing Contractor privately. When the Testing Contractor emerged from his private meeting with defendant, the Management Firm representative asked the Testing Contractor what they needed to do to move forward on the proposal. After directing the Management Firm representative outside, the Testing Contractor said, "I'm not saying the Mayor said this, but $100,000 by the end of the month to the Mayor's campaign and the contract is yours whether he wins the election or not."

120. After being solicited for money in return for the contract, the Management Firm decided not to pursue the project with the City under those circumstances.

Racketeering Act Nine

121. Bribery. On or about August 20, 1997, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed bribery, in violation of O.C.G.A. §§ 16-10-2 and 16-2-20, in that as an elected public official of the City of Atlanta, defendant indirectly solicited a thing of value, i.e, $100,000, by inducing the reasonable belief that the giving of the thing of value would influence his performance and failure to perform an official action.

 

Defendant's Solicitation of Funds to Retire Campaign Debt and Personal Use of Campaign Funds

122. From in or about January 1998 to in or about 2003, in the Northern District of Georgia and elsewhere, defendant, aided and abetted by others known and unknown to the Grand Jury, knowingly and willfully devised and intended to devise, and participated in a scheme and artifice to defraud campaign contributors of money and property and the citizens of the City of defendant's honest services by misleading campaign contributors concerning the status of campaign funds and soliciting contributions from City contractors and others ostensibly to retire campaign debt from defendant's re-election campaign.

123. Defendant, through another known to the Grand Jury, misled his campaign manager and deputy campaign manager for fundraising as to the status of campaign funds following the re-election in 1997.

124. Through in or about 1998 and 1999, defendant, aided and abetted by others known and unknown to the Grand Jury, solicited and raised additional campaign funds that donors were told were needed to "retire campaign debt."

125. From in or about 1998 through in or about 2000, defendant, aided and abetted by another known to the Grand Jury, misled campaign creditors concerning the availability of funds to pay the campaign creditors.

126. From in or about 1998 through in or about 2003, defendant, aided and abetted by another known to the Grand Jury, while misleading campaign contributors and creditors as to the status of campaign funds, used funds that were received in response to solicitations to retire campaign debt for personal expenses incurred after the expiration of the campaign, including, but not limited to, sporting event tickets, Disney World tickets, personal travel, clothing, and cell phone charges.

 

Racketeering Act Ten

127. Mail Fraud. From in or about 1998 through 2003, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed mail fraud, in violation of Title 18, United States Code, Sections 1341, 1346 and 2, in that he, for the purpose of executing the above-described scheme and attempting to do so, knowingly caused solicitations to retire campaign debt; contributions to defendant's campaign; correspondence representing the status of campaign funds; and payments for personal expenses of defendant incurred after the campaign, to be placed in authorized depositories of the United States Postal Service and caused to be delivered according to the directions thereon.

 

Racketeering Act Eleven

Undisclosed Benefits from Water Company

128. From in or about 1999 through 2002, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, knowingly and willfully devised and intended to devise, and participated in, a scheme and artifice to defraud the City and its citizens of their intangible right to the honest services of defendant by soliciting and accepting financial benefits in kind from a company engaged in and seeking to do business with the City. It was part of the scheme that defendant concealed and failed to disclose to the City and its citizens financial benefits he received from a City contractor while participating in transactions during his term as Mayor of the City.

 

Water Company's Contract with City

129. On or about December 24, 1998, defendant, on behalf of the City, signed a contract with a water company (the "Water Company") to provide private operation and maintenance of the City's water system for 20 years at an annual cost of $21.4 million beginning on January 1, 1999. The Water Company's parent company was based in Paris, France.

 

Benefits for Defendant from Water Company

130. On or about June 15, 1999, a personal friend of defendant purchased an airline ticket to travel to Paris, France on July 24, 1999, for a vacation and invited defendant to go along. Defendant accepted the invitation, and, aided and abetted by others known and unknown to the Grand Jury, made arrangements for the Water Company to pay for the hotel accommodations and transportation service for defendant and the City's Chief Operating Officer (the "COO") to visit Paris between July 24 and 29, 1999.

131. From on or about July 25 through 28, 1999, defendant and the COO received and accepted from the Water Company and its parent company personal benefits totaling in excess of $12,900 for the Paris hotel rooms and a car and driver for defendant, his personal friend, and the COO, without disclosing to the City and its citizens the benefits they received.

132. From on or about July 27 through 30, 1999, the Water Company and certain of its executives and affiliated individuals wrote checks to defendant's re-election committee ranging from $100 to $1,000, totaling approximately $6,900, at a time when defendant was not eligible to seek re-election. A portion of the contributions from the Water Company executives were deposited into the campaign bank account in August 1999, but over $3,000 of the contributions were not deposited into the account until on or about September 23, 1999.

133. On or about September 21, 1999, defendant obtained from the campaign account into which the Water Company contributions were deposited a check in the amount of $1,337.98 to pay the credit card charge for his airline ticket to Paris in July 1999.

134. Between 1999 and 2001, defendant and the COO directed the Water Company to retain and pay as consultants and subcontractors certain individuals who were political supporters of defendant.

 

Defendant's Subsequent Acts to Benefit the Water Company

135. After receiving the undisclosed personal benefits from the Water Company, defendant directly and indirectly took actions intended to benefit the Water Company.

136. Between 1999 and 2001, the Water Company incurred expenses in operating the City's water system which it contended were not contemplated by the twenty-year operations and maintenance contract signed in December 1998, and the Water Company sought additional compensation from the City for these expenses.

137. Based upon a discussion with defendant, a City official tried for several months in 2001, without success, to persuade the City's Water Department Commissioner to sign agreements to provide additional compensation for the Water Company.

138. In early December 2001, the City official reported to defendant that the Water Department Commissioner refused to sign the proposed amendments providing additional compensation for the Water Company.

139. On or about December 19, 2001, the Water Company submitted letter agreements drafted for defendant's signature granting millions of dollars in additional compensation to the Water Company.

140. On or about December 31, 2001, a Water Company executive received a voice-mail message from an assistant to defendant stating that defendant had signed the letter agreements.

141. On or about January 2, 2002, two sets of seven letter agreements, each one individually signed by defendant, were sent through the United States mail from defendant's office to the Water Company executive.

142. On or about October 4, 2002, following the publication of a newspaper article about the letter agreements with the Water Company, defendant denied signing the letter agreements and subsequently issued a public

statement that he did not "knowingly" sign the letter agreements.

 

Racketeering Act Eleven

143. Defendant committed the following acts of racketeering activity, any one of which alone constitutes Racketeering Act Ten:

(a) Wire Fraud. In or about July 1999, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed wire fraud, in violation of Title 18, United States Code, Sections 1343, 1346 and 2, in that he, for the purpose of executing the above-described scheme and attempting to do so, knowingly caused to be transmitted by means of interstate wire transmissions from Indianapolis, Indiana to Atlanta, Georgia correspondence about the trip to Paris.

(b) Mail Fraud. On or about January 2, 2002, in the Northern District of Georgia and elsewhere, defendant WILLIAM C. CAMPBELL, aided and abetted by others known and unknown to the Grand Jury, committed mail fraud, in violation of Title 18, United States Code, Sections 1341, 1346 and 2, in that he, for the purpose of executing the above-described scheme and attempting to do so, knowingly caused an envelope to be placed in an authorized depository of the United States Postal Service and caused to be delivered according to the directions thereon, addressed to the offices of the Water Company's joint venture partner in Atlanta, Georgia, which envelope contained two sets of seven letter agreements dated December 19, 2001, signed by defendant.

All in violation of Title 18, United States Code, Section 1962(c).

 

COUNTS TWO THROUGH FOUR (CORRUPT PAYMENTS)

 

1. The Grand Jury realleges and incorporates by reference paragraphs One and Eight through Thirty-three of Count One of this Indictment.

2. On or about the dates listed below, in the Northern District of Georgia, and elsewhere,

WILLIAM C. CAMPBELL, defendant herein, being an agent of the City, aided and abetted by others known and unknown to the Grand Jury, did knowingly accept and agree to accept something of value, namely cash payments in the approximate amounts listed below, with the intent to be influenced and rewarded in connection with a business, transaction, and series of transactions of the City involving something of value of at least $5,000:

Count Date Approximate Amount of Payment

Two June 9, 1999 $ 25,000

Three July 22, 1999 $ 20,000

Four August 20, 1999 $ 10,000

In violation of Title 18, United States Code, Sections 666(a)(1)(B) and 2.

 

COUNTS FIVE THROUGH SEVEN (TAX VIOLATIONS)

 

1. The Grand Jury realleges and incorporates by reference paragraphs One and Eight through 33, 36 through 50, 52 through 66, 69 through 87, 89 through 96, 99 through 114, 116 through 120, 122 through 126, and 129 through 142 of Count One of this Indictment.

2. On or about the dates listed below, in the Northern District of Georgia and elsewhere,

WILLIAM C. CAMPBELL, defendant herein, who resided at 940 Waverly Way in Atlanta, Georgia, during the calendar years 1997, 1998 and 1999, willfully made and subscribed, and caused to be made and subscribed, joint United States Individual Income Tax Returns (Forms 1040) for the tax years listed below, on behalf of himself and his wife, which returns were verified by written declarations that they were made under the penalties of perjury and filed with the Internal Revenue Service, which returns defendant did not believe to be true and correct as to every material matter, in that defendant reported the total incomes listed below on line item 22, whereas, as he then and there well knew and believed, he had received income of a material amount in excess of that reported amount.

Count Date Tax Year Total Income

Five October 15, 1998 1997 $161,544

Six October 15, 1999 1998 $162,627

Seven October 14, 2000 1999 $183,652

In violation of Title 26, United States Code, Section 7206(1).

 

SPECIAL FINDINGS

 

1. With respect to Count One of the Indictment:

(a) The offense involved payments for the purpose of influencing an elected official and officials holding high-level decision-making positions;

(b) The offense involved more than one bribe;

(c) Defendant was an organizer and leader of a criminal activity that involved five or more participants and was otherwise extensive;

(d) Defendant was an organizer, leader, manager, and supervisor in criminal activity other than described in paragraph (c); and

(e) Defendant abused his position of public trust in a manner that significantly facilitated the commission and concealment of the offense.

2. With respect to Counts 2-4 of the Indictment:

(a) The offense involved payments for the purpose of influencing an elected official and officials holding high-level decision-making positions;

(b) The offense involved more than one bribe; and

(c) Defendant was an organizer, leader, manager, and supervisor in criminal activity involving less than five participants.

 

SALLY QUILLIAN YATES

ACTING UNITED STATES ATTORNEY

Georgia Bar No. 591250

 

PHYLLIS B. SUMNER

ASSISTANT UNITED STATES ATTORNEY

Georgia Bar No. 692165

 

RUSSELL G. VINEYARD

ASSISTANT UNITED STATES ATTORNEY

Georgia Bar No. 727890

 

600 U.S. Courthouse

75 Spring Street, S.W.

Atlanta, GA 30303