beaumont isd contractor calvin walker's indictments

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  • 8/6/2019 Beaumont ISD contractor Calvin Walker's indictments

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    Case 1 :1 1 -cr-00067-TH "SEALED* Document 2 Filed 05/04/11 Paoe 1 of 18p.tteo. o

    "#;"* nlSiJg*r"J,"# FI* ^,

    IN TI{E UNITED STATES DISTRICT COI'RTFOR TFIE EASTERN DISTRICT OF TEXAS MAY C 4 2OII

    BEAI,IMONT DTVISION

    UNITED STATES OF AMERICA

    vs.

    .CAI,'WNGARYWAIKER

    u"oou,o, MALAND. CLERK

    DEPUTYJ

    J

    $

    CRIMINALNO. l:1l-CR- $ JIralg fieailf;eJy'

    INDICTMENT

    THE UNITED STATES GRAND JURYCHARGES:

    Counts One - Three (Violation: 18 U.S.C. S134fMail Fraud; 18 U.S.C. S2

    Aiding and Abetting)

    From in or about September 2008, to in or about December 2010, in the Eastern

    District of Texas and elsewhere, Calvin Gary Walkeq defendanl irnowingly devised and

    intended to devise a scheme and artifice to defraud and to deceive the Beaumont lndependent

    School District by the submission offalse and fraudulent invoices for electrical supplies and

    materials never purchased or said invoices being inflated beyond the actual cost and

    contracted mark-up by means offalse and fiaudulent pretenses and representations knowing

    at the time that such preterses and representations would be and were false when made, said

    scheme so devised and intended to be devised as follows:

    Introduction

    Calvin Gary Walker, defendan! doing business as Walker's Electric Company, was

    chosen by the Beaumont Independent School District @ISD) through a competitive bidding

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    Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 Page2of 18

    process in August 2008 to exclusively provide electrical services to BISD which could not

    be provided by the staff electricians. As part of the written contract with BiSD' the

    defendant was to provide eiectrical supplies and materials at cost plw a tenpelcent mark-up.

    Acklitionally, any use of subcontractors for an electrical project was aiso to be provided at

    cost plus a ten percent mark-up. similarly, any rental equipment needed for an electrical

    project was also to be provided at cost plus a ten percent mark-up. The contract between

    BISD and Calvin Gary Walker, defendant, doing business as Walker's Ele.ctric Company,

    was renewed in 2009 for an additional year by the BISD board of trustees and was again

    awarded to the defendant and his company by competitive bid in 2010 under the same terms

    and conditions-

    The Scheme

    calvin Gary walker, defendant, doing busiaess as walker's Electric company,

    would submit invoices to BISD for costs of materials, supplies, and subcontractor services

    which were routinely false and fraudulent in that the cost arnounts were inflated far beyond

    the actual costs incurred by defendant. Such Walker's Electric Company invoices to BISD

    for payment were sometimes accompanied by suppiier invoices for materials which were

    altered or fabricated to reflect amolnts larger than the actual costs ofmaterials, supplies, and

    subcontractor services. As a furtherpart

    of saidscheme to obtain payments from BISD on

    the invoices submitted to BISD for supplies and materials, Calvin Gary Walkel defendant

    would also attach wa.lkey's Electric Company checks made payable to various suppliers in

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    Case 1:'11-cr-00067-TH -SEALED* Document 2 Filed 05/04/1 1 Page 3 of 18

    the inflated amounts which were never actually pfesented to or negotiated by such suppliers,

    Aware ofthe intentionai misrepresentationsin the documentation submitted to BISD, Calvin

    Gary Walker, defendant, also fraudulently invoiced an inflated ten percent mark-up based

    upon the fraudulent material and supply costs.

    In addition to the above false and fraudulent submissions to BISD, Calvin Gary

    Walker, defendant, also fraudulently invoiced charges for bucket tuck lentals and the

    related ten percent mark-up when, in fact, as the defendant well kneq he owned said bucket

    truck equipment, and did not incur any rental costs.

    As a result of said scheme and artifice to defraud, calvin Gary walker, defendant,

    received approximately $3,700,000 or more in firnds from BISD in excess ofthe actual costs

    incurred and the related ten percent mark-up, causing a loss to BISD of the same anount.

    on or about the dates listed below, in the Eastem District of Texas and elsewhere,

    Calvin Gary Walker, defendant, aided and abetted by others known and unknown to the

    gand jury, for the puryose of executing the aforesaid scheme and altifice, did knowingly

    cause to be delivered by the United States Postal Service or by commercial interstate carrier

    according to the directions thereon, a letter conlaining a checig for the amount listed below,

    as a payment for materials or supplies not provided to BISD, addressed to walker's Electric

    Co., 3710 Roland Road, Beaumont, TX 77708'

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    Case 1 :1 1-cr-00067-TH .SEALED" Document 2 Filed 05/04/11 Page 4 of 18

    Count Date of Mailing Amount of Check BISDProject

    $1s7,674.68

    Amount of FalseMaterial Costs

    May 1,2009 $ 82,700.00 Ozen HS SoftbalV $ 647,000

    2 April 30,2010 $ 79,385.0iBaseball Lighting

    SmithMiddle $ 18,000School repairs

    Amelia/Caldwood $87,000Portable Buildings

    It:Jy 22,2010

    All in violation of 18 U.S.C. $$ 1341 and 2.

    Counts Four- Nine (Violation: f8 U.S.C. S1343Wire Fraud; 18 U.S'C. 52

    Aiding and Abetting)

    The grandjury realleges the introduction and scheme and artifice described above in

    the indictment in Counts One tlrough Three and incorporates the same by refelence.

    on or about the below dates, in the Eastem Distict of Texas and elsewhere, calvin

    Gary Walker, defendant, aided and abetted by others known and unknown to the grand jury,

    for the pu4rose ofexecuting or attefiipting to execute the aforesaid scheme and artifice, did

    knowingly cause to be transmitted in interstate and foreign commerce, by means of a wire

    communication, certain signs, Signals, and sounds, narnely, electronic mailings or emails to

    BISD of invoices containing inflated amounts for materials, supplies and subcontractor

    services, and electronic tansmissions to other entities, as described below, which caused or

    facilitated the payment of funds to defendant and his company:

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    Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 Page 5of 18

    Count Date

    February24,2009

    Febrmry 26,2009

    March20,2009

    Apil24,2009

    8 August 20,2009

    November 30, 2010 Email of invoice ftomCalvin Walker to BISD

    AIl in violation of 18 U.S.C. $$ 1343 and 2.

    Nature of Wire BISD Amount of FalseTransmission Project Materials Costs

    Facsimile fiom Walker Ozen SoftbalV 5647,000Electric to Goidleaf Baseball lightingFinancial, Ltd.

    Emails tolfrom Walker Ozen Softbaly $647,000Electric to Goldleaf Baseball lightingFinancial, Ltd.

    Electronic file transfer Ozen SoftbalV $647,000by Summit Electric Baseball lightingbetween Beawnont, Texasand Albuquerque, New Mexico

    Electronic file transfer Regina HowelV $ 1 , I 83 ,000by Summit Electric South Park campusbetween Beaumont, Texasand AJbuquerque, New Mexico

    Electronic file transfer Regina HowelV $343,000by Sunlnit Electric South Park campusbetween Beaumont, Texasand Albuquerque, New Mexico

    Soulh ParkStadium lighting

    $ 85,000

    CountTen (Violation: 18 U.S.C. $2314Interstate Transportation

    ofFunds by Fraud)

    On or about the lSth day of December, 2009, in the Eastem District of Texas and

    elsewhere, Calvin Gary Walker, defendant, did cause to be transported and transfered in

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    Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 Page6of 18

    interstate cormerce fiom the State of Texas to the State ofNew York, money, in the form

    ofa businesscheck, No. 565676, in the amount of$138,596.70, by depositing the check into

    an account maintained by the defendant at Capital One, N.A., knowing such check to have

    been taken by fraud that being a scheme to inflate electrical maintenance invoices submitted

    to the Beaumont Independent School District for paymen! inciuding an invoice for materials

    used at Dunbar Elementary School, of which, as the defendant well knew, was false and

    aaudulent in that the amount ofmaterials invoiced had been inflated beyond the conkactual

    amount of cost plus ten percent maxk-up.

    All in violation of 18 U.S.C. $ 23 14.

    Counts Eleven - F ourteen (Violatiop: 18 U.S.C. $2314Ilterstate Transportation

    of Funds by Fraud)

    On or about tle dates listed belo% in the Eastem District of Texas, Calvin Gary

    Walker, defendant, did cause to be transported and transferred in interstate cofirnerce from

    the State of Texas to the State oflouisiana, money, in the form of business checks ofa

    value of$5,000 or more as listed below, by depositing the checks into an account maintained

    by the defendant at Capi'ral One, N.A., knowing such checks to have been taken by fraud, that

    being a scheme to inflate elecftical maintenance invoices submitted to the Beaumont

    Independent School District for paym.en! which, as the defendant well knew, were false and

    fraudulent in that the amount ofmaterials invoiced had been inflated beyond the contractual

    amount of cost plus ten percent maxk-up,

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    Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 PageTof 18

    Count Date Check No. Amount BISD Project

    li May 29,2009 557268 $ i,285,064'00Regina/South Park

    12 Ju1y30,2009 559382 $ 160,110.50 BinghamElementary

    13 March5,2010 569M2 $ 119,051.02 FrenchElem'trailen

    14 hily22,2010 575639 $ 157,674'68 Amelia/Caldwood

    AII in violation of 18 U.S.C. $ 2314.

    Counts Fifteen - Sixteen (Violation: 18 U.S'C' 5666Fraud upon Programs

    receiving federal fu nds)

    On or about the dates listed below, in the Eastern Distriot of Texas' Calvin Gary

    walker, defendant, being an agent ofthe Beaumont Independent School Distict, Beaumon!

    Texas, a locai government or organization receiving in the one year period begiruring January

    1, 2008, federal benefits in excess of $10,000, did steal, embeufe and obtain by fraud'

    propedy worth at least $5,000 under the care, custody, and control of the Beaumont

    Independent Sohool District, in that the defendant submitted an invoice fol the cost of

    materials for the repair of the following BISD facilities which was falsely and fraudulently

    inllatedintheapproximateamountslistedbelow,anduponwhichthedefendantreceived

    payment:

    Count Date ofBISDCheck

    15 October 16,2008

    Amount of Check BISD Amount of FalseProject Material CostsInvoiced

    S 5gg!757.26 MLK Middle School $ 91'000hurricane rePairs

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    Gase'l:11-cr-00067-TH.SEALED* Document2 Filed 05/04/11 Page8of 1B

    16 October16,2008 5599,757.26 SmithMiddleSchool $167'000hurricane rePairs

    AII in violation of 18 U.S"C. $ 666(aXlXA).

    Counts Seventeen-Twenty-four (Violation: 18 U.S.C. $666Fraud upon Programsreceiving federal funds)

    on or about the dates listed below, in the Eastem District of Texas, Calvin Gary

    walker, defendang being an agent ofthe B eaumont Independent school Distict, Beaumonq

    Texas,alocalgovemmentororganizationreceivingintheoneyearperiodbegimingJanuary

    L zoag, federal benefrts in excess of $10,000, did steal, embezz|e and obtain by ftaud'

    property worth at least $5,000 urder the care, custody, and control of the Beaumont

    Independent school District, in that the defendant submitted invoices fol the cost ofmatrials

    or labor for the repair of the tbllowing BISD facilities which were falsely and fraudulenfly

    inflated in the approximate amounts listed below, and upon which the defendant received

    palment:

    Count

    11

    18

    Date of BISD Amount of CheckCheck

    April 3,2009 $ I,153,300.00(initial PaYment)

    April30,2009 $82,700.00(frnal payment)

    May 29,2009 $ 1,285,064.00

    BISD Amount of FalseProject Material (Labor)

    Costs Invoiced

    Ozen HS SoftbalV $ 647,000Baseball Lighting

    Ozen HS SoftbalV same as Count 17Baseball Lighting

    Regina Howell $ 588,000temporary campus

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    Case 1:11-cr-00067-TH.SEALED" Document2 Filed 05104111 Page I of 1B

    20 May 29,2009 $1.285.064.00 SouthPark $ 594,000temporary campus

    JuIy30,2009 $ 160,110.50 Bingham-Blanchette $ 145,000Elementary School

    September 10, 2009 $ 1,592,839.10 Regina HowelV $ 343,000South Park

    23 September 10,2009

    rcmporar7 campuses

    $ 1,592,839.10 ReginaHowelV $ 83,200SouthPark (labor)temporary camPuses

    $ 138,596.70 Dunbar Elem. trailers $ 112,0004 December i 8. 2009

    All in violation of 18 U.S.C. $ 666(a)(1XA).

    Counts Twent!'-five - Thirtv (Violation: 18 U.S.C. $666Fraud upon programs

    receiving federal funds)

    On or aboul the dates listed below, in the Eastem District of Texas, Calvin Gary

    Walker, defendant, being an agent ofthe Beaumont Independent School District, Beaumon!

    Texas, a local govemment or organization receiving inthe one year period beginning January

    1,2010, federal benefits in excess of $10,000, did steal, embezzle and obtain by fraud,

    property worth at least $5,000 under the care, custody, and control of the Beaumont

    Independent School District, in that the defendant submitted invoices for the cost ofmaterials

    for the repair of the following BISD facilities which were falsely and fraudulently inflated

    in the approximate amounts listed below, and upon which the defendant received payment:

    22

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    Case 1:1't-cr-00067-TH -SEALED* Document2 Filed 05/04/1 1 Page 10 of 18

    Count Date of BISD Amount of Check BISD Amount of False. Check Project Material Costs

    25 March5,2010 $ 119,051.02 FrenchElementarv $27'000temP. classrooms

    26 Api129,2010 $ 79,385.01 SmithMddle $ 18'000School repairs

    27 1u1y22,2010 $157,674.68 SouthParkstadium $ 20'000

    28 luly 22;2010 8 157,674.68 Amelia/Caldwood $ 87,000Portable Buildings

    29 October2l,2010 $164,435.40 Installgeneratorat $ 35,000BISD Administration

    30 December 3, 2010 $ 499,000.00 South Park M.S.. stadium lights

    All in violation of 18 U.S.C. $ 666(aX1)(A).

    $ 85,000

    Count Thirtv-one (Violation: 18 U.S.C. S666' Fraud upon programs

    receivin g federal funds)

    On or about the 16th day of October, 2008, in the Eastern District of Texas' CaMn

    Gary Walker, defendant, being an agent of the Beairmont Independent School District,

    Beaumont, Texas, a local govemment or organization ieceiving in the one year period

    beginning January 1,2008, federal benefits in excess of$10,000, did steal, embezzle and

    obtain by fraud, property worth at least $5,000 under the care, custody, and controlof the

    Beaumont Independent School Distric! in that the defendant submitted two invoices for the

    cost of bucket truck rentals of $1 12,000 for the repair of Smith Middle School and King

    10

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    Case 1:1 1-cr-00067-TH .SEALED* Document2 Filed 05/04/11 Page11of1B

    Mddle School which was false and fraudulent in that the defendant did not rent said

    equipment or invoice the equipment at cost, and upon which the defendant received payment

    in that aurount.

    All in violation of 18 U.S.C. $ 666(aXl)(A).

    Count Thirty-two (Violation: 18 U.S.C. 5666Fraud upon programsreceiving federal funds)

    On or about the 10th day of September, 2009, in the Eastern District of Texas, Calvin

    Gary Walker, defendant, being an agent of the Beaumont lndependent School District,

    Beaumont, Texas, a local govemment or organization receiving in the one year period

    beginning January i, 2009, federal benefits in excess of $10,000, did steal, embezzle and

    obtain by fraud, property worth at least $5,000 under the care, custody, and control of the

    Beaumont Independent School District, in that the defendaot submitted an invoj.ce for the

    cost of bucket truck rentals of $546,000 for the electical s]'sterr construction of Regina

    Howell and South Park temporaxy campuses which was false and fraudulent in that the

    defendant did not rent said equipment or invoice the equipment at cost, and upon which the

    defendant received payment in that amount.

    All in violation of 18 U.S.C. $ 666(aX1XA).

    CountThirty-three(Violation: 18 U.S.C.

    $1957Money Laundering)

    On or about the 1 lth day of Septemb er, 2009, in the Eastem District of Texas and

    elsewhere, Calvin Gary Walker, defendant, did klowingly engage and attempt to engage

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    Case 1:1'1-cr-00067-TH -SEALED* Document2 Filed 05/04/11 Page 12 of 1B

    in a monetary transaotion in criminally derived property ofa value greater than $ 10,000 and

    which was derived from a specified unlawful activity, that monetary transaction being the

    negotiation of a check ftom the Beaumont lndependent School District in the amount of

    51,592,839.10 by the defendant into the J.P. Morgan Chase Banlg which said monetary

    transaction involved the proceeds of specified unlawful activily, that is, wire fraud as

    described in Count 8 of this indictuent ani the theft of fimds as described in Coimts 22, 23

    and 32 ofthis indictnent which is adopted herein, conduct puoishable under the laws ofthe

    United States.

    All in violation of 18 U.S.C. $ 1957(a).

    Count Thirtv-four {Violation: 18 U.S.C. 51957Money Laundering)

    On or about the 8th day of September, 2009, in the Eastem District of Texas and

    elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage

    in a monetary transaction in criminally derived property of a value greater than $ 10,000 and

    which was derived from a specified unlawfui activity, that monetary hansaction being the

    purchase of a 2010 Mercedes S5F, 4 door, VIN WDDNG7BB0AA28863 1, in the amount of

    $117,000, which said monetary transaction involved the proceeds of specified unlawful

    activity, that is, the theft of fu:rds described in Counts 7,4,5,6,7,11 - 12, and 15 - 21 ofthis

    indictuent which is adopted herein, conduct punishable under the laws of the United States.

    All in violation of 18 U-S.C. $ 1957(a).

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    Case 1:11-cr-00067-TH"SEALED* Document2 Filed 05104111 Paqe 13of 1B

    CountThirty-five (Violation: 18 U.S.C. $1957Money Laundering)

    On or about the 27st day of September, 2009, in the Eastern District of Texas and

    elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage

    in a monetary transaction in criminally derived property ofa value greater than $ 10,000 and

    which was derived ftom a specified unlawful activif, that monetary transaction being the

    purchase ofa Transamerica Preferred Choice Fixed Annuity Contract 02TPC047 479 for the

    amount of$1,600,000 by the defendant using fimds from the JP Morgan savings account

    nurnber *****+7080of defendant which said monetary ftansaction involved the proceeds

    of specifred unlawful activity, that is, the theft of funds described in Counts I,4, 5,6,7,8,

    11 - 12,15 - 23, and 32 of this indictnent which are adopted herein, conduct punishable

    under the laws of the United States.

    Al1 in violation of i8 U.S.C. $ i957(a).

    Count Thir8-six (Violation: 18 U.S.C. $1957Money Laundering)

    On or about the 7th day of Octobet,2009, in the Eastem District of Texas, Calvin

    Gai-y Walker, defendant, did knowingly engage and attempt to engage in a monetary

    transaction in criminally derived property of a value greater than $10,000 and which was

    derived from a specified unlawfr{ activity, that monetary transaction being the purchase ofa uact of land for $175,000 on Pleasure Island, Port Arthur, Texas, described as Tract 31A.'

    Lafitte's Landing, which said monetary transaction involved the proceeds of specified

    1J

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    Case 1:11-cr-00067-TH.SEALED* Document 2 Filed 05104111 Page 14 of 18

    unlawful activity, tlat is, the theft of funds as described in Counts l,4,5,6,7,11 - 12,and

    15 - 21 of this indictment which is adopted herein, conduct punishable under the laws ofthe

    United States.

    All in violation of 18 U.S.C. $ i957(a).

    Connt Thirtv-seven (Violation: 18 U.S.C. 51957Money Laundering)

    On or about the 28th day of October, 2009, n the Eastem District of Texas and

    elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage

    in a monetary transaction in criminally derived property of a value greater than $ 10,000 and

    which was derived from a specified uniawfill activity, tlat monetary transaction being the

    purchase ofa Transarnerica Preferred Choice Fixed A:rnuity Contxact 02TPC080685 for the

    amount of $1,800,000 by the defendant using frrnds ftorn the JP Morgan savings account

    number *****{'7080of defendang which said monetary transaction involved the proceeds

    of specified unlawfirl activity, that is, the theft of fiuds described in Counts 1, 4 through 8,

    11 - 12, 15 - 23, ard 32 ofthis indicfinent which is adopted herein, conduct punishable under

    the laws of the United States.

    All in violation of 18 U.S.C. $ 1957(a).

    NOTICE OF INTENTION TO SEEK CRIMINAI FORFETTURES

    As a result of committing one or more of the offerses alleged in Counts 1 - 37 of the

    indictnent Calvin Gary Walker, defendan! did use or intend to use personal property to

    commit said offenses and shall forfeit to the United States such property pursuant to 18

    14

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    Case 1:11-cr-00067-TH .SEALED* Document 2 Filed 05/04/11 15 of 18

    U.S.C. $981(a)(lXC), $ 982 (aXa), and28 U.S.C. $ 2461(c), includingbutnotlimitedtothe

    following:

    1. Personal Property

    a. MONEY JIIDGMENT, being asum ofmoney equal to $3,700,000.00 in United Statescurrency rqxesenting the amount of proceeds obtained as a result of the above fraudoffenses, in violation of I 8 U.S.C. $ $ 666, 1341, 1343, 2314, and 1957.

    b. The following assets or funds representing proceeds obtained as a result ofthe abovefraud offenses, in vioiation of 18 U.S.C. $$ 666, 1341, 1343,2314, and 1957:

    A Trarsarnericd Preferred Choice Fixed Annuity Contract 02TPC 047 47 9, pwchnedfor $1,600,000 on or about September 21, 2009, using funds from the JP Morgansavings account number ***!k**7080of Calvin Walker;

    A TransamericaPrefened Choice Fixed Amuity Contract 02TPC080685 purchasedfor $1,800,000 on or about October 28,2009, using frnds from the JP Morgansavings account numbef, *x**'r*7080 of Calvin Walker;

    A 2010 Mercedes S5F, 4 door, \IIN WDDNG7Bts0AA288631, purchased on orabout September 8,2009, fromMercedesBenz ofHouston, Greenway, inthe amormtof $1 17,000;

    Tbree BISD checks in the amounts of $9,743.86, $1O,325.34, nd$499,000, andthefunds they represent, seized from the defendant on or about December 7 ,2010.

    2. Real Property

    A parcel of land purchased on or about Octo ber'7,2009 described as Tract 31A ofa Replat of Lots numbered Thirty-one and Thirty-two (3 1 &32) ofLafitte's LandingPhase Two, a 106.97 acre subdivision out of and a part of the N. Coleman Survey A-12 and the Dennis Gahagan League, Abstract No. 123, in the City of Port Arthur,

    Jefferson County, Texas, as the sameappears upon the map or plat thereof, on file and

    of record in Vo1.16 page 309 Map Records of Jefferson Cotmty, Texas;

    3, Substitute Assets

    If as a result of any act or omission by defendan! any of the property described

    Page

    15

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    Case 1 :1 1 -cr-00067-TH -SEALED" Document 2 Filed 05/04/11 Page 16 of 18

    above:

    (a) cannot be located upon the exercise of due diligence;(b) has been transferred or sold tq or deposited with, a third party;(c) has been piaced beyond the jurisdiction of the court;(d) has been substantially diminished in value; or(e) has been commingled with other property which cannot be divided withoutdifficulty;

    it is the intent ofthe United States, pursuant to Title 2 I , United States Code, Section 853 (p),

    incorporated by reference by 18 U.S.C. $981(aX1XC) and $ 982 (a)(a), and 28 U.S'C' $

    Zail@),to seek forfeiture of any other property of defendant up to the value ofthe above

    forfeitabie properly, including but not linited to all properfy, both real and personal owned

    by defendant.

    By virnre of the commission of the aforementioned offenses charged in this

    Indictnent by the defendan! any and ail interest the defendant has in the above-described

    property is vested in the United States and hereby forfeited to the United States for its use or

    for any other disposition in iG discretion pursuant to 18 U.S.C. $981(aX1XC) and $ 982

    (a)(4), and 28 U.S.C. $ 2461(c).

    ASSISTANT I'NITED STATES ATTORNEY

    'RAND J['RY FOREPERSON

    JOHNM. BALESUNITED-STATES ATTORNEY

    -to

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    Case 1:11-cr-00067-TH -SEALED- Document 2 Filed 05104111 Paqe 17 of 1B

    IN TTM UNITED STATES DISTRICT COI'RTFOR THE EASTERN DISTRICT OF TEXAS

    BEAI'MONT DTVISION

    LINITED STATES OF AMERICA 6$VS. t CRIMINAINO. t:11-CR-!

    CALVINGARY\MAIKER O

    NOTICE OFPENALTY

    Counts One - Three

    Violation: 18 U.S.C. $ 1341 (Mail Fraud); 18 U.S.C. $ 2 (Aiding andAbettingan Offlense)

    Penait: Not more than twenty (20) years imprisonment; a fine of not morethan $250,000, or both. A terrn of supervised release of not morethan five (5) years.

    Soeciai Assessment: $100

    Counts Four - Nine

    Violation: 18 U.S.C. g 1343 (\Mire Fraud); 18 U.S.C. g 2 (Aiding and Abettingan Offense)

    Penalty: Not more than twenty (20) years imprisonment; a flne of not morethan $250,000, or both. A term of supervised release of not morethan five (5) years.

    Special Assessment: $100.00

    Counts Ten - Fourteen

    Violation: 18 U.S.C. $ 2314 (nterstate Transportation of Money by Fraud)

    Penaltv: Imprisonment of not more than ten (10) years, a fine not to exceed$250,000.00, or both. A term of supervised release ofnot more tha:r tbree (3)years rnay be imposed.

    17

  • 8/6/2019 Beaumont ISD contractor Calvin Walker's indictments

    18/18

    Case 1:11-cr-00067-TH "SEALED" Document2 Filed 05104111 Page lBof 18

    Snecial Assessment: $100.00 for each count.

    Counts Fifteen - Thirtv-two

    Violation: 18 U.S.C. $ 666(a)(1)(A) (Fraud upon Programs receiving federalfunds)

    Penalty: Imprisonment of not more than ten (10) years, a fine not to exceed$250,000, or both; a temr of supewised release of not more than tl'lree(3) years.

    Special Assessment: $ I00.00

    Counts Thirty-three - Thirtv-seven

    Violation: 18 U.S.C. $ 1957 (vloney Larmdering Transactions Greaterthan $10,000)

    Penalty: Not more than ten (10) yean imprisonment; a fine of not more than$250,000 or twice the value ofthe criminally derived property, or both;a term of supervised release ofnot more lhan tlree (3) years'

    Soeciai Assessment: $100.00

    i8