federal case indictments

8/20/2019 Federal Case Indictments

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FILED

U . S . D IS T R I C T C O U R T

S A V A N N A H D I V .

2015 DEC -2 j 5:f9

C L E R K

S O D I S T

6

CR415 203

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF GEORGIA

SAVANNAH DIVISION

UNITED STATES OF AMERICA

INDICTMENT NO.

CHADWICK L. REESE

and

VIO: 18 U.S.C.

§

1341

Mail Fraud

18 U.S.C.

§

1951

Extortion

Forfeiture Allegation

JOEL T. MORRIS

Defendants.

THE GRAND

JURY CHARGES THAT:

Introduction

A t all times relevant to this Indictment:

1

he Chatham Area Transit Authority (CAT) was created by an Act of the Georgia

General Assembly to operate a transit system in Chatham County, Georgia. CAT s yearly

revenues include m illions of d ollars in passenger fares, local taxes and federal grants.

2 efendant

Chadw ick L. Reese

was the Executive D irector of CA T .

3 .

efendant

Joel T. Morris

was the C A T D irector of Maintenance.

Case 4:15-cr-00203-WTM-GRS Document 27 Filed 12/02/15 Page 1 of 8


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COUNTS ONE - THREE

Mail Fraud

18 US. C.

ff

1341

4.

Paragraphs 1 through 3 of the Indictment are incorporated by reference as if fully

set forth herein.

5. Beginning no later than April, 2014, through the return of this Indictment, in

C hatham C ounty, Georgia, within the S outhern D istrict of Georgia, and elsewhere, D efendants

Chad wick L. Reese

and

Joel T. Morris

and others known and unknown to the Grand Jury,

devised and intended to devise a scheme and artifice to defraud and deprive the citizens of

C hatham C ounty and the C hatham A rea T ransit A uthority of their right to honest and faithful

services through bribery, kickbacks and the concealment of material information.

Manner and M eans

6.

It was part of the scheme and artifice that the D efendants, aided and abetted by

each other, would secretly use their official positions to enrich themselves by soliciting and

accepting cash and other payments in exchange for rigging the award of C A T contracts to

selected individuals and companies.

7.

It was further part of the scheme and artifice that the D efendants, aided and

abetted by each other, would direct CAT to make payments to individuals and companies who

had been awarded C A T contracts through a rigged and fraudulent process.

It was further part of the scheme and artifice that the D efendants, aided and

abetted by each other, would direct how and when they would receive bribery and kickback

payments.

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9. t was further part of the schem e and artifice that the D efendants, aided and

abetted by each other, would take steps to hide, conceal, and cover up their bribery and kickback

scheme.

T he Mailings

10.

n or about the dates listed below, the D efendants, for the purpose of executing,

and attempting to execute, the scheme and artifice, did knowing ly cause to be sent by U .S . Mail

C hatham A rea T ransit A uthority checks in the amounts so listed:

Count

ate of Ma iling

mount of Check

uly

17 2015

1 9 , 3 9 7 . 2 0

2

eptember 11, 20 15

13,421.00

3

ctober l6,2015

11,755.76

All done in violation of Title 18, United States Codes, Sections 1341 and 1346.

COUNT FOUR

Extortion

18 US C §1951

11.

aragraphs 1 through 10 of the Indictment are incorporated by reference as if

fully set forth herein.

12.

n or about June

25, 2015,

in Chatham County, within the Southern District of

Georgia, and elsewhere, D efendant

Joel T. Morris

aided and abetted by others, did knowingly

attempt to obstruct, delay and affect commerce, and the movement of articles and commodities

in comm erce, by extortion, in that the D efendant, in his official capacity with C hatham A rea

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Transit Authority, attempted to obtain money from PW, with that individual's consent, which

was induced under color of official right.

All done in violation of Title 18, United States Code, Section 1951.

COUNT FIVE

Extortion

18 U S 0 §1951

13.

Paragraphs I through 10 of the Indictment are incorporated by reference as if


14. On or about July 22, 2015, in Chatham County, within the Southern District of

Georgia, and elsewhere, D efendant

Chadw ick L. Reese

aided and abetted by others, did

knowingly attempt to obstruct, delay and affect commerce, and the movement of articles and

commodities in commerce, by extortion, in that the Defendant, in his official capacity with

Chatham Area Transit Authority, attempted to obtain money from PW, with that individual's

consent, which was induced under color of official right.


COUNT SIX

Extortion

18 U S.C. §1951

15.

Paragraphs 1 through 10 of the Indictment are incorporated by reference as if


16. O n or about S eptember

15,

2015, in Chatham County, within the Southern

D istrict of Georgia, and elsewhere, D efendant

Chadwick L. R eese

aided and abetted by others,

u



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did knowingly attempt to obstruct, delay and affect commerce, and the movement of articles and

commodities in commerce, by extortion, in that the Defendant, in his official capacity with




COUNT SEVEN

Extortion

18 US. C. §1951

17. Paragraphs 1 through 10 of the Indictment are incorporated by reference as if


18.

On or about September 18, 2015, in Chatham County, within the Southern

D istrict of Georgia, and elsewhere, D efendant

Joel T. Morris



comm odities in commerce, by extortion, in that the D efendant, in his official capacity with



A ll done in violation of T itle 18, U nited S tates C ode, Section 1951.

COUNT EIGHT

Extortion

18 US. C. §1951

19.

Paragraphs I through 10 of the Indictment are incorporated by reference as if




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20.

On or about October 26, 2015, in Chatham County, within the Southern District

of Georgia, and elsewhere, D efendant

Chadwick L. R eese aided and abetted by others, did






COUNT NINE

Extortion

18 US. C. §1951

21.

Paragraphs 1 through 10 of the Indictment are incorporated by reference as if


22.

On or about October 29, 2015, in Chatham County, within the Southern District

of Georgia, and elsewhere, D efendant

Joel T. Morris







FORFEITURE ALLEGATION

The allegations contained in Counts One through Nine of this Indictment are

hereby realleged and inco rporated by reference for the purpose of alleging forfeitures pursuant to

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T itle 18, U nited S tates C ode, S ection 981 (a)(1 )(C ) and T itle 28, U nited S tates C ode, Section

2461(c).

2. Upon conviction of one or more of the offenses in violation of Title 18, United

S tates C ode, Section 1341 set forth in C ounts O ne through Three of this Indictment, the

D efendants,

Chadwick L. Reese

and/or Joel T. Morris

shall forfeit to the United States of

A merica, pursuant to T itle 18, U nited S tates C ode, Section 981 (a)(1 )(C ) and T itle 28, U nited

S tates C ode, S ection 24 61(c), any property, real or personal, which constitutes or is derived from

proceeds traceable to the offense(s).

3. Upon conviction of one or more of the offenses in violation of Title 18, United

S tates C ode, S ection 19 51 set forth in C ounts Four through N ine of this Indictment, the

D efendants,

Chadwick L. Reese and/or Joel T. Morris

shall forfeit to the United States of

A merica, pursuant to T itle 18, U nited S tates C ode, Section 981 (a)( 1 )(C ) and T itle 28, U nited

S tates C ode, S ection 24 61(c), any property, real or personal, which constitutes or is derived from

proceeds traceable to the offense(s).

4.

If any of the property described above, as a result of any act or omission of the

D efendants:

a.

cannot be located upon the exercise of due diligence;

b.

has been transferred or sold to, or deposited w ith, a third party;

C .

as been placed 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

without difficulty,

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Foreperson

irst A ssistant U nited S tates A ttorney

the U nited S tates of A merica shall be entitled to forfeiture of substitute property pursuant to T itle

21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section

2461(c).

A ll purs ua nt to 18 U . S . C . § 9 81(a )(1)(C ) a nd 28 U . S . C . § 2 4 6 1(c ).

A T R U E BI LL .

Edward J. T arver

U nited S tates A ttorney

TaffertW

A ssistant U nited S tates A ttorney

Criminal Division Chief

* denotes lead counsel

P

[4]


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