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CLERK'S OFFICE U S

. DI6lT . COURTAT M INGDON, VAFILED

JUL 2 1 2215JULIA C

. UD , LERBY: .D Ll

IN THE UNITED STATES DISTRICT COURTFOR THE W ESTERN DISTRICT OF W RGINIA

ABINGDON DIVISION

UNITED STATES OF AM ERICA

V.

W ES ROSENBALM

@*

*@ *

: Case No. *

AGREED STATEM ENT OF FACTS

Introductitm

On or about November 1951, the City of Bristol, Vir e ia establi+ed the Bristol

Virgnia Uilities Board as a city agency to be a pro vider of utility serdces, including electric

power, water, and sewer, to the residents of the Ci ty of Bristol, Virginia.

On or about July 1, 2010, Bristol Virsnia Utilities Board became the Bristol

Virginia Utilities Authority, a state authority of the Commonwealth of Virsnia.

Each of the calendar years between 2010 and 2014, B ristol Virginia Utilities

Authority received more th* $10,000.00 in flmds fro m the United States government.

4. At tim es relevant to the filed lnform ation, Com p anies //1 through #9, operated as

contractors or vendors for Bristol Virsnia Utilitie s Authority or its predecessor Bristol Virsnia

Utilities Board.

5. At a11 times relevant to the filed inform ation, W ES ROSENBALM served as

Chief Executive Om cer of Bristol Virginia Utilities Authority or its predecessor, Bristol Virsnia

Utilities Board.

6. On or about and between January 1, 2008, and Dec ember 31, 2008, W ES

ROSENBM M 'S gross pay as Chief Executive Officer was $156.203.7 1. On or about alld

between January 1, 2009, and Decem ber 31, 2009, W ES ROSENBALM 'S F oss pay as Chief

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Case 1:15-cr-00021-JPJ Document 4 Filed 07/21/15 of 14 Pageid#: 10

Executive Om cer was $182,201.43.On or about and bdw een January 1, 2010, and Dœ ember

3l, 2010, W ES ROSENBALM 'S Foss pay ms Chief Executi ve Ofscer was $184,367.60. On or

about and between January 1, 2011, and December 31, 2011, W ES ROSENBALM 'S p oss pay

as Cllief Executive Oo cer was $199,678.64. On or ab out and between January 1, 2012, and

December 31, 2012, W ES ROSENBM M 'S gross pay as Clli ef Executive Officer was

$207,293.30. On or about and between January 1, 201 3, and December 31, 2013, W ES

ROSENBM M 'S gross pay ms Chief Executive Oflcer was $218,819.81.

Dem and n ine of Value as a Reward

On or about October 18, 2008, W ES ROSENBM ,M sent an email to Co-

conspirator #1 and other employees of Bristol Virsn ia Utilities directing t11* to contact

vendors and contractors of Bristol Vir/nia Utiliées to tell them to pay money to the Blistol

Chamber of Comm erce to become members of the Bristo l Chamber of Commerce. At this time,

Co-conspirator #1 was the president of the Bristol Chamber of Commerce. The em ail stated, in

part.'

These people/organizations p?ilkc allot of money /. #' of #)7.7 and they need torcf?zm thefavor. 1 strongly suggest that each onejo in to Jlc/p the Chamber whichin /?zm helps 5 )'U more than you can imagine within the business community . .J#.f a company does regular business with BW they n eed to join. . . Iilt goeswithout saying but 1 am going to say it we have bee n good to these companiesthey need to rc/xm thefavor to us and it will cost vcry litde money to do so.

8. On or about October 22, 2008. at 10:57 a.m ., Co-c onspirator //1 sent an email to a

representative of Company #9, which stated, in part :

Hello l'representativel,As you may 'F/JF Fc,& is president ofthe Chamber th is year and they are on theirmembership campaign, so, of course, 1 have been tag ged to help out. Is thereanm ay .w xr-/ir??i could increase your membership fr om its current status ofanannual rate of$401 to $1203 and become a GoldM ember ? F'c certainly wouldappreciate j/.? Just let me katlw .

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9. On or about October 22, 2008, at 11:02 a.m ., the representaéve of Company #9

sent al em ail to Co-conspirator #1 which stated, in part

(Co-conspirator #1.1,Fc 'll change our status. Exactly what do wc getfor becoming a GoldM ember?

10. Company //8 was contacted by a representative o f Bristol Virginia Utilities

Authority and asked to join the Chamber of Commerce . As a result of this contact, Company //8

paid the Bristol Cham ber of Commerce to become a tr old M em ber'' of the Bristol Chamber of

Commerce. Company #8 only paid money to become a çr old M ember'' of the Bristol Chamber

of Commerce and believed this wms required as a ttc ost of doing business'' to continue to receive

contracts from Bristol Virginia Utilities Board.

11. ()n or about Jtme 1, 2009, W ES ROSENBALM sent a n email to Co-conspirator

//1 and others statinga in part:

I'Company #41 is coming in f/tfly and 1 need to hit them up with the sponsorshiprequests wc discussed. 1 recall the kjtfç Christmas Jwrf (sic) but what else do wcneed sponsorsfor? F//lf do wc normally spend on the Christmas rtzrf (sic) forthe kids? FàJ/ do wc spend on our Christmasparty? F //tz/ else wl.: there? I tw lmeeting with them at 2 soplease get back to me quic kly.

12. On or about July 23, 2009, Bristol Virginia Uti lities Employee #1 CtEmployee

#1), at the diredion of W es Rosenbalm and Co-conspi rator #1, sent an email from Bristol,

Virginia to Company #1a located in Charlotte, NCa a nd also sent a copy of the email to Co-

conspirator //1 and W es Rosenbnlm . The em ail to Co mpany //1 solicited the flmding of a

luncheon for Bristol Virginia Utilities employees O er the naming of Bristol Virginia Utilities as

a fmalist for an award.The em ail stated, in part'.

Unfortunately, the Iocal economy has made it imposs ible for us to suy cientlyfund the celebration and recognize our employees ap propriately. Therefore, weare asking our major long-term vendor partners to J ?e/# with this celebration bymaking a cash contribution //?tz/ wj// be used towa rd the cost ofthe event.

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13. ()n or about ytugust 17,2009, Company #1 notile d Bristol Virgnia Utilities

Board via em ail it was unable to provide Bristol Vi rginia Utilities Board with funding due to lack

of resources, however, Company #1 provided a $1,000 credit to its bill to Bristol Virginia

Utilities Board in order to comply w1t.11 the reque st for flmding from Bristol Virginia Utilities

Board.

14. ()n or about July 2009, Em ployee #1, at the dir ection of W ES ROSENBM M and

Co-conspirator #1, contacted Com pany #7 and solicit ed funding for a ltmcheon for Blistol

Virginia Utilities employees aAer the nnm ing of Bri stol Virginia Utilities ms a finalist for an

awrd. As a result of this solidtation, Company //7 provided Bristol Virginia Utilities Board w11

a check m ailed from California to the W estern Distr ict of Virginiw payable to Bristol Virginia

Utilities Board in the amount of $1,000.00.

15. On or about August 19, 2009, Employee #9 sent a n em ail to W ES ROSENBALM

and other employees of BristolVirginia Utilities Bo ard stating, in summ ary, had acquired

$7,000.00 &om mtlltiple compO ies to pay for the lun cheon for Bristol Virginia Uélities Board.

16. On or about September 6, 2011, while in prelim i nary conlact negotiations with

Com pany #5, in anticipation of a Request for W oposa ls for services being issued by Bristol

Virginia Utilities Authority, Co-conspirator #1, at the diredion of W ES ROSENBM V via

email from Bristol, Virginia to Atlanta, Georgia, C o-conspirator //1 conlcted a Representative

//1 of Company //5 and requested th1 Company //5 pr ovide éckets to a University of Kenm cky

bmsketball or football game for W ES ROSENBM ,M and h is five children.

17. On or about Odober 26, 2011, Co-conspirator #1 inquired via em ail if

Representative #1 had received Bristol Virginia Uti lities Authority's Request for Proposal for

services. Representative #1 responded he had receiv ed the Request for Proposal.

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18. On or about November 16, 2011, Representative # 1 of Company #5 notified Co-

conspirator //1 that he had acquired 5ve éckets to a University of Kentucky basketball game for

W ES ROSENBALM and if he should send the tickets to Co-conspirator #1. Co-conspirator //1

replied via em ail from Bristol, Virginia to Atlanta , Georgia:

JT,&, but let 's wait until wc award the 1?F# - 1 d o not want it construed as a g#during ourprocess. M ake sense?

n e representative of Company //5 responded to Co-co nspirator's em ail, by

stating, in part:

It does.

19. On or about December 31, 2011, Company #5 and B ristol Virginia Utilities

Authority entered into a binding contract for selvi ces.

20. On or about and between Janual.y 1, 2010 and De cember 31, 2014, Company //3

received more than $20,000,000 itl pam ents from Bri stol Virsnia Utilities Authority as a major

contractor hired as a result of state and federal g rants.

21. On or about November 10, 2011, W ES ROSENBALM em ailed Co-conspirator //1

and others and stated, in part:

Fc have a sponsorfor the bar at the customer apprec iationfunction. Please havethem send that bill to l'company #31, not SP'1.f

22. On or about January 30, 2012, Company #3 paid $ 663.50 to Bristol Virginia

Utilities Authority for the alcohol purch%es at the Bristol Virginia Utilities Authority Custom er

Appreciation Event. Comp> y #3 paid for the Bristol Virginia Utilities Authority alcohol

purchases because of the fear that a failure to mak e such payment would result in economic hnrm

to Company #3's ongoing business w 1t11 Bristol Virg inia Utilities Authority and if it w as not paid

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th1 W ES ROSENBM M and his Co-conspirators would prov ide less favorable treatment to

Com pany #3.

23. On or about and between January 1, 2010 and Dec ember 25, 2012 , W ES

ROSENBM M , Cmconspirator #1 and otber high-level mana gement employees at Bristol

Virginia Utilities Authority received gift cards fr om Company #3.

24. On or about Decem ber 23, 2011, W ES ROSENBALM se nt an email to the CEO

of Company #3, which stated, in part:

Thank you for the gdt card. F/llf is always a speci al treat for me each year. 1hope you have a wondeful Christmas.

25. ln or about 2012, Co-conspH tor #1 requested tha t Employee #3, an employee of

Bristol Virginia Utilities Authority, contact Compa ny //3 and tell Company //3 that she preferred

that Company //3 provide her with a Christm as gift card for spa serdces at the M artha

W mshington Inn as opposed to a g1* card to Bass Pro Shops. ()n or about December 2012,

Company //3 provided Co-conspirator //1 w11 a giA c ard for $200.00 to the M artha W ashington

lnn. Company //3 provided tlle $200.00 gift card to the Mnrtha W ashington for the benefit of Co-

conspirator #1 because of the fear that a failure t o provide said g18 card would result in

economic hnrm to Company #3's ongoing business with Bristol Virsnia Utilities Authority and

that if not provided W ES ROSENBALM and Co-conspirat or //1 would provide less favorable

treae ent to Company #3.

26. On or about Novem ber 6. 2012, w1t.11 W ES ROSENB M M 'S knowledge Co-

conspirator #1 sent an em ail to employees of Bristo l V irginia Utilities Authority that stateda in

pad'

Here is what 1 would like to have..F/ltwk&gjvjz?g lunch underwritten by I'Company #21 - $2,850

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Christmas Dinner zlatfcrwrj/fcn by Jctmrl?;>' #J7 - $15,000Children 's Christmas plr@ to be underwritten by I' Company #41 - $5,500I'Employee #U, can you reach out to I'company #21 J /W I'company #V P(Employee #zl/lEmployee #3l to contact Company #J.Thankslfco-conspirator #J./

On or about Novem ber 2012, at W ES ROSENBM M 'S and Co -conspirator #1's

direction, Employee //3 contacted Company //3 and r equested they provide $15,000.00 to pay for

the Bristol Virginia Utilities Authority Christmas Dinner. Employee //3 told the President and

CEO of the Company //3 that his company had been ch osen to pay for this event due to the large

am ounts of money paid to Company //3 by Bristol Vir ginia Utilities Authority. Company //3

agreed to pay for the Bristol Virginia Utilities Au thority Chrishnas Dinner.

28. On or about November 2012, Company //2 provided Bristol Virginia Utilities

Authority w1t.1: $2,850.00 to pay for the Bristol V irginia

luncheon.

Utilities Authority Thimksgiving

29. On or about November 7, 2012. Employee //1 sent an em ail from Bristol, Virginia

to Company #1, located in Chadotte, North Carolina, which stated, in part:

Fè generally ask our long-established vendor partne rsfor àc/p this timeof year in subsidizing various employee F/?tzakçg/v jng and Christmasevents. 1 would /ïkc to askyour consideration this year in subsidizing ourChildren 's Christmas rlr/ .p @ $5,800. This will help provide food J/llg#s to employee children up to 12 years ol4 andprov ide tza opportunityfor (Company #11 to gain good will andpress within Jnl without the #PUorganization.

30. On or about November 7, 2012, Employee //1 sent all email to Company #4,

which stated, in part:

F'c generally ask our long-established vendor partn ersfor help this time ofyearin subsidizing various employee Thanksgiving and Ch ristm as events. 1 would /ï/reto ask your consideration this year in subsidizing our Children 's Christmas #1r@@ $5,800. This will àc/p provide food and g#s to em ployee children up to 12

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years ol4 tzatf provide Jn opportunity for fcompany #41 to gain good will tzatfpress within andwithout the #1z'L/ organization.

31. On or about November 2012, Employee //1 sent an em ail to W ES

ROSENABALK Co-conspirator #1. and others, which, in part stated:

1 talked with (employee) @ fcompany #4l and he agre ed to rlz/l the requestfor;J, 800 up the pole, but Ntzy.& l'Company #41 is in afreeze on cash expenditures do(sic) to poorhnancials.

32. On or about November 8, 2012, W ES ROSENBALM sen t an email to Employee

#3 directing him to contact Company #3 and ask them to pay $4,125.00 for a b%ketball scorer's

table for his children's school. W ES ROSENBALM 'S st ated, in part:

1 e tpw we just hit up ffltmrtza.y #3lfor the Christ mas #1rf.y but wouldyou askthem fthey would consider this since it can be paid over three years. This isfor(School #1.1.

()n or about Novem ber 14, 2012, Em ployee //3 folwar ded W ES ROSENBM M 'S

em ail to the President and CEO of Com pany #3. On or about Novem ber 15, 2012, the President

and CEO of Company //3 sent an email to Employee #3 , which stated, in part:L'uv,nnt*.N

1 am assuming this is the school that Fc,& kids go to. Is hejust lookingfor tosponsor this or is he wanting me topay to Jftzvc Bv uput on the table?

34. On or about November 14,2012, Co-conspirator // 1 sent an em ail to W ES

ROSENBM M stating that Company //4 would pay for the Bristol Virginia Utilities Authority

Children's ChrisM as party. An invoice was sent to C ompany #4 requestzg pam ent in the

amount of $5,800.00. Company M paid Bristol Virginia Utilities Authority $5,800.00. Both

Co-conspirator //1 and W ES ROSENBALM had children w ho received gifts from the $5,800.00

paid by Company #4.

35. On or about December 3. 2012. Company #3 issued a check in the amount of

$4,125.00 to pay for a basketball scorer's table fo r School #1, at wllich W ES ROSENBALM 'S

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children attended and he had been a member of the B oard of Directors. Company #3 paid for the

scorer's table because of the fear that a failure t o make such pam ent would result in economic

harm to Com pany #3's ongoing business w1t11 Bristol Virginia Utiliées Authority and that W ES

ROSENBALM and Co-conspirator #1 would provide less favorable treatment to Company #3.

36. On or about January 3. 2013, Co-conspirator //1 ,* t11 the u owledge and assent of

W ES ROSENBM M directed Employee //3 to contact Compa ny #3 and direct them to pay an

invoice from the Foundation Event Facility in the a mount of $12,297.18, which refleded the

costs to Bristol Virginia Utilities Authority for t he 2012 Employee Chrismlas Party held on

December l5, 2012. Co-conspirator //1 further direc ted that she preferred that Company #3 pay

the Foundation Event Facility directly. An invoice w as sent to Company #3 via email from

Bristol, Virginia to South Carolina.

On or about January 9, 2013, Company //3 issued a c heck to the Foundation Event

Facility in the nmount of $12,297.18. Company #3 pai d for theBristol Virginia Uilities

Authority Employee Christmms Party because of the f ear that a failure to m ake such payment* ,*,.

would result in economic hnrm to Com pany #3's ongoi ng business w1t.11 Bristol Virginia Utilities

Authority and that W ES ROSENBM M and Co-conspirator #1 would provide less favorable

treatment to Company #3.

Defm ud the Internal Revenue Service

Cmsh Bonuses and CWR Cards

38. On or about and between M arch 10, 2003, and Apr il 1, 2013, Bristol Virginia

Utilities Authority and its predecessor Bristol Vir ginia Utilities Board knowingly and

intentionally paid bonuses to employees outside of the norm al pav oll system . These bonuses

were paid in the fonn of cash and gift cards.

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39. On or about and between M arch 1û, 2003, and Apr il 1, 2013, Bristol Virginia

Utilities Authority and its predecessor Bristol Vir ginia Utilities knowingly and intentionally did

not report these bonuses to the Intem al Revenue Ser vice in the form of Intemal Revenue Service

W -2 or 1099 form s.

40. On or about and between January 1, 2009, and Ap ril 1, 2013, Bristol Virginia

Utilities Authority and its predecessor Bristol Vir ginia Utilities Board paid bonuses to employees

in an amount of at least $48,000.00 which was not t axed nor reported to the Internal Revenue

Service. Form W -2 subm itted to the Intem al Revenue Service fraudulently stated the incom e

received by Bristol Virginia Utilities Authority an d Bristol Virginia Uélities Board employees.

41. On or about and between M arch 10, 2003, and Apr il 2013, W ES

ROSENBALV as Chief Executive Offcer, knew that Inte rnal Revenue Service W -2 forms sled

with the lnternal Revenue Service in fact did not c ontmin acclzrate inform ation and contained

gaudulent alld false information, nam ely, that thes e form s did not accurately reflect the

compensation paid by Bristol Virginia Utilities Aut hority and its predecessor Bristol Virginia

Utilities Board to its employees.

42. On or about July 13, 2007, Co-conspirator //1 s ent an email to a Bristol Virsnia

Uélities Board employee stating, in part

JC./t#? you spare $500 out (7//?://.3/ cash for me this a.m. It is to pay abonus to an employee.

43. On or about December 5, 2008, Co-conspirator // 1 sent an em ail to W ES

ROSENBALM and others. stating, in part,

JFe,&, I'Employee #31 came by this a.m. and asked w hat wd could do for the watercrcw - they were out to aAer l a.m. and as wd know they all missed the rlrf.ywith wfe 's (sic) that were all dressed up and nowh ere to go... ..lEmployee #3land 1 are of the opinion to give each a $200 gt/i c ard as appreciation for theirdedication and enough to /J1e wfe ',: out (sic) -- or whatever they want to do.

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44. On or about D ecem ber 8, 2008. Co-conspirator // 1 sent an em ail to employees of

Bristol Virginia Utilities Board asking th- to issu e nine $200 g1f1 cards to be provided to tlle

water crew employees who had missed the Bristol Vir ginia Utilities Board Christmas party.

45. On or about M ay 9, 2009, Co-conspirator //1 sen t an email to a Bristol Virginia

Board employee, stating:

fEmployee #41, cfza you please provide me $500 from your rc//z cashbalance. m mployee #J ./ this will be paid to a SP7.7 employee as a bonusfor Optinet (set top box recovery). For each $26k i n set top boxesrecovered $500 bonus ispaid.

46. On or about September 24, 2009, Co-conspirator //1 sent an em ail to accounting

stnW at Bristol Vir/nia Utilities Board stating, in part:

X le are going to buy $2k in g# cards for use for th e remainder of theJiscal yearfor employee incentives/employee g#à', e tc.

47. On or about November 20, 2009, Co-conspirator / /1 sent an em ail to W ES

ROSENBM M , stating, in part:

mcx, each year 1 have given $50-$100 to my accounti ng ,j'/l -#'l.#er the completedaudit. 1 would D/cc to do that again this year - 1 did budgetfor this. It will be atotal of9 gtft cards.

48. On or about December 8, 2010, Co-conspirator // 1 sent an em ail to the conkoller

of Bristol Virginia Utilities Authority and stated, in part'.

1 really would like to give /7SW gdt ctzrA to every onefor their bonus - doyou feel strongly wg need to ma it through payroll? It will be a total of$5k.

The controller rem onded via em ail:

Visa cards are easier, but they are still ta able in come. V' wc rlm itthrough payroll, that removes anypotential liabilit y on this.

ln a latc email, the controller stated:

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I'Tlhe IM Wcw,& gdt ctzrtf,ç the same as cash. Any cash payment isconsidered tnrnble.

In a later em ail, Co-conspirator //1 stated:

1 would still rather do gft cards : (

ln response, tlze contoller replied Wa email:

1 would to, (sic) but technically running it throug h payroll is the rightthing to do.

49. On or about January 25, 2011, Co-conspirator // 1 sent an em ail to an employee at

Bristol Virginia Utilities Authority stating, in pa rt:

l'Employee #4 .1, will you please bring me a total ofssoofrom re/f y cash topay out this $25k recovery milestone. I will need t he $500 packaged thefollowing wtzy.'

(Employee #61 $80fEmployee #7l $65l'Employee #81 $355

50. On or about September 2, 2011, Co-conspirator #1 sent an em ail to W ES

ROSENBALM 'S wife and others th1 stated, in part:

1 am hoping to get to the mall /tktft,y to purchase $2500 in g# cards forsp't7 to use tofor employee incentiveplans, etc.

51. On or about Septem ber 6, 2011, Co-conspirator # 1 sent an email to a Bristol

Virginia Utilities Authority employee that stated, in part:

$500 - can you see fwe have $500 in rcf/.y cash top ay m mployee #7) hisbonusfor the recovery of$25 in set top boxes. F/fAN #&

52. On or about Septem ber 18, 20011, Employee #8 se nt an email to Co-conspirator

//1 that stated, in part:

W o-conspirator #1J(Employee #71 has reached the 25000 plateau for the 500 bonus. lfyoucouldget itfor him it would be appreciated

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In response, Co-conspirator #1 th0 sent an email to Employee #4 that stateda in

part:

Can you get $500for mefrompetty cash?

53. On or about October 31, 2011, W ES ROSENBM M sent an em il to Co-

conspirator //1 and others stating, in part:

1 need 5 $25 g#i cardsfor birthdays this month.

54. On or about November 30, 2011, W ES ROSENBM M sent an emil to Co-

conspirator #1 and others stating. itl part:

1 need 14 $25 g#i cardsfor this month.r/lc/r-ç/ wil l go out F//zlrxstftzy.

55. On or about and between Septem ber 7, 2012, and September 8, 2012, W ES

ROSENBM M , using Bristol Virginia Utilities Authorit y fllnds, plzrchased #A cards in varying

amounts, totaling. $6.716.50, for use at Bristol Vi rginia Utilities Authority.

Use of Governm ent Vellicles for Personal Use

56. On or about and between July 2006 and July 2012 , W ES ROSENBALM and at

least five other employees at Bristol Virginia Util ities Authority and its predecessor Bristol

Virginia Utilities Board received the use of govem m ent owned vehicles for non-business related

personal use. Prior to July 2006. W ES ROSENBALM was paid a vehicle allowance of $500.00

per month. Subsequent to July 2012, when W ES ROSENB ALM no longer had the use of a

Bristol Virginia Utilities Authority vehicle for pe rsonal use, he was paid a monthly vehicle

allowance of at le%t $1,800.00.

57. On or about and between July 2006 and July 1, 2 012, W ES ROSENBALM , as

Chief Executive Om cer for Bristol V irginia Utilitie s Authority and its predecessor Bristol

Vir/nia Utilities Board, w11 the apeement of Co-con spirator #1, (Iid not report this taxable

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benetk to the Internal Revenue Service and provided false inform ation on W -2 form s regarding

the compensation provided to these employees of Bri stol Virginia Utilities Authority and its

predecessor Bristol Virginia Utilities Board. n is t u able benefit would have been at least

$6,000.00 per employee per year.

Colmtrv Club M emberships

58. On or about and between December 2007 and April 2015, Bristol Virginia

Utilities Authority and its predecessor Bristol Vir ginia Utilities Board paid for memberships at

the Bristol Country Club for W ES ROSENBALM , Co-cons pirator #1, and two other employees.

In total. more th% $69,748.00 was paid on behalf of these individuals to the Bristol Country

Club for m embership.This taxable benefit was not re ported to the Internal Revenue Service and

W -2 forms subm itted to the Internal Revenue Service for these four individuals contained false

and fraudulent information regarding the compensati on provided by Bristol Vir/nia Utilities

Authority and its predecessor Bristol Virginia Util ities Board.

Date- ' - ,.

llate:

a(l ,,/ysllate:

W G RosenbalmgeD efenda '

. o herty, sCounsel for efend nt

Zac T. IœeA ' tant U nited States Attorney

' inla State Bar No. 470:7

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