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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA :
:
v. : CRIMINAL NO. 14 -
:
GREGORY NAYLOR :


GOVERNMENT=S GUILTY PLEA MEMORANDUM

I. INTRODUCTION
On August 27, 2014, defendant Gregory Naylor (Naylor) was charged in a
three-count information with misprision of a felony in violation of Title 18, United States Code,
Section 4, a falsification scheme in violation of Title 18, United States Code, Section 1001(a)(1),
and false statements in violation of Title 18, United States Code, Section 1001(a)(2). The
charges arose from defendant=s knowledge and participation in two schemes initiated by his
long-time friend and former employer, Elected Official A.
In the first scheme, relevant to Count One in the Information, defendant Naylor
was aware of and helped conceal the theft of federal grant funds and other charitable funds which
were used to repay an illegal campaign debt incurred by Elected Official A during his candidacy
in the 2007 mayoral race in Philadelphia. Additional criminal activities related to this
transaction are described below. These include (1) creating false contracts between the parties
to justify the interstate transfer of the funds stolen to repay the illegal campaign loan, and (2)
filing false campaign reports which concealed the use of the stolen funds to pay back the illegal
campaign debt, among other things.

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Specifically, Naylor was aware that during the campaign, large amounts of money
from an unexplained source were being spent on Elected Official A's behalf, and he helped to
conceal the influx of campaign funds by preparing a false invoice. Naylor subsequently became
aware that Elected Official A and others orchestrated the theft of federal grant funds and other
charitable funds to repay the outstanding balance of the campaign debt, and he agreed to the
falsification of campaign finance reports in order to further conceal the elected official's
activities.
In the next scheme, relevant to Counts Two and Three in the Information, Naylor
conspired with Elected Official A to pay down portions of the college debt of the elected
official's son, using federal and mayoral campaign funds. The funds Naylor used to pay down
the debt were sent via U.S. mail to Naylor. Some of the payments originated directly from the
mayoral campaign fund, and some were illegally sourced from Elected Official A's federal
campaign election committee and passed through the mayoral campaign fund account to Naylor.
Naylor first made these improper payments at Elected Official A's request in August 2007, and
continued making them through April of 2011. The payments totaled approximately $22,663.
Naylor created IRS forms 1099 for 2007, 2008, and 2010 which falsely claimed that the
payments made on the son's college debt were earned income to Elected Official A's son for
services rendered by the son as an independent contractor to Naylors consulting firm. When
confronted about the payments by federal agents in investigative interviews, Naylor on two
occasions lied and repeated the cover story that the official's son was an independent contractor
working for Naylor's political consulting firm.


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II. PLEA AGREEMENT
The government and defendant have reached a plea agreement in which the
defendant will plead guilty to all counts of the information. An executed copy of the plea
agreement is attached as Exhibit A.
III. MAXIMUM PENALTIES
The Court may impose the following total maximum penalties: The maximum
penalty for a violation of Title 18, United States Code, Section 4 is three years imprisonment, a
one year period of supervised release, $250,000 fine and a $100.00 special assessment. The
maximum penalty for each violation of Title 18, United States Code, Section 1001 is five years
imprisonment, a three year period of supervised release, $250,000 fine and a $100.00 special
assessment. The total maximum penalty is thirteen years imprisonment, a $750,000 fine, a three
year period of supervised release, and a $300 special assessment.
IV. ELEMENTS OF THE OFFENSES
To prove that the defendant committed the crime of misprision of a felony in
violation of 18 U.S.C. ' 4, as alleged in Count One, the government must prove the following:
1. A federal felony was committed;
2. The defendant had knowledge of the commission of that felony;
3. The defendant failed to notify an authority as soon as possible. An "authority"
includes a federal judge or some other federal civil or military authority, such as a
federal grand jury, Secret Service or FBI agent; and
4. The defendant did an affirmative act, as charged, to conceal the crime.

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Pattern Crim. J ury Instr. 10th Cir. 2.08 (2011). See also, United States v. Gebbie, 294 F.3d 540,
544 (3d Cir. 2002).
To prove that the defendant committed a falsification scheme in violation of 18
U.S.C. 1001(a)(1), as alleged in Count Two, the government must prove the following:
1. The defendant had a duty to disclose material information;
2. The defendant falsified, concealed, or covered up such material information by
trick, scheme, or fraud;
3. The falsified, concealed, or covered up information was material;
4. The falsification and/or concealment was knowing and willful; and
5. The material information was within the jurisdiction of the executive, legislative,
or judicial of the government of the United States.
United States v. Mastronardo, 849 F.2d 799, 803 (3d Cir. 1988).
To prove that the defendant made false statements in violation of 18 U.S.C.
1001(a)(2) as alleged in Count Three, the government must prove the following:
1. The defendant made a statement or representation;
2. That the statement or representation was false;
3. That the false statement was made knowingly and willfully;
4. That the statement or representation was material; and
5. That the statement or representation was made in a matter within the executive,
legislative, or judicial branch of the Government of the United States. United States v. Castro,
704 F.3d 125, 139 (3d Cir. 2013).


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V. FACTUAL BASIS FOR PLEA

If this case were to proceed to trial, the government would present the following
facts to prove the essential elements of the offenses beyond a reasonable doubt.
COUNT ONE
Misprision of a Felony
1. Defendant Greg Naylor is a political consultant and former long-time employee of
Elected Official A. Naylor has been a close personal friend of Elected Official A for over
twenty years. Naylor founded and operates a consulting firm named Sydney Lei & Associates,
Inc. (SLA). SLA received significant income from its affiliation with the now defunct
Nonprofit 1, which was founded by Elected Official A. On one occasion, Elected Official A
contacted Naylor to tell him that he had obtained federal funding for Nonprofit 1, and that
Naylor should contact the nonprofit in order to secure federal funding for the benefit of Naylors
SLA by subcontracting with Nonprofit 1, which Naylor did. In 2007, defendant Naylor and SLA
worked on Elected Official A's unsuccessful campaign for Mayor of the City of Philadelphia.
2. Nonprofit 1was run by its Chief Executive Officer (CEO), Person A, also a
former employee of Elected Official A. For years, Nonprofit 1 was also responsible for
organizing an annual Conference on Higher Education named for Elected Official A. The
conference was supported financially in large measure by the Sallie Mae Fund, the charitable
arm of Sallie Mae, the student loan funder. Nonprofit 1 also received the vast majority of its
funding from the federal government, a fact well known to defendant Naylor. Specifically,
Nonprofit 1 received grant funding from the U.S. Department of J ustice (DOJ ), the
Department of Commerce, the National Aeronautic and Space Administration (NASA), and

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the National Oceanic and Atmospheric Administration (NOAA), among other federal
agencies.
3. Person B is a political consultant and was an operative of Elected Official A's
mayoral campaign. Person B was a founder and partner in a Washington, D.C. political
consulting firm, Company 1.
4. Person C is the spouse of a former staffer of Elected Official A and founder of a
for-profit Philadelphia-based public policy technology company, Company 2.
5. In 2007, Elected Official A ran for election as a candidate for Mayor of
Philadelphia, Pennsylvania. As his candidacy faltered and suffered in the polls, his campaigns
finances began to suffer significantly. The growing weakness in the campaigns finances was a
well-known and obvious fact to Elected Official A's inner circle which included, among others,
defendant Naylor.
The Scheme to Borrow $1 million for the Campaign
6. In April 2007, as his mayoral campaign funds were diminishing, elected Official
A lost a challenge to Philadelphias campaign finance contribution limits in the Pennsylvania
Superior Court. After losing in court, Elected Official A engaged in a scheme to violate the
applicable Philadelphia campaign finance laws and contribution limits by secretly arranging for
and receiving an illegal $1 million campaign contribution in the form of a personal loan from
long-time friend and political supporter, Person D.
7. Elected Official A and his confederates routed the $1 million contribution from
Person D through the political consulting firm, Company 1, which was also working on Elected
Official A's campaign. Person B and Company 1 executed a promissory note with Person D, and

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used the Person D-supplied funds - received via wire transfer - to pay various expenses of
Elected Official A's campaign directly in advance of the mayoral primary. Portions of the $1
million dollars were directed to defendant Naylors firm, SLA, and Naylor spent that money on
behalf of the campaign.
8. Between April 30, 2007 and primary Election Day, Person B and Naylor spent in
total approximately $600,000 from the loan proceeds in support of Elected Official A's mayoral
campaign. A portion of the $600,000 was spent on media buys. Approximately $200,000 in
cash was spent as walking around money in support of the campaign for Mayor on Election
Day itself. Naylor distributed the cash on Election Day.
9. Since Person B on behalf of Company 1 was the signatory on the promissory note
with Person D, and to have some documentation of the $200,000 in walking around money for
which Company 1 could be held to account by Person D, Person B requested Naylor to submit a
false invoice for the cash from SLA to Elected Official A's mayoral campaign. Naylor prepared
the false invoice from SLA and addressed it to the mayoral campaigns treasurer in the amount
of $193,580.19. At the time the invoice was prepared, Naylor was well aware that the campaign
did not owe SLA any money for the services detailed in the invoice, dated J une 1, 2007.
10. Elected Official A subsequently lost the primary election, which ended his
mayoral campaign. On or about J une 22, 2007, Person B returned the unspent $400,000 of the
loan proceeds to Person D, leaving a $600,000 loan balance.
11. After Elected Official A lost the mayoral primary, his campaign reported the
campaigns outstanding debt in its Campaign Finance Statement publicly filed with the
Commonwealth of Pennsylvania or about J une 15, 2007. In that Campaign Finance Statement,

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the campaign did not report the loan from Person D and falsely reported the outstanding
campaign debt to Naylors SLA in the amount of $193,580.19 as documented by Naylor in the
false invoice.
12. In late 2007, Person D experienced acute financial difficulty and instructed his
son to contact Person B at Company 1 to call in the debt. Person B reported Person D's demand
for repayment to elected Official A and his friends, associates, and former and current
employees, including defendant Naylor.
13. Naylor discussed the problem regarding the debt to Person D with elected Official
A, who told Naylor that he had a plan and was putting some things in place. Shortly after that
conversation, Naylor stopped receiving calls from Person B about the $600,000 Person D was
demanding.
The Fraudulent Scheme to Repay the $600,000 Debt Using Funds from Non-profits

14. Elected Official A arranged for Nonprofit 1 to route funds it received from the
Sallie Mae Fund and also federal grant funds to a company run by Person C, an ally of Elected
Official A, under the guise of a false contract for services. As described below, Person C's
company, Company 2, executed a fake contract with Person A's Nonprofit 1 to disguise the
movement of the money from Nonprofit 1 to Company 2. Company 2 and Company 1, the
political consulting firm operated by Person B, also executed a fake contract to disguise the
movement of money from Company 2 to Company 1, which money Person B then used to repay
Person D.
15. On J anuary 9, 2008, Person B received an email from Person C, owner of
Company 2, which suggested forming a strategic partnership between Company 1 and

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Company 2.
16. On J anuary 14, 2008, Person C emailed Person A at Nonprofit 1 with a proposal
for his company, Company 2, to allegedly provide public policy software for Nonprofit 1. In the
proposal, Person C sought substantial upfront funding.
17. On J anuary 24, 2008, Person B emailed Person C and provided him with wiring
instructions for a payment to be made to Company 1's bank account at United Bank in Bethesda,
Maryland.
18. Around this time, Person C advised the Chief Financial Officer (CFO) of
Company 2 that Company 2 would be receiving approximately one half million dollars from
Nonprofit 1, and that the CFO was to thereafter wire transfer $600,000 to Company 1. The CFO
objected to the wire transfer and pointed out to Person C that his entity, Company 2, was having
difficulty making payroll. The CFO also inquired what Company 1 would be providing
Company 2 in return for the $600,000 and inquired whether a contract existed. Person C told
the CFO that Company 2 would be receiving influence and political connections. Person C
instructed the CFO to make the wire transfer to Company 1 once the funds were received from
Nonprofit 1.
19. On J anuary 27, 2008 at 10:59 p.m., Person C sent to Person A via email a
proposed engagement agreement between Company 2 and Nonprofit 1. In the email, Person C
indicated that he would send someone to pick up the check at about 1 PM. Afterwards, at
11:12 p.m., Person C emailed to Person B a proposed contract between Company 2 and
Company 1. The contract promised an advanced sum of $600,000 to be paid by Company 2 to

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Company 1 by J anuary 31, 2008. Person B replied the same day at 11:13 p.m., inquiring of
Person C whether he received the wiring instructions for the payment to Company 1.
20. On J anuary 28, 2008, Person A wrote a check payable to Company 2 in the
amount of $500,000. In order to issue the $500,000 check from Nonprofit 1, Person A used
$500,000 received by Nonprofit 1 from the Sallie Mae Fund which was intended by the donor to
support the annual Conference on Higher Education named for Elected Official A. In fact, by
accepting the donation, Person A and Nonprofit 1 certified to the Sallie Mae Fund that the
money would be used for no other purpose than the Annual Conference on Higher Education.
21. Also on J anuary 28, 2008, Person A responded to Person C at Company 2 from
the Nonprofit email account. In the response, Person A advised Person C that You can pick up
the check today as discussed, but as I stated I am not in a position to sign a contract committing
funds that I am not sure that I will have. In fact, Person A did not sign a version of Person C's
contract with Company 2 until August of 2008. No work justifying the $500,000 advanced
payment from Nonprofit 1 to Company 2 was ever performed.
22. On J anuary 28, 2008, at Person C's direction, Company 2's CFO emailed Bank of
America and requested a draw down on Company 2's line of credit in the amount of $150,000.
The line of credit supplied by Bank of America to Company 2 was secured by assets belonging
to Person C's spouse, a former staffer for Elected Official A. The CFO asked Bank of America
to wire the money to Company 2's operational account. According to the CFO, the draw down
was necessary in order to add $100,000 to the $500,000 received from Nonprofit 1 in order to
make the $600,000 wire transfer to Company 2, as demanded by Person C. Company 2 used the
$50,000 balance from the draw down on the line of credit to pay Company 2's ordinary expenses.

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23. On J anuary 30, 2008, Person B emailed Person C at Company 2 with a subject
line, You are killing me. In the message section of the email, Person B wrote, I made a
commitment based on yours to me. Please dont drag this out. I have a lot on the line.
24. On J anuary 31, 2008, Company 1 received a $600,000 payment by wire transfer
from Company 2. No work justifying the $600,000 advanced payment from Company 2 to
Company 1 was ever performed. That same day, Company 1 sent $600,000 by wire transfer to
Person D, settling the outstanding loan balance.
25. The accounting records for Company 2 falsely labeled the transaction from
Nonprofit 1 to Company 2 as Developmental Income, and the transaction from Company 2 to
Company 1 was falsely labeled a marketing expense.
26. Sometime after Company 1 sent the $600,000 by wire transfer to Person D's
account, Naylor discussed the arrangement with Elected Official A. Elected Official A told
Naylor that he had resolved the problem with Person D by arranging to have funds moved from
Nonprofit 1 to Company 2 to Company 1 for the purpose of satisfying the debt to Person D.

27. In March of 2008, Person C began to contact Person A to inquire about the
contract between Company 2 and Nonprofit 1 which was unsigned by Person A even though
Person A had already routed money from Nonprofit 1 to Company 2 months earlier. While
Person C was attempting to reach Person A, auditors from the United States Department of
J ustice (DOJ ) were performing an audit of Nonprofit 1 regarding federal funds it had received.
On March 23, 2008, Person A responded to Person C by email and stated, in part, [The DOJ
auditors] are still very uncomfortable with your [proposed] contract amongst other things and
depending on their findings some of the [federal grant] funding may have to be returned . . . And
you should know in the future that as a result of the DOJ audit I will not be in a position to do
another contract such as this.

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28. In order to make Company 2 whole for its $600,000 wire transfer to Company 1,
on May 20, 2008, Person A supplemented the $500,000 which Person A had already provided
by Nonprofit 1 check to Company 2 with a second Nonprofit 1 check payable to Company 2 in
the amount of $100,000. To issue the check, Person A used funds Nonprofit 1 received from
Nonprofit 2, another entity founded by Elected Official A. Nonprofit 1 originally received the
funds by cashier's check from Nonprofit 2 dated May 19, 2008 in the amount of $225,000.
Nonprofit 1 documented the $225,000 cashier's check in its books as a loan payable. A review
of the books and records of Nonprofit 1 reveals that the payments to Company 2 were falsely
classified as computer center:database for the J anuary payment and consulting for the May
payment.
29. In order to repay Nonprofit 2 for the $100,000 Nonprofit 1 "borrowed" from it to
write the second check to Company 2, Person A drew on funds received by Nonprofit 1 via a
federal grant in the amount of $1,807,757 from the National Aeronautics and Space
Administration (NASA). Under the terms of NASAs grant, the funds were intended to support
a Math, Science, & Technology Enrichment Program for members of underrepresented
groups in the City of Philadelphia. Person A, in fact, certified to NASA that was the case.
Nonprofit 1 received the first draw down on the NASA grant on J une 13, 2008 and placed the
funds in Nonprofit 1's operating account. Person A then wrote a check drawn on Nonprofit 1's
operating account to Nonprofit 2 in the amount of $415,000 which included repayment of the
$100,000 Person A used from Nonprofit 2 to pay Company 2. Person A never disclosed to
NASA that $100,000 from the NASA grant was used to repay a loan from Nonprofit 2 to

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Nonprofit 1, which loans funds Person A and Nonprofit 1 had illegally used to pay Company 2
on May 20, 2008.
30. While the DOJ audit was ongoing and Person A continued to attempt to explain
Nonprofit 1's questionable finances to the auditors, DOJ s Office of Inspector General (DOJ
OIG) issued a subpoena duces tecum on or about J uly 17, 2008 to Person C's company,
Company 2, seeking any and all contract documents, invoices, correspondence, timesheets,
deliverables, and proof of payment, related to any services provided to or payments from
[Nonprofit 2 or Nonprofit 1]. By August 26, 2008, Company 2 had still not responded to the
DOJ OIG subpoena, and DOJ OIG contacted Person C by email to inquire as to the delay.
31. In the interim, on or about August 1, 2008, Person C contacted Person A by email
with a revision Person A had previously requested to the contract between Company 2 and
Nonprofit 1. After Person C made the revision, Person A subsequently executed the contract on
behalf of Nonprofit 1, during the DOJ audit, after the issuance of the subpoena, and nearly seven
(7) months after Nonprofit 1made the initial payment of $500,000, which funds, ultimately, were
used to repay Person D.
32. On or about February 1, 2010, Elected Officials A's mayoral campaign again
falsely reported the outstanding campaign debt to SLA in the campaigns Campaign Finance
Statement, publicly filed with the Commonwealth of Pennsylvania. In this filing, however, the
campaign falsely listed an in-kind contribution of $20,000 from Naylors SLA to the
campaign. The campaign also documented two expenditures to SLA, one for $5,000, and the
second for $1,500. The campaign claimed both expenditures were for Election Day Operation
Expenses. Correspondingly, the campaign reduced its alleged debt to SLA from $193,580.19

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to $167,080.19. Prior to submitting the Campaign Finance Statement to the state, the mayoral
campaigns Treasurer telephoned Naylor and told him that the debt to SLA would be reduced on
the campaign disclosure form. As the debt to SLA was non-existent in the first place, Naylor
acknowledged what the campaign Treasurer was going to do and voiced no objection.
33. The deception has continued, as false entries were submitted in Elected Official
A's mayoral campaigns publicly filed Campaign Finance Report further reducing the alleged
debt to SLA as recently as J anuary 31, 2014. Each Campaign Finance Report is signed by
Elected Official A affirming that his campaign has not violated any provisions of the
applicable campaign finance laws.

COUNTS TWO AND THREE
Falsification Scheme and False Statements
34. The Federal Bureau of Investigation (FBI) is an agency and department of the
United States with the jurisdiction to investigate criminal violations of the federal law, including
violations of the Federal Election Campaign Act of 1971, as amended, Title 2, United States
Code, Sections 431, et seq.
35. The Internal Revenue Service (IRS) is an agency and department of the United
States with the jurisdiction to investigate violations of the federal tax laws.
36. In 2007, Elected Official A initiated a scheme by which Naylors consulting
company, SLA, would pay down Elected Official A's son's student loan debt to a university
and/or a student loan funding entity, which debt at one point was over $100,000.
37. Elected Official A told Naylor that he would reimburse SLA for the student loan
payments. Financial records from Elected Official A's congressional campaign, mayoral

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campaign, and SLA show that between 2007 and 2011 Naylor, through SLA, paid a university l
and later a student loan funding entity, which held the student loan, a total of approximately
$26,663. Naylor received checks signed by the Treasurer of Elected Official A's defunct
mayoral campaign drawn on the mayoral campaigns account. In turn, Naylor issued checks
from SLA to Drexel and/or Sallie Mae. As detailed below, the mayoral campaigns Treasurer
made numerous transfers from Elected Official A's congressional campaign fund to the mayoral
Campaigns account in order to fund the checks to Naylor which were used to pay down the
student loan debt.
38. Specifically, at the beginning of the execution of the scheme, on approximately
J anuary 7, 2008, the Treasurer for both Elected Official A's congressional and mayoral
campaigns moved $10,000 from the congressional campaign fund to the mayoral campaign in
order to write a check to from the mayoral campaign to Naylors SLA in the amount of $10,900.
Naylor, in turn, used the $10,900 SLA received from Elected Official A's mayoral campaign to
make payments on the student loan debt owed by the Elected Official's son. Later during the
scheme, on November 23, 2010, the Treasurer moved an additional $5,000 from the
congressional campaign account to the mayoral account in order to write a $5,000 check to
Naylors SLA. The memo section falsely documented election day expenses as the reason for
the check. Naylor in turn used the $5,000 SLA received to make additional payments on the
student loan debt. Between 2008 and J anuary of 2011, an additional $7,663.52 was taken from
the mayoral account, transferred to Naylors SLA, and used by Naylor to make additional
payments on the student loan debt. In all, Naylor made thirty-three payments totaling $22,663
on behalf of the Elected Official A's son using misappropriated funds from Elected Official A's

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campaign accounts.
39. In order to conceal the scheme over a period of years from detection and
prosecution by law enforcement officials and the federal judiciary, as well as from exposure by
the news media and also to avoid the appearance of taxable income to SLA as a result of serving
as a conduit for the student loan payments from the Elected Official A's congressional campaign
funds, Naylor created false IRS form 1099s for 2007, 2008, and 2010. Each form 1099
concealed the misuse of campaign funds by falsely claiming that the payments made at Elected
Official A's direction on behalf of his son to retire the sons college debt were earned income
to the son. Naylors serial false submissions reported to the government that the payments were
for services rendered by the son as an independent contractor to Naylors consulting firm, SLA.
40. Defendant Naylor was interviewed on J anuary 30, 2013 about the conduit scheme
and misuse of campaign funds by federal agents from the Internal Revenue Service and the FBI.
In that interview, Naylor falsely claimed that Elected Official A's son was on a retainer to
perform services for SLA, such as running errands and taking photographs for SLA, which
assertion Naylor knew was false. Naylor further falsely claimed that he issued IRS forms 1099
in 2007, 2008, and 2010 for the work done by Elected Official A's son.
41. Federal agents from the IRS and FBI re-interviewed defendant Naylor on April
10, 2013. During that interview, Naylor reaffirmed his earlier false statements and repeated that
Elected Official A's son was on a retainer to perform services for SLA as an independent
contractor.

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42. Naylors statements to the IRS and the FBI were false because Elected Official
A's son performed no services for SLA and the tuition debt payments made by Naylor for the
son were not earned income to the son.
43. Naylor engaged in the conduct described above knowingly, corruptly, and
willfully, and not because of accident, mistake, or other innocent reason. This memorandum sets
forth only the essential facts necessary that would need to be proven to establish the elements of
the offenses charged. It does not include each and every fact known to defendant or the
government, and it is not intended to be a full enumeration of all of the facts surrounding
defendants case or his knowledge or participation in the schemes described.
Respectfully submitted,

ZANE MEMEGER J ACK SMITH
United States Attorney for the Chief, Public Integrity Section
Eastern District of Pennsylvania


s/ Paul L. Gray s/ Eric L. Gibson
Paul L. Gray Eric L. Gibson
Assistant United States Attorney Trial Attorney & Special Asst. U.S.
Attorney

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the Government=s Guilty Plea
Memorandum has been served by Electronic Court Filing and e-mail upon the following:
Robert J . Levant, Esquire
Levant and Martin
320 North 18
th
Street
Philadelphia, PA 19103

Counsel for Gregory Naylor



/s/ Eric L. Gibson
ERIC L. GIBSON
Trial Attorney and Special Asst. U.S. Attorney


DATED: August 27, 2014