Beruflich Dokumente
Kultur Dokumente
UNITED STATES OF
AMERICA :
Y.
ELLENCHAPMAN
LAWRENCE FARNESE
Date
Filed:
VIOLITiONS:
'2016
5 counts)
18 U.S.C. S$ 1341,1346,2
count)
l8 U.S.C. $$ 1952(aX3) and 2 (Travel
Act-6 counts)
Fraud-l
INDICTMENT
THE GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS
At all times relevant to this Indictment:
l.
political pa(ies in the City of Philadelphia, the city is divided into approximately 66 wards.
2.
3.
The members of the Democratic Party ward committees are typically elected by
the neighborhoods that compose the ward ("divisions"), with each division electing two persons
to serve on the ward committee. [n the case of a vacancy between elections, ward commiftee
members can be appointed.
4.
The ward committee members elect a ward leader, who is responsible for
organizing the political activities ofthe party within the ward and who represents the ward on the
Democratic Party's City Committee.
5.
The duties and responsibilities of ward commiltee members are set lbrth in the
Rules of the Democratic Party of the City and County of Philadelphia, which provide that ward
commiftee members are obligated to be faithful to the Democratic Party and to act in the "best
interests of the party."
6.
Committee.
7.
8.
l.
9.
Famese.
COUNT ONE
CONSPIRACY
18
10.
Paragraphs
u.s.c. s 371
herein.
II
I to in or about December
District
Mail and Wire Fraud: to devise and intend to devise a scheme and artifice to
defraud and to deprive the Democratic Party. the members olthe Democratic
Party, the Democratic Eighth Ward, and the Eighth Ward Democratic Committee,
of their intangible right to the honest services of CHAPMAN tfuough bribery, and
to detiaud and to obtain money fiom the Friends ofFarnese campaign by means
l34l,
Bribery in Violation of the Travel Act: to use, and aid, abet. and cause to be
used, a
Title l8
Ann.
and accepting $6,000 from FARNESE and Person A to pay for a college study-abroad progam
tbr CHAPMAN's daughter, in exchange for which CHAPMAN agreed to use her position as a
party official on the Eighth Ward Democratic Committee to vote for FARNESE for Democratic
Ward Leader of the Eighth Ward.
13.
GHAPMAN's vote for FARNESE for Democratic Ward Leader of the Eighth ward by providing
CHAPMAN with a $6,000 payment from Friends of Famese to pay the tuition for CHAPMAN's
daughter's study-abroad program.
14.
a.
CHAPMAN agreed and intended to take action in her capacity as Eighth Ward
Democratic Committee Member, including voting for FARNESE for Democratic
b.
c.
FARNESE and Person A attempted to conceal and did conceal their crimes by,
among other things, causing Friends of Famese to file a campaign finance report
OVERT ACTS
15.
FARNESE, Person A and others known and unknown to the Grand Jury, committed the
a.
On or about
May
18, 201
Democratic Ward Leader of the Eighth Ward, a position for which FARNESE
was a candidate, FARNESE and CHAPMAN had a conversation in which
FARNESE agreed to help fund the tuition for CHAPMAN's daughter's studyabroad program through Bard College.
b.
CHAPMAN was switching her position to vote fbr FARNESE for Democratic
Ward Leader for the Eighth Ward instead of Person B, as CHAPMAN had
previously intended.
c.
l, FARNESE
"Hi
Ellen, Just wanted to thank you again for taking the time to chat with me
yesterday. Your support and vote for me as Ward leader is something I sincerely
appreciate it [sic.]."
d.
needed'Just over $14,000" to cover the tuition for the study-abroad program.
e.
subject line "Funding" that read, "Ellen, When does she actually need the money
f.
On or about May
g.
h.
On or about May
wrote an email to FARNESE with the subject line ''Re: Chapman daughter
money" that read, "ok,just spoke to both ellen and her daughters father...they are
going to get back to us with details on who the check should be *ritten too [sic].
She said
that'-though
leader and
she had some suggestions about some things we could say and
she's going to get back to me in the next day or two,.ts I was calling at a bad time
for her to chat more." (ellipses in original)
i.
On or about May
j.
On or about May
she
was cool."
k.
for
l.
On or about
of
Friends of Famese to send a check in the amount of$6,000 drawn on the Friends
campaign finance report with the City of Philadelphia and the Commonwealth
of
WIRE FRAUD
16.
Paragraphs
17.
I through
if fully
set forth
herein.
l,
Eighth Ward, and the Eighth Ward Democratic Committee, of their intangible right to the honest
services of CHAPMAN through bribery, and to defraud and to obtain money tiom the Friends
Famese campaign by means offalse and fraudulent pretenses, representations and promises.
18.
On or about the dates listed below, in the Eastem District ofPennsylvania, the
defendants, for the purpose ofexecuting the above-described scheme and aflifice to defraud,
deprive. and obtain money, and attempting to do so, sent and caused to be sent by wires in
interstate commerce the following wire communications:
Wire
Date
May 23,2011
May 24,2011
.+
July 12,201I
July I 2, 201 I
Count
of
of
person."
6
July 19,201I
COUNT SEVEN
MAIL FRAUD
18 U.S.C. $S 1341, 1346,a.nd2
19.
Paragaphs
20.
From in or about May 2011 to in or about December 2011, in the Eastem District
as
iffully
set forth
herein.
Eighth Ward, and the Eighth Ward Democratic Committee, of their intangible right to the honest
services of CHAPMAN through bribery, and to defraud and to obtain money from the Friends
Farnese campaign by means
21.
of
l,
the purpose ofexecuting the above-described scheme and artifice to defraud, deprive, and obtain
money, and attempting to do so, knowingly placed and caused to be placed in an authorized
depository for United States Mail, to be sent and delivered by the United States Postal Service, a
check to Bard Cotlege for $6,000 drawn on the bank account of Friends of Famese.
l0
TRAVEL ACT
18 U.S.C. $$ 1952(aX3) and 2
22.
Paragraphs
23.
From in or about May 201'l to in or about December 201I' in the Eastem District
I through
herein.
facility in interstate and foreign commerce with the intent to promote, manage, establish,
carry on, and facititate the promotion, management, establishment, and carrying on of an
unlawful activity, namely, bribery, contrary to Title l8 Pa. Cons. Stat. Ann.
4701' and
carrying on, and facilitation of the promotion, management, establishment and carrying on of the
above unlawful activity:
Date
May 23,2011
May 24,2011
l0
July 12,201 I
ll
Juty 12,201I
t2
Count
l3
of
A TRUE BILL:
Trial Attomeys
Public Integrity Section
1Z