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IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF

AMERICA :

Y.
ELLENCHAPMAN
LAWRENCE FARNESE

CRIMINAL NO. 16-

Date

Filed:

VIOLITiONS:

18 U.S.C. $ 371 (Conspiracy-l count)


18 U.S.C. SS 1343, 1346,2 (Wire Fraud-

'2016

5 counts)

18 U.S.C. S$ 1341,1346,2

count)
l8 U.S.C. $$ 1952(aX3) and 2 (Travel
Act-6 counts)

(Mail

Fraud-l

INDICTMENT
THE GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS
At all times relevant to this Indictment:

l.

For purposes oforganizing the activities ofthe Democratic and Republican

political pa(ies in the City of Philadelphia, the city is divided into approximately 66 wards.

2.

The Philadelphia Democratic Party (the "Democratic Party") has a committee in

each ward ("ward committee").

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.

Defendant ELLEN CHAPMAN was a member of the Eighth Ward Democratic

Committee.

7.

Defendant LAWRENCE FARNESE was a Pennsylvania State Senator and a

candidate for Democratic Ward Leader of the Eighth Ward in 201

8.

l.

Friends of Famese was a political committee organized to support defendant

FARNESE's campaign for the Pennsylvania State Senate.

9.

Person A was a political consultant; one of Person

A's clients was Friends of

Famese.

COUNT ONE

CONSPIRACY
18
10.

Paragraphs

u.s.c. s 371

through 9 of this Indictment are re-alleged as if fully set forth

herein.
II

From in or about May 201

I to in or about December

201 I , in the Eastem

District

of Pennsylvania, the defendants,

ELLEN CHAPMAN ANd


LAWRENCE FARNESE,
did knowingly and willfully conspire and agree with one another and Person A, and others
known and unknown to the Grand Jury, to commit offenses against the United States, that is:

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

offalse and fraudulent pretenses, representations and promises, in violation of l8


U.S.C. $$
b.

l34l,

343, and 1346; and

Bribery in Violation of the Travel Act: to use, and aid, abet. and cause to be
used, a

facility in interstate and foreign commerce with the intent to promote,

manage, establish, carry on, and facilitate the promotion, management,

establishment, and carrying on of an unlawful activity, namely, bribery, contrary


to

Title l8

Pa. Cons. Stat.

Ann.

$ 4701, and thereafter

to perform and to attempt

to perform such promotion, management, establishment, carrying on, and

facilitation of the promotion, management, establishment and carrying on of the


above unlawful activity, in violation

of l8 U.S.C. $$ 1952(a)(3) and 2.

PURPOSE OF THE CONSPIRACY


12.

It was a purpose of the conspiracy for CHAPMAN to enrich herself by soliciting

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.

It was a purpose ofthe conspiracy for FARNESE and Person A to buy

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.

MANNER AND MEANS

14.
a.

The manner and means ofthe conspiracy included the following:

CHAPMAN agreed and intended to take action in her capacity as Eighth Ward
Democratic Committee Member, including voting for FARNESE for Democratic

Ward Leader of the Eighth Ward.

b.

In exchange for CHAPMAN's vote, FARNESE and Person A provided

CHAPMAN with funds from Friends of Famese for CHAPMAN's daughter's


study-abroad program.

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

with the City of Philadelphia and the Commonwealth of Pennsylvania falsely


listing the tuition payment as a "donation".

OVERT ACTS

15.

In lurtherance of the conspiracy, and to accomplish its purposes, CHAPMAN,

FARNESE, Person A and others known and unknown to the Grand Jury, committed the

following overt acts, among others, in the Eastem District of Pennsylvania:

a.

On or about

May

18, 201

l, in anticipation of the upcoming election for

Democratic Ward Leader of the Eighth Ward, a position for which FARNESE
was a candidate, FARNESE and CHAPMAN had a conversation in which

CHAPMAN, who had intended to support another candidate, Person B, agreed to


vote for FARNESE for Democratic Ward Leader for the Eighth Ward and

FARNESE agreed to help fund the tuition for CHAPMAN's daughter's studyabroad program through Bard College.

b.

On or about May 18,

201l, after her conversation with FARNESE, CHAPMAN

had a conversation with Person B in which CHAPMAN advised Person B that

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.

On or about May 19, 201

l, FARNESE

sent CHAPMAN an email that read,

"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.

On or about May 23,20 I I , CHAPMAN sent FAI(NESE an email with

information about CHAPMAN's daughter's study-abroad program, including the


fact that CHAPMAN's daughter had received a $10,000 scholarship but still

needed'Just over $14,000" to cover the tuition for the study-abroad program.

e.

On or about May 23,2011, FARNESE sent an email to CHAPMAN with the

subject line "Funding" that read, "Ellen, When does she actually need the money

in hand? If it's later I have an idea."

f.

On or about May

g.

On or about May 24,2011, shortly after CHAPMAN and FARNESE spoke by

24,201I, FARNESE called CHAPMAN.

phone, Person A called CHAPMAN.

h.

On or about May

24,201l, after his conversation with CHAPMAN, Person A

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

'I told famese I'd support him for ward

that'-though

leader and

I'm going to honor

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

24,201I, FARNESE responded to Person A's email, "ok.

Good. Did she get mad?"

j.

On or about May

24,201l, Person A responded to FARNESE, "no not at all,

she

was cool."

k.

On or about July 12,2011 , Person A emailed an invoice for the tuition

for

CHAPMAN's daughter's study-abroad program to the treasurer of Friends of


Famese, instructing the treasurer to put CHAPMAN's daughter's name and

student identification number in the memo line of the check.

l.

On or about

Jtly 12,2011, FARNESE,

through Person A, caused the treasurer

of

Friends of Famese to send a check in the amount of$6,000 drawn on the Friends

of Farnese bank account by U.S. mail from Pennsylvania to Bard College in


Annandale, New York to help pay the tuition for CHAPMAN's daughter's studyabroad program.

m. In or about 2012, FARNESE

and Person A caused Friends of Farnese to file a

campaign finance report with the City of Philadelphia and the Commonwealth

of

Pennsylvania reporting the $6,000 expenditue to Bard College for CHAPMAN's

daughter's study-abroad tuition as a "donation" without mentioning either

CHAPMAN or her daughter.


In violation of Title I 8, United States Code, Section 3 7l

COUNTS TWO THROUGH SIX

WIRE FRAUD

l8 U.S.C. $S 1343, 13,16, and 2

16.

Paragraphs

17.

From in or about May 201I to in or about December 201

I through

15 of this lndictment are re-alleged as

if fully

set forth

herein.

l,

in the Eastem District

of Pennsylvania, the defendants,

ELLEN CHAPMAN ANd


LAWRENCE FARNESE,
aided and abetted by Person A, devised and intended to devise a scheme and artifice to defraud
and to deprive the Democratic Party, the members of the Democratic Party, the Democratic

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

Email communication f'rom Person A to FARNESE with the subject


line ''Re: Chapman daughter money."

.+

July 12,201I

Email communication from Person A to treasurer of Friends


Famese with the subject line "Fwd: Bard invoice."

July I 2, 201 I

Email communication from Person A to treasurer of Friends of


Famese with the subiect line "Fwd: Fw: Fwd: info for famese's

Count

Email communication from EARNESE to CHAPMAN with the


subject line, "Funding."

of

of

person."
6

July 19,201I

Wire transfer in the amount of 56,000 liom Friends of Famese


account in Philadelphia, PA to Bard College account in Annandale,
NY.

In violation of Title 18. United States Code, Sections 1343,1346. and2.

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

I through l5 olthis [ndictment are re-alleged

as

iffully

set forth

herein.

of Pennsylvania, the defendants,

ELLEN CHAPMAN ANd


LAWRENCE FARNESE,
aided and abetted by Person A, devised and intended to devise a scheme and artifice to defraud
and to deprive the Democratic Party, the members of the Democratic Party, the Democratic

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

offalse and fraudulent pretenses, representations and promises.

In or about July 201

l,

in the Eastem District of Pennsylvania, the defendants, for

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.

In violation of Title 18, United States Code, Sections 1341,1346,and2-

l0

COUNTS EIGHT THROUGH THIRTEEN

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

5 of this Indictment are re-alleged as

if fully set forth

herein.

of Pennsylvania, the defendants,

ELLEN CHAPMAN ANd


LAWRENCE FARNESE,
aided and abetted by Person A, knowingly and willfully did use, and aid, abet, and cause to be
used, a

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

thereafter performed and attempted to perform such promotion, management, establishment,

carrying on, and facilitation of the promotion, management, establishment and carrying on of the
above unlawful activity:

Date
May 23,2011

Facility in Interstate and Foreign Commerce


Email from FARNESE to CHAPMAN with the subject line,
"Funding."

May 24,2011

Email from Person A to FARNESE with the subject line "Re:


Chapman daughter money."

l0

July 12,201 I

Email from Person A to treasurer of Friends of Farnese with


the subject line "Fwd: Bard invoice."

ll

Juty 12,201I

Email from Person A to treasurer of Friends of Famese with


the subject line "Fwd: Fw: Fwd: intb lor famese's person."

t2

July 12, 201I

Check mailed from Philadelphia, Pennsylvania to Annandale,


New York.

Count

l3

July 19, 2011

Wire transfer in the amount of $6,000 from a Friends

of

Famese account in Philadelphia, Pennsylvania to a Bard

College account in Annandale, New York.

In violation of Title 1 8, United States Code, Sections 1952(a)(3) and 2.

A TRUE BILL:

Trial Attomeys
Public Integrity Section

1Z

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