Full Indictment MWilliam Campbell JR

Case 2:10-cr-00186-AKK -JEO Document 4 Filed 03/30/11 Page 1 of 41 FILED
2011 Mar-31 PM 04:27

U.S. DISTRICT COURT
N.D. OF ALABAMA
JWV/TMJ/GAM March 2011

DTF GJ #8
IN THE UNITED STATES DISTRICT COURT FOR THE

NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
UNITED STATES OF AMERICA *

*
v. * CR -
*
MAURICE WILLIAM CAMPBELL, JR.,* SUPERSEDING
also known as, BILL CAMPBELL, *
also known as, “SIR WILLIAM” *
Defendant. *
INDICTMENT
THE GRAND JURY CHARGES:
At all times material to this Superseding Indictment:
Introduction
1. Defendant MAURICE WILLIAM CAMPBELL, JR., in or about
January 2003, was hired as the State Director of the Alabama Small Business
Development Consortium (“the Consortium” or “ASBDC”). The Consortium was
comprised of four-year institutions in the State of Alabama – each of which had its
own small business development center – as well as a procurement technical center
and an international trade center. The ASBDC’s purposes were to enhance
economic growth, to provide management and technical assistance to small
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Case 2:10-cr-00186-AKK -JEO Document 4 Filed 03/30/11 Page 2 of 41
businesses, and to develop Alabama’s workforce. The State Director’s office was
located at the University of Alabama at Birmingham in Birmingham, Alabama, and
subsequently at the University of Alabama in Tuscaloosa, Alabama. In his role as
State Director, defendant MAURICE WILLIAM CAMPBELL, JR., in addition
to other duties, was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama.
2. In or about February 2005, defendant MAURICE WILLIAM
CAMPBELL, JR., incorporated the Alabama Small Business Institute of
Commerce (“the Institute” or “ASBIC”). Defendant MAURICE WILLIAM
CAMPBELL, JR. was the President, a director, the initial registered agent, and
incorporator of the Institute. The stated purpose of the Institute was to enhance
economic development, increase employment, and reduce business failure in
Alabama through business education and workforce training. The Institute was
formed as a nonprofit, with the representation that the corporation shall not be
operated for private profit, nor its assets at any time inure to the benefit of any
shareholder, member, director, trustee, officer or other private person. The
Institute was expressly organized exclusively for purposes authorized within
Section 501(c)(3) of the Internal Revenue Code, and for nonprofit purposes within
2
the meaning of the Alabama Code.
3. The Institute received nearly all of its funding from the State of Alabama
through grants, contracts, and appropriations in the education budget. From 2005
through 2010, the private nonprofit Institute received over seven million three
hundred thousand dollars ($7,300,000.00) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institute’s stated purposes.
Count One
Mail Fraud
Title 18, United States Code, Sections 1341 and 2
1. From in or about August 2004 and continuing to in or about August
2005, in Jefferson, Calhoun, and Etowah Counties within the Northern District of
Alabama, and elsewhere, the defendant,
MAURICE WILLIAM CAMPBELL, JR.,
aided and abetted by others known and unknown to the grand jury, did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama, the State of Alabama Department of Finance, and
others, and to obtain money and property by means of materially false pretenses,
representations, and promises, said scheme and artifice being in substance as
follows:
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Purpose of the Scheme and Artifice
2. It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL, JR. would and did use his position as State Director of
the Alabama Small Business Development Consortium (“ASBDC”) to obtain
money belonging to the State of Alabama.
3. It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL, JR. in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham, Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery, Alabama requesting money for the ASBDC.
MAURICE WILLIAM CAMPBELL, JR. in or about September 2004 would
and did cause the ASBDC to apply for state funds through a “Project
Questionnaire.”
and did cause a “Project Questionnaire” to be completed and sent to private
counsel administering bond proceeds for the State. The “Project Questionnaire”
identified the project for which State money was requested as the “Jacksonville
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State University Small Business Development Consortium.” In the questionnaire,
the “project owner” was identified as the “Alabama Small Business Development
Consortium.” In the “Use of the Project” section, the question stated “Other than
the project owner identified above and individual members of the general public,
will the project be used in the trade of business of any ‘person’ (individual,
corporation, non-profit entity, partnership, limited liability company,
proprietorship, etc.) other than a governmental unit? If so provide details.” The
typed answer stated “It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium: University of Alabama at Birmingham, University of North Alabama,
Alabama A&M University, University of Alabama at Huntsville, University of
Alabama at Tuscaloosa, Jacksonville State University, Alabama State University,
University of West Alabama, Troy University, and the University of South
Alabama.”
6. It was a further part of the scheme and artifice that in or about February
2005, the defendant MAURICE WILLIAM CAMPBELL, JR. would and did
cause to be incorporated the Alabama Small Business Institute of Commerce, a
private nonprofit entity under federal and state law, with defendant CAMPBELL
as President, Director, incorporator, and registered agent.
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MAURICE WILLIAM CAMPBELL, JR. on or about May 31, 2005, did cause
to be sent by facsimile to the Department of Finance documents concerning the
ASBDC request for funding, including a “Total Program Cost Worksheet” stating
the “cost to run the ASBDC Program for 2 years.”
MAURICE WILLIAM CAMPBELL, JR. on or about June 2, 2005, did cause to
be mailed from the State Department of Finance in Montgomery, Alabama to
Jacksonville State University in Jacksonville, Alabama a State Warrant in the
amount of $1,500,000.00.
MAURICE WILLIAM CAMPBELL, JR. on or about July 7, 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden, Alabama, an
account in the name of the Alabama Small Business Institute of Commerce.
MAURICE WILLIAM CAMPBELL, JR. on or about July 15, 2005, as
President of the Alabama Small Business Institute of Commerce (“The Institute”)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
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State University for $1,200,000.00.
MAURICE WILLIAM CAMPBELL, JR. on or about August 1, 2005, caused
Jacksonville State University to provide a check to The Institute in the amount of
$1,200,000.00.
MAURICE WILLIAM CAMPBELL, JR. on or about August 4, 2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1,000,000.00, and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute.
MAURICE WILLIAM CAMPBELL, JR., and others, would and did use the
funds in The Institute accounts for personal benefit.
The Mailing
14. On or about June 2, 2005, the exact date being unknown to the Grand
Jury, in Jefferson, Etowah, and Calhoun Counties within the Northern District of
Alabama, and elsewhere, defendant
aided and abetted by others known and unknown to the grand jury, for the purpose
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of executing the above-described scheme and artifice and attempting to do so,
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($1,500,000.00) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery, Alabama 36130 to Jacksonville State University, 700
Pelham Road N, Jacksonville, Alabama, 36265.
All in violation of Title 18, United States Code, Sections 1341 and 2.
Count Two
Conspiracy
Title 18, United States Code, Section 371
THE CONSPIRACY
1. The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein.
2. From in or about February 2005 and continuing until in or about April
2010, the exact dates being unknown, in Jefferson, Calhoun, and Etowah Counties
within the Northern District of Alabama, and elsewhere, the defendant
MAURICE WILLIAM CAMPBELL, JR.
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knowingly and willfully conspired, combined, and agreed with other persons,
known and unknown to the Grand Jury, to commit offenses against the United
States: that is,
(A) to devise and intend to devise a scheme and artifice to defraud the State
of Alabama and the private nonprofit Institute and to obtain money and
property belonging to others by means of false and fraudulent pretenses,
representations, and promises by use of United States mail or interstate
carrier, in violation of Title 18, United States Code, Section 1341;
(B) to devise and intend to devise a scheme and artifice to defraud the
State of Alabama and the private nonprofit Institute and to obtain
money and property belonging to others by means of false and
fraudulent pretenses, representations, and promises by use of interstate
wire transmissions, in violation of Title 18, United States Code,
Section 1343;
(C) to conduct or attempt to conduct a financial transaction which in fact

involves the proceeds of specified unlawful activity with the intent to
promote the carrying on of specified unlawful activity; or with intent to
engage in conduct constituting a violation of section 7201 or 7206 of the
Internal Revenue Code of 1986; or knowing that the transaction is designed
in whole or in part to conceal or disguise the nature, the location, the source,
the ownership, or the control of the proceeds of specified unlawful activity;
or to avoid a transaction reporting requirement under State or Federal law, in
violation of Title 18, United States Code, Section 1956(a)(1); and
(D) to engage or attempt to engage in a monetary transaction in criminally

derived property of a value greater than $10,000, and that is derived from
specified unlawful activity, in violation of Title 18, United States Code,
Section 1957.
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MANNER AND MEANS OF THE CONSPIRACY
3. It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL, JR. would and did use his position and authority as State Director
of the Consortium to gain access to state officials – including legislators, personnel
at the Finance Department, and the President, Deans, and other personnel at
Jacksonville State University.
4. It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL, JR. would and did represent to state officials that he
was seeking funding for the Consortium, for the education and training for
Alabama workers, as well as small business development.
sought funding for his nonprofit, the Institute, to serve the same mission of
education and training for Alabama workers, as well as small business
development.
WILLIAM CAMPBELL, JR. would and did seek state funding for the Institute
through grants, contracts, and appropriations in the state education budget.
7. It was a further part of the conspiracy that the Institute received more
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than seven million three hundred thousand dollars ($7,300,000.00) in state funding.
WILLIAM CAMPBELL, JR. and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank, now Regions Bank, into
which state funds were deposited and transferred.
WILLIAM CAMPBELL, JR. and others would and did receive direct access to
the bank accounts of the Institute through checkcards, and would and did use those
checkcards to make over one million dollars in purchases including jewelry,
clothing, personal services, food, lodging, and gas.
WILLIAM CAMPBELL, JR. and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit, the
interest on which was deposited into the account from which checkcard
transactions were made.
obtained by the Institute to purchase and lease vehicles, including a Mercedes, a
Yukon Denali, and two Honda Pilots.
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obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits.
obtained by the Institute for the benefit of themselves, their families, and their
friends.
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the “Little Sisters” and to make purchases for the “Little Sisters.”
WILLIAM CAMPBELL, JR. and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities, including Baptist Housing Services
LLC, Johnson Marketing Group LLC, and S&D Supporting Services, as well as an
account at Compass Bank in the name of Baptist Health Services.
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WILLIAM CAMPBELL, JR. and others were issued checkcards on these
accounts. In addition to his Institute business checkcard, defendant MAURICE
WILLIAM CAMPBELL, JR. had checkcards issued to him on the Baptist
Housing Services LLC, Johnson Marketing Group LLC, and S&D Supporting
Services accounts.
WILLIAM CAMPBELL, JR. and others issued checks to the “Little Sisters”
from these additional accounts.
WILLIAM CAMPBELL, JR. and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium.
WILLIAM CAMPBELL, JR. and others did not disclose to state officials,
including legislators, officials at Jacksonville State University, or officials at the
Universities of other Consortium members, how the state money provided to the
Institute was being spent, and did disguise and misrepresent expenditures in the
books and records of the Institute.
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OVERT ACTS
20. In furtherance of the conspiracy and to achieve the objects thereof,
defendant MAURICE WILLIAM CAMPBELL, JR. and others committed and
caused to be committed the following overt acts, among others, in the Northern
District of Alabama and elsewhere:
CAMPBELL, JR. incorporated the Alabama Small Business Institute of
Commerce (“the Institute” or “ASBIC”).
22. In or about July, 2005, defendant MAURICE WILLIAM
CAMPBELL, JR., the Bookkeeper of the Institute, and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce, the “Operating Account” (x5227), at AmSouth bank, now
Regions Bank.
23. On or about June 21, 2005, defendant MAURICE WILLIAM
CAMPBELL, JR. executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty, staff, and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $95,600.00.
24. On or about July 27, 2005, defendant MAURICE WILLIAM
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CAMPBELL, JR. caused a check from Jacksonville State for $95,600.00 to be
deposited into the Operating Account of the Institute.
CAMPBELL, JR. caused State of Alabama officials to mail a check for
$1,500,000 to Jacksonville State University.
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $1,200,000.00.
27. On or about August 2, 2005, defendant MAURICE WILLIAM
CAMPBELL, JR. and others caused a check for $1,200,000.00 from Jacksonville
State University to be deposited into the Operating Account of the Institute.
CAMPBELL, JR. and a Director of the Institute established a $1,000,000
certificate of deposit with AmSouth Bank, now Regions Bank, the interest on
which was deposited into the Travel Account of the Institute.
CAMPBELL, JR. and others opened another Institute account, the “Travel
Account” (x5873), at AmSouth Bank, now Regions Bank.
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30. On or about October 1, 2005, defendant MAURICE WILLIAM
train workers in the State of Alabama for $400,000.00. In the ensuing months,
defendant MAURICE WILLIAM CAMPBELL, JR. and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement.
Jacksonville State University for a strategic partnership to further the common
goals of education, training, and workforce development, in which the Institute
would receive $1,200,000.00 for the operation of Institute programs for education,
training, and workforce development. In the ensuing months, defendant
MAURICE WILLIAM CAMPBELL, JR. and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement.
32. In or about September 2006, defendant MAURICE WILLIAM
CAMPBELL, JR. hired the Executive Director of the Institute.
33. In or about October 2006, defendant MAURICE WILLIAM
CAMPBELL, JR. caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium.
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34. On or about December 5, 2006, defendant MAURICE WILLIAM
CAMPBELL, JR. purchased items from Reeds Jewelers for $1,024.60 using his
Institute checkcard.
35. On or about May 11, 2007, defendant MAURICE WILLIAM
CAMPBELL, JR. and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank, now Regions
bank.
CAMPBELL, JR. and the Bookkeeper caused Institute check number 737 in the
amount of $25,000.00, for “Jan. Feb. March April & May Rent,” to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account.
amount of $15,000.00, for “Oct. Nov. & Dec. Rent,” to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account.
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amount of $15,000.00, for “June, July, August Rent,” to be issued to Baptist
account.
39. On or about September 12, 2007, and on a monthly basis for the
remainder of 2007, defendant MAURICE WILLIAM CAMPBELL, JR. and the
Bookkeeper caused Institute checks for $5,000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account.
41. On or about November 23, 2007, defendant MAURICE WILLIAM
CAMPBELL, JR. purchased an item at Gus Mayer for $539.55 using his Institute
checkcard.
42. On or about January 29, 2008, and on a monthly basis for the remainder
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of 2007, defendant MAURICE WILLIAM CAMPBELL, JR. and the
43. On or about June 30, 2008, the Executive Director of the Institute
purchased items at Coach in Foley, Alabama, using his Institute checkcard in the
amount of $1,930.99.
44. On or about August 6, 2008, the Executive Director of the Institute
incorporated Johnson Marketing Group LLC.
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank. Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL, JR.
MAURICE WILLIAM CAMPBELL, JR. caused others to retrieve checks from
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47. On or about December 2, 2008, the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL, JR. was paid with a Baptist
Housing Services LLC Regions Bank account check for $4,343.12, using funds
from the Institute.
48. On or about December 9, 2008, the defendant MAURICE WILLIAM
CAMPBELL, JR. issued $200 checks to three of the “Little Sisters” and treated
them to dinner at Bottega, which was paid for on the Bookkeeper’s Institute
checkcard in the amount of $715.65.
of 2009, defendant MAURICE WILLIAM CAMPBELL, JR. and the
50. On or about February 20, 2009, the bill for the VISA credit card used by
Housing Services LLC Regions Bank account check for $284.82, using funds from
the Institute.
51. On or about March 16, 2009, the Executive Director of the Institute
purchased items at UltraDiamonds, via the Internet, using his Institute checkcard in
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the amount of $1,544.40.
52. On or about April 23, 2009, the Executive Director purchased engraving
services at Triple S. Trophies located in Gadsden, Alabama, using his Institute
checkcard in the amount of $180.00 to have bracelets engraved with the words “Sir
William” and “Lil Sister.”
53. In or about April 2009, defendant MAURICE WILLIAM
CAMPBELL, JR. on behalf of Baptist Housing Services, and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide “marketing services” to
Baptist Housing Services for $12,000.00.
54. On or about April 14, 2009, a check for $12,000.00 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group.
55. On or about April 29, 2009, the bill for the VISA credit card used by
Housing Services LLC x7917 account check for $1,822.61, using funds from the
Institute.
CAMPBELL, JR. caused an employee of Regency Pointe to open an account at
Regions Bank in the name of S&D Supporting Services (x4750). Checkcards on
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this account were issued to the Regency Pointe employee and defendant
CAMPBELL, JR. caused a Cashier’s Check in the amount of $24,000.00 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
S&D Supporting Services.
CAMPBELL, JR. took “Little Sisters” on a shopping trip at the Summit in
Birmingham, Alabama using a VISA credit card issued to him.
59. On or about June 29, 2009, the bill for the VISA credit card used by
from the Institute.
60. On or about July 29, 2009, the bill for the VISA credit card used by
the Institute.
61. On or about September 3, 2009, the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL, JR. was paid with a Baptist
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the Institute.
62. On or about September 10, 2009, the Executive Director purchased
items at UltraDiamonds, via the Internet, using his Institute checkcard in the
63. On or about October 23, 2009, the Executive Director purchased
engraving services at Triple S. Trophies located in Gadsden, Alabama, using his
Institute checkcard in the amount of $150.00 to have bracelets engraved with the
words “Sir William” and “Lil Sister.”
the Institute.
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66. On or about October 28, 2009, the bill for the VISA credit card used by
the Institute.
from the Institute.
68. On or about January 6, 2010, and on a monthly basis through March
2010, defendant MAURICE WILLIAM CAMPBELL, JR. and the Bookkeeper
caused Institute checks for $6,000.00 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account.
All in violation of Title 18, United States Code, Section 371.
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Counts 3 through 58
Wire Fraud
out herein.
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein.
3. From in or about February 2005, and continuing to in or about April
within the Northern District of Alabama, and elsewhere, defendant
and with the intent to defraud, devise and intend to devise a scheme and artifice to
defraud the State of Alabama, the Institute, and others, and to obtain money and
property belonging to the Institute and the State of Alabama, by means of
materially false and fraudulent pretenses, representations, and promises.
4. It was a part of the scheme and artifice that defendant MAURICE
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5. It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL, JR. would and did represent to state
officials that he sought funding for his nonprofit, the Institute, to serve the same
mission of education and training for Alabama workers, as well as small business
development.
6. It was a further part of the scheme and artifice that defendant MAURICE
7. It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($7,300,000.00) in state
funding.
friends.
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WILLIAM CAMPBELL, JR. would and did cause the creation of bank accounts
at Regions Bank in the name of other entities, including Baptist Housing Services
LLC, Johnson Marketing Group LLC, and S&D Supporting Services.
MAURICE WILLIAM CAMPBELL, JR. would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC, Johnson Marketing
Group LLC, and S&D Supporting Services, which he used to make expenditures
for his personal benefit, in addition to his Institute business checkcard.
MAURICE WILLIAM CAMPBELL, JR. would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the “Little Sisters,” and make purchases for the “Little Sisters.”
MAURICE WILLIAM CAMPBELL, JR. would and did cause state funding
obtained by the Institute, and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account, to be used to pay charges on a VISA credit
card issued to him.
MAURICE WILLIAM CAMPBELL, JR. and others did not disclose to state
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officials, including legislators, officials at Jacksonville State University, or
officials at the Universities of other Consortium members, how the state money
provided to the Institute was being spent, and did disguise and misrepresent
expenditures in the books and records of the Institute.
THE WIRE COMMUNICATION
14. On or about the dates set forth below, each such date constituting a
separate count of this Indictment, in Jefferson, Calhoun, and Etowah Counties
aided and abetted by others known and unknown to the Grand Jury, for the purpose
of executing the above-described scheme and artifice and attempting to do so, did
transmit and cause to be transmitted in interstate commerce, by means of a wire
communication, certain signs and signals, that is, defendant MAURICE
WILLIAM CAMPBELL, JR. caused an interstate communication between
Alabama and another state to be made on each occasion listed below.
15. The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein.
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COUNT DATE AMOUNT VENDOR

3 12/5/2006 $1,024.60 Reed’s Jewelers
4 3/1/2007 $188.52 Just Add Water
5 3/26/2007 $268.14 Just Add Water
6 8/20/2007 $130.71 Jos. A. Bank
7 11/23/2007 $539.55 Gus Mayer
8 12/24/2007 $969.56 Jos. A. Bank
9 3/1/2008 $196.07 Jos. A. Bank
10 3/22/2008 $421.81 Jos. A. Bank
11 5/14/2008 $149.04 Behind the Glass
12 7/24/2008 $566.35 White House Black Market
13 10/22/2008 $761.83 Coach
14 10/22/2008 $1,043.71 Coach
15 12/9/2008 $715.65 Bottega
16 12/22/2008 $1,521.10 Jos. A. Bank
17 1/30/2009 $61.07 Hooters
18 2/9/2009 $98.74 Hooters
19 3/14/2009 $163.45 TJMaxx
20 3/16/2009 $1,544.40 UltraDiamonds
21 4/23/2009 $180.00 Triple S Trophies & Engraving
22 3/19/2009 $413.40 Neiman Marcus
23 4/17/2009 $828.92 Neiman Marcus
24 5/28/2009 $110.80 Village Tavern
25 5/28/2009 $1,113.20 BeBe
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26 6/11/2009 $487.60 Express

27 6/11/2009 $82.48 Banana Republic
28 6/11/2009 $54.56 Belk
29 6/11/2009 $387.95 Abercrombie & Fitch
30 6/11/2009 $225.83 PF Chang’s
31 6/24/2009 $39.80 Hooters
32 6/24/2009 $1,124.16 Coach
33 7/13/2009 $42.15 Hooters
34 7/20/2009 $44.69 Hooters
35 7/27/2009 $364.00 Urban Outfitters
36 7/27/2009 $793.98 BCBG
37 7/27/2009 $296.85 Fleming
38 8/1/2009 $1,753.89 Coach
39 8/14/2009 $878.00 Coach
40 8/25/2009 $250.00 Baytowne Jewelers
41 8/28/2009 $38.32 Hooters
42 8/28/2009 $1,775.00 Baytowne Jewelers
43 9/21/2009 $20.12 Hooters
44 9/21/2009 $1,544.40 UltraDiamonds
46 9/22/2009 $112.83 Belk
47 9/28/2009 $194.68 Francesca’s
48 10/9/2009 $204.53 Belk
49 10/27/2009 $403.05 Jos. A. Bank
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50 10/29/2009 $204.60 Francesca’s

51 11/29/2009 $381.76 Macy*s
52 12/5/2009 $294.19 Belk
53 12/5/2009 $152.38 Belk
54 12/14/2009 $100.06 Macy*s
55 12/14/2009 $241.72 Macy*s
56 12/14/2009 $122.35 Express
57 12/16/2009 $280.10 Express
58 12/16/2009 $118.78 Banana Republic
Counts 59 and 60
Mail Fraud
out herein.
herein.
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein.
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THE MAILING
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier, to wit, United Parcel Service, and willfully caused said shipments to be
delivered according to the direction thereon.
5. The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein.
COUNT DATE DELIVERED TO

510 East Grand Avenue
59 3/27/2009
Rainbow City, AL 35906
510 East Grand Avenue
60 9/25/2009
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Counts 61 through 91
Money Laundering
Title 18, United States Code, Sections 1956(a)(1)(B)(i) & 2
out herein.
herein.
set out herein.
4. On or about each of the dates set forth in each Count below, in Jefferson,
Calhoun, and Etowah Counties within the Northern District of Alabama, the
defendant
aided and abetted by others known and unknown to the Grand Jury, knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce, that is, transfer of the monetary instrument referenced in each
Count below, a check from the x5227 account of the Alabama Small Business
33
Institute of Commerce, which involved the proceeds of specified unlawful activity,
that is, mail fraud, wire fraud, and conspiracy, to the x7917 account of Baptist
Housing Services LLC, knowing that each transaction was designed in whole and
in part to conceal and disguise the nature, location, source, ownership, and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction, knew that the property involved
in each financial transaction, that is, the monetary instrument described below, was
proceeds of some form of unlawful activity.
Counts 61 and 91 as though fully set forth therein:
AMOUNT DEPOSITED
INSTITUTE
COUNT DATE INTO BHS ACCOUNT
CHECK NUMBER
x7917
61 9/12/2007 #788 $ 5,000.00
62 10/1/2007 #794 $ 5,000.00
63 11/7/2007 #815 $ 5,000.00
64 12/11/2007 #842 $ 5,000.00
65 1/29/2008 #863 $ 6,000.00
66 2/4/2008 #871 $ 6,000.00
67 3/4/2008 #892 $ 6,000.00
68 5/1/2008 #924 $ 6,000.00
69 6/2/2008 #944 $ 6,000.00
34
70 7/2/2008 #962 $ 6,000.00

71 8/1/2008 #989 $ 6,000.00
72 9/3/2008 #1016 $ 6,000.00
73 10/1/2008 #1054 $ 6,000.00
74 11/3/2008 #1077 $ 6,000.00
75 12/2/2008 #1097 $ 6,000.00
76 1/15/2009 #1145 $ 6,000.00
77 2/2/2009 #1162 $ 6,000.00
78 3/3/2009 #1179 $ 6,000.00
79 4/1/2009 #1214 $ 6,000.00
80 5/6/2009 #1247 $ 6,000.00
81 6/1/2009 #1272 $ 6,000.00
82 7/1/2009 #1298 $ 6,000.00
83 8/4/2009 #1347 $ 6,000.00
84 9/2/2009 #1372 $ 6,000.00
85 10/1/2009 #1407 $ 6,000.00
86 11/2/2009 #1439 $ 6,000.00
87 12/1/2009 #1465 $ 6,000.00
88 1/6/2010 #1521 $ 6,000.00
89 2/1/2010 #1540 $ 6,000.00
90 3/2/2010 #1560 $ 6,000.00
91 4/6/2010 #1585 $ 6,000.00
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i)
and 2.
35
Money Laundering
Title 18, United States Code, Sections 1957 & 2
out herein.
herein.
set out herein.
defendant
engaged in and attempted to engage in a monetary transaction, by, through, and to
a financial institution, in and affecting interstate commerce, in criminally derived
property of a value greater than $10,000.00, that is, the transfer of funds in the
36
amount set forth below, into the account listed below, such property having been
derived from a specified unlawful activity, that is, mail fraud, wire fraud, and
conspiracy.
ACCOUNT INTO
FUNDS
COUNT DATE WHICH FUNDS WERE
TRANSFERRED
DEPOSITED
Alabama Small Business Baptist Housing Services
Institute of Commerce LLC Account x7917
92 5/10/2007
Check Number 737
for $25,000.00
93 5/10/2007
Check Number 738
for $15,000.00
94 8/1/2007
Check Number 777
for $15,000.00
Baptist Housing Johnson Marketing Group
Services LLC Check LLC Account x1459
95 4/14/2009
Number 1044
for $12,000.00
Regions Bank Cashier’s S&D Supporting Services
96 5/8/2009 Check # 5002068436 Account x4750
for $24,000.00
37
NOTICE OF FORFEITURE
[ 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]
1. The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18, United States Code, Section 981(a)(1)(C)
and Title 28, United States Code, Section 2461(c).
2. Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18, United States Code, Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight, and upon conviction of the offense of
conspiracy in violation of Title 18, United States Code, Section 371 set forth in
Count Two of this Indictment, the defendant,
shall forfeit to the United States of America, pursuant to Title 18, United States
Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any
property, real or personal, which constitutes or is derived from proceeds traceable
to the offenses. The property to be forfeited includes, but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents, $7,326,569.02.
3. If any of the property described above, as a result of any act or
38
omission of the defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has 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,
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title
28, United States Code, Section 2461(c).
All pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c).
39
[18 U.S.C. § 982(a)(1)]
1. The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18, United States Code, Section 982(a)(1).
FORFEITURE
2. As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment, the defendant,
shall forfeit to the United States any property, real or personal, involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL, JR. or
any property traceable to such property. The property to be forfeited includes, but
is not limited to, the aggregate sum of two hundred seventy-three thousand dollars
$273,000.00 and all interest and proceeds derived therefrom.
3. If any of the property described above as being subject to forfeiture
pursuant to Title 18, United States Code, Section 982(a)(1), as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL, JR.:
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred to, sold to, or deposited with a third person;
(3) has been placed beyond the jurisdiction of the Court;

40
(4) has been substantially diminished in value; or
(5) has been commingled with other property that cannot be
subdivided without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code,
Section 853(p), to seek forfeiture of any other property of said defendant,
MAURICE WILLIAM CAMPBELL, JR., up to the value of the above
forfeitable property.
All pursuant to Title 18, United States Code, Section 982(a)(1).
A TRUE BILL.
/s/
Foreperson of the Grand Jury
JOYCE WHITE VANCE

UNITED STATES ATTORNEY
/s/
Tamarra Matthews Johnson
Assistant United States Attorney
/s/
George A. Martin
Assistant United States Attorney
41
Case 2:10-cr-00186-AKK -JEO Document 4-1 Filed 03/30/11 Page 1 of 41 FILED
2011 Mar-31 PM 04:27
U.S. DISTRICT COURT
N.D. OF ALABAMA
JWV/TMJ/GAM March 2011

DTF GJ #8
7~1\ l'IR ¥hf U~f~D STATES DISTRICT COURT FOR THE

L ,~:,~, "?'\(:Tc~RtHERN DISTRICT OF ALABAMA
1:.C.lr· J-\Li:..dh
l
SOUTHERN DIVISION
,j"\
UNITED STATES OF AMERICA *

*
v. * CR
*
MAURICE WILLIAM CAMPBELL, JR., * SUPERSEDING
also known as, BILL CAMPBELL, *
also known as, "SIR WILLIAM" *
Dekndant *
INDICTMENT
THE GRAND JURY CHARGES:
At all times material to this Superseding Indictment:
Introduction
1. Defendant MAURICE WILLIAM CAMPBELL, JR., in or about
January 2003, was hired as the State Director of the Alabama Small Business
Development Consortium ("the Consortium" or "ASBDC"). The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center. The ASBDC's purposes were to enhance
economic growth, to provide management and technical assistance to small
Case 2:10-cr-00186-AKK -JEO Document 4-1 Filed 03/30/11 Page 2 of 41
businesses, and to develop Alabama's workforce. The State Director's office was
located at the University of Alabama at Birmingham in Birmingham, Alabama, and
subsequently at the University of Alabama in Tuscaloosa, Alabama. In his role as
State Director, defendant MAURICE WILLIAM CAMPBELL, JR., in addition
to other duties, was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama.
CAMPBELL, JR., incorporated the Alabama Small Business Institute of
Commerce ("the Institute" or "ASBIC"). Defendant MAURICE WILLIAM
CAMPBELL, JR. was the President, a director, the initial registered agent, and
incorporator of the Institute. The stated purpose of the Institute was to enhance
economic development, increase employment, and reduce business failure in
Alabama through business education and workforce training. The Institute was
formed as a nonprofit, with the representation that the corporation shall not be
operated for private profit, nor its assets at any time inure to the benefit of any
shareholder, member, director, trustee, officer or other private person. The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code, and for nonprofit purposes within
the meaning of the Alabama Code.
3. The Institute received nearly all of its funding from the State of Alabama
through grants, contracts, and appropriations in the education budget. From 2005
through 2010, the private nonprofit Institute received over seven million three
hundred thousand dollars ($7,300,000.00) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institute's stated purposes.
Count One
Mail Fraud
Title 18. United States Code, Sections 1341 and 2
1. From in or about August 2004 and continuing to in or about August
2005, in Jefferson, Calhoun, and Etowah Counties within the Northern District of
Alabama, and elsewhere, the defendant,
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama, the State of Alabama Department of Finance, and
others, and to obtain money and property by means of materially false pretenses,
representations, and promises, said scheme and artifice being in substance as
follows:
2. It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL, JR. would and did use his position as State Director of
the Alabama Small Business Development Consortium ("ASBDC") to obtain
money belonging to the State of Alabama.
MAURICE WILLIAM CAMPBELL, JR. in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham, Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery, Alabama requesting money for the ASBDC.
and did cause the ASBDC to apply for state funds through a "Project
Questionnaire."
MAURICE \\:,ILLIAM CAMPBELL, JR. in or about September 2004 would
and did cause a "Project Questionnaire" to be completed and sent to private
counsel administering bond proceeds for the State. The "Project Questionnaire"
identified the project for which State money was requested as the "Jacksonville
State University Small Business Development Consortium." In the questionnaire,
the "project owner" was identified as the "Alabama Small Business Development
Consortium." In the "Use of the Project" section, the question stated "Other than
the project owner identified above and individual members of the general public,
will the project be used in the trade of business of any 'person' (individual,
corporation, non-profit entity, partnership, limited liability company,
proprietorship, etc.) other than a governmental unit? If so provide details." The
typed answer stated "It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium: University of Alabama at Birmingham, University of North Alabama,
Alabama A&M University, University of Alabama at Huntsville, University of
Alabama at Tuscaloosa, Jacksonville State University, Alabama State University,
University of West Alabama, Troy University, and the University of South
Alabama."
6. It was a further part of the scheme and artifice that in or about February
2005, the defendant MAURICE WILLIAM CAMPBELL, JR. would and did
cause to be incorporated the Alabama Small Business Institute of Commerce, a
private nonprofit entity under federal and state law, with defendant CAMPBELL
as President, Director, incorporator, and registered agent.
MAURICE WILLIAM CAMPBELL, JR~ on or about May 31,2005, did cause
to be sent by facsimile to the Department of Finance documents concerning the
ASBDC request for funding, including a "Total Program Cost Worksheet" stating
the "cost to run the ASBDC Program for 2 years."
MAURICE WILLIAM CAMPBELL, JR. on or about June 2,2005, did cause to
be mailed from the State Department of Finance in Montgomery, Alabama to
Jacksonville State University in Jacksonville, Alabama a State Warrant in the
amount of$I,500,000.00.
MAURICE WILLIAM CAMPBELL, JR. on or about July 7, 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden, Alabama, an
account in the name of the Alabama Small Business Institute of Commerce.
MAURICE WILLIAM CAMPBELL, JR. on or about July 15,2005, as
President of the Alabama Small Business Institute of Commerce ("The Institute")
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
State University for $1,200,000.00.
MAURICE WILLIAM CAMPBELL, JR. on or about August 1,2005, caused
Jacksonville State University to provide a check to The Institute in the amount of
$1,200,000.00.
MAURICE WILLIAM CAMPBELL, JR. on or about August 4,2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 ,000,000.00, and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute.
MAURICE WILLIAM CAMPBELL, JR., and others, would and did use the
funds in The Institute accounts for personal benefit.
The Mailin&
14. On or about June 2,2005, the exact date being unknown to the Grand
Jury, in Jefferson, Etowah, and Calhoun Counties within the Northern District of
Alabama, and elsewhere, defendant
aided and abetted by others known and unknown to the grand jury, for the purpose
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($1,500,000.00) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery, Alabama 36130 to Jacksonville State University, 700
Pelham Road N, Jacksonville, Alabama, 36265.
Count Two
Conspiracy
Title 18. United States Code. Section 371
THE CONSPIRACY
out herein.
2. From in or about February 2005 and continuing until in or about April
within the Northern District of Alabama, and elsewhere, the defendant
knowingly and willfully conspired, combined, and agreed with other persons,
known and unknown to the Grand Jury, to commit offenses against the United
States: that is,
(A) to devise and intend to devise a scheme and artifice to defraud the State
of Alabama and the private nonprofit Institute and to obtain money and
property belonging to others by means of false and fraudulent pretenses,
representations, and promises by use of United States mail or interstate
carrier, in violation of Title 18, United States Code, Section 1341;
(B) to devise and intend to devise a scheme and artifice to defraud the
State of Alabama and the private nonprofit Institute and to obtain
money and property belonging to others by means of false and
fraudulent pretenses, representations, and promises by use of interstate
wire transmissions, in violation of Title 18, United States Code,
Section 1343;
(C) to conduct or attempt to conduct a financial transaction which in fact

involves the proceeds of specified unlawful activity with the intent to
promote the carrying on of specified unlawful activity; or with intent to
engage in conduct constituting a violation of section 7201 or 7206 of the
Internal Revenue Code of 1986; or knowing that the transaction is designed
in whole or in part to conceal or disguise the nature, the location, the source,
the ownership, or the control of the proceeds of specified unlawful activity;
or to avoid a transaction reporting requirement under State or Federal law, in
violation of Title 18, United States Code, Section 1956(a)(1); and
(D) to engage or attempt to engage in a monetary transaction in criminally

derived property of a value greater than $10,000, and that is derived from
specified unlawful activity, in violation of Title 18, United States Code,
Section 1957.
MANNER AND MEANS OF THE CONSPIRACY
3. It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL, JR. would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators, personnel
at the Finance Department, and the President, Deans, and other personnel at
Jacksonville State University.
sought funding for his nonprofit, the Institute, to serve the same mission of
education and training for Alabama workers, as well as small business
development.
7. It was a further part of the conspiracy that the Institute received more
10
than seven million three hundred thousand dollars ($7,300,000.00) in state funding.
WILLIAM CAMPBELL, JR. and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank, now Regions Bank, into
which state funds were deposited and transferred.
WILLIAM CAMPBELL, JR. and others would and did receive direct access to
the bank accounts of the Institute through checkcards, and would and did use those
checkcards to make over one million dollars in purchases including jewelry,
clothing, personal services, food, lodging, and gas.
obtained by.the Institute to purchase a one million dollar certificate of deposit, the
interest on which was deposited into the account from which checkcard
transactions were made.
obtained by the Institute to purchase and lease vehicles, including a Mercedes, a
Yukon Denali, and two Honda Pilots.
11
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits.
friends.
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the "Little Sisters" and to make purchases for the "Little Sisters."
WILLIAM CAMPBELL, JR. and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities, including Baptist Housing Services
LLC, Johnson Marketing Group LLC, and S&D Supporting Services, as well as an
account at Compass Bank in the name of Baptist Health Services.
12
WILLIAM CAMPBELL, JR. and others were issued checkcards on these
accounts. In addition to his Institute business checkcard, defendant MAURICE
WILLIAM CAMPBELL, JR. had checkcards issued to him on the Baptist
Housing Services LLC, Johnson Marketing Group LLC, and S&D Supporting
Services accounts.
WILLIAM CAMPBELL, JR. and others issued checks to the "Little Sisters"
from these additional accounts.
WILLIAM CAMPBELL, JR. and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium.
WILLIAM CAMPBELL, JR. and others did not disclose to state officials,
including legislators, officials at Jacksonville State University, or officials at the
Universities of other Consortium members, how the state money provided to the
Institute was being spent, and did disguise and misrepresent expenditures in the
books and records of the Institute.
13
OVERT ACTS
20. In furtherance of the conspiracy and to achieve the objects thereof,
defendant MAURICE WILLIAM CAMPBELL, JR. and others committed and
caused to be committed the following overt acts, among others, in the Northern
District of Alabama and elsewhere:
CAMPBELL, JR. incorporated the Alabama Small Business Institute of
Commerce ("the Institute" or "ASBIC").
22. In or about July, 2005, defendant MAURICE WILLIAM
CAMPBELL, JR., the Bookkeeper of the Institute, and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce, the "Operating Account" (x5227), at AmSouth bank, now
Regions Bank.
Jacksonville State University for the Institute to provide faculty, staff, and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $95,600.00.
14
CAMPBELL, JR. caused a check from Jacksonville State for $95,600.00 to be
deposited into the Operating Account of the Institute.
CAMPBELL, JR. caused State of Alabama officials to mail a check for
$1,500,000 to Jacksonville State University.
26. On or about July 15,2005, defendant MAURICE WILLIAM
train workers in the State of Alabama for $1,200,000.00.
27. On or about August 2,2005, defendant MAURICE WILLIAM
CAMPBELL, JR. and others caused a check for $1,200,000.00 from Jacksonville
State University to be deposited into the Operating Account of the Institute.
CAMPBELL, JR. and a Director of the Institute established a $1,000,000
certificate of deposit with AmSouth Bank, now Regions Bank, the interest on
which was deposited into the Travel Account of the Institute.
CAMPBELL, JR. and others opened another Institute account, the "Travel
Account" (x5873), at AmSouth Bank, now Regions Bank.
15
30. On or about October 1,2005, defendant MAURICE WILLIAM
train workers in the State of Alabama for $400,000.00. In the ensuing months,
defendant MAURICE WILLIAM CAMPBELL, JR. and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement.
32. In or about September 2006, defendant MAURICE WILLIAM
CAMPBELL, JR. hired the Executive Director of the Institute.
33. In or about October 2006, defendant MAURICE WILLIAM
CAMPBELL, JR. caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium.
16
34. On or about December 5, 2006, defendant MAURICE WILLIAM
CAMPBELL, JR. purchased items from Reeds Jewelers for $1,024.60 using his
Institute checkcard.
35. On or about May 11,2007, defendant MAURICE WILLIAM
CAMPBELL, JR. and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank, now Regions
bank.
amount of $25,000.00, for "Jan. Feb. March April & May Rent," to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account.
37. On or about May 10,2007, defendant MAURICE WILLIAM
CAMPBELL, JR. and the Bookkeeper caused Institute check number.738 in the
amount of$15,000.00, for "Oct. Nov. & Dec. Rent," to be issued to Baptist
account.
38. On or about August 1,2007, defendant MAURICE WILLIAM
17
amount of $15,000.00, for "June, July, August Rent," to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account.
39. On or about September 12,2007, and on a monthly basis for the
remainder of2007, defendant MAURICE WILLIAM CAMPBELL, JR. and the
41. On or about November 23,2007, defendant MAURICE WILLIAM
CAMPBELL, JR. purchased an item at Gus Mayer for $539.55 using his Institute
checkcard.
18
of2007, defendant MAURICE WILLIAM CAMPBELL, JR. and the
Services and deposited into the Baptist Housing Services LLC x791 7 account.
43. On or about June 30, 2008, the Executive Director of the Institute
purchased items at Coach in Foley, Alabama, using his Institute checkcard in the
amount of$I,930.99.
incorporated Johnson Marketing Group LLC.
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank. Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL, JR.
19
from the Institute.
48. On or about December 9,2008, the defendant MAURICE WILLIAM
CAMPBELL, JR. issued $200 checks to three of the "Little Sisters" and treated
them to dinner at Bottega, which was paid for on the Bookkeeper's Institute
checkcard in the amount of$715.65.
49. On or about January 15,2009, and on a monthly basis for the remainder
of2009, defendant MAURICE WILLIAM CAMPBELL, JR. and the
Services and deposited into the Baptist Housing Services LLC x791 7 account.
50. On or about February 20, 2009, the bill for the VISA credit card used by
the Institute.
51. On or about March 16, 2009, the Executive Director of the Institute
purchased items at UltraDiamonds, via the Internet, using his Institute checkcard in
20
the amount of$I,544.40.
52. On or about April 23, 2009, the Executive Director purchased engraving
services at Triple S. Trophies located in Gadsden, Alabama, using his Institute
checkcard in the amount of $180.00 to have bracelets engraved with the words "Sir
William" and "Lil Sister."
53. In or about April 2009, defendant MAURICE WILLIAM
CAMPBELL, JR. on behalf of Baptist Housing Services, and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide "marketing services" to
Baptist Housing Services for $12,000.00.
54. On or about April 14, 2009, a check for $12,000.00 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group.
55. On or about April 29, 2009, the bill for the VISA credit card used by
Housing Services LLC x7917 account check for $1,822.61, using funds from the
Institute.
CAMPBELL, JR. caused an employee of Regency Pointe to open an account at
Regions Bank in the name ofS&D Supporting Services (x4750). Checkcards on
21
this account were issued to the Regency Pointe employee and defendant
CAMPBELL, JR. caused a Cashier's Check in the amount of $24,000.00 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
S&D Supporting Services.
58. On or about June 11,2009, defendant MAURICE WILLIAM
CAMPBELL, JR. took "Little Sisters" on a shopping trip at the Summit in
Birmingham, Alabama using a VISA credit card issued to him.
59. On or about June 29,2009, the bill for the VISA credit card used by
from the Institute.
60. On or about July 29,2009, the bill for the VISA credit card used by
the Institute.
22
the Institute.
62. On or about September 10,2009, the Executive Director purchased
items at UltraDiamonds, via the Internet, using his Institute checkcard in the
63. On or about October 23,2009, the Executive Director purchased
engraving services at Triple S. Trophies located in Gadsden, Alabama, using his
Institute checkcard in the amount of $150.00 to have bracelets engraved with the
words "Sir William" and "Lil Sister."
64. On or about September 29,2009, the bill for the VISA credit card used
the Institute.
23
66. On or about October 28,2009, the bill for the VISA credit card used by
the Institute.
67. On or about December 1,2009, the bill for the VISA credit card used by
from the Institute.
68. On or about January 6, 2010, and on a monthly basis through March
2010, defendant MAURICE WILLIAM CAMPBELL, JR. and the Bookkeeper
caused Institute checks for $6,000.00 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account.
All in violation of Title 18, United States Code, Section 371.
24
Counts 3 throueh 58
Wire Fraud
Title 18. United States Code. Sections 1343 and 2
out herein.
herein.
3. From in or about February 2005, and continuing to in or about April
and with the intent to defraud, devise and intend to devise a scheme and artifice to
defraud the State of Alabama, the Institute, and others, and to obtain money and
property belonging to the Institute and the State of Alabama, by means of
materially false and fraudulent pretenses, representations, and promises.
4. It was a part of the scheme and artifice that defendant MAURICE
25
MAURICE WILLIAM CAMPBELL, JR. would and did represent to state
officials that he sought funding for his nonprofit, the Institute, to serve the same
mission of education and training for Alabama workers, as well as small business
development.
7. It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($7,300,000.00) in state
funding.
friends.
26
WILLIAM CAMPBELL, JR. would and did cause the creation of bank accounts
at Regions Bank in the name of other entities, including Baptist Housing Services
LLC, Johnson Marketing Group LLC, and S&D Supporting Services.
MAURICE WILLIAM CAMPBELL, JR. would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC, Johnson Marketing
Group LLC, and S&D Supporting Services, which he used to make expenditures
for his personal benefit, in addition to his Institute business checkcard.
MAURICE WILLIAM CAMPBELL, JR. would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the "Little Sisters," and make purchases for the "Little Sisters."
MAURICE WILLIAM CAMPBELL, JR. would and did cause state funding
obtained by the Institute, and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account, to be used to pay charges on a VISA credit
card issued to him.
MAURICE WILLIAM CAMPBELL, JR. and others did not disclose to state
27
officials, including legislators, officials at Jacksonville State University, or
officials at the Universities of other Consortium members, how the state money
provided to the Institute was being spent, and did disguise and misrepresent
expenditures in the books and records of the Institute.
THE WIRE COMMUNICATION
of executing the above-described scheme and artifice and attempting to do so, did
transmit and cause to be transmitted in interstate commerce, by means of a wire
communication, certain signs and signals, that is, defendant MAURICE
WILLIAM CAMPBELL, JR. caused an interstate communication between
Alabama and another state to be made on each occasion listed below.
15. The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein.
28
COUNT DATE AMOUNT VENDOR

3 12/5/2006 $1,024.60 Reed's Jewelers
4 3/112007 $188.52 Just Add Water
5 3/26/2007 $268.14 Just Add Water
6 8/20/2007 $130.71 Jos. A. Bank
7 11123/2007 $539.55 Gus Mayer
8 12124/2007 $969.56 Jos. A. Bank
9 311/2008 $196.07 Jos. A. Bank
10 3/22/2008 $421.81 Jos. A. Bank
11 5114/2008 $149.04 Behind the Glass
12 7/24/2008 $566.35 White House Black Market
13 10/22/2008 $761.83 Coach
14 10/22/2008 $1,043.71 Coach
15 12/9/2008 $715.65 Bottega
16 12/22/2008 $1,521.10 Jos. A. Bank
17 1130/2009 $61.07 Hooters
18 2/9/2009 $98.74 Hooters
19 3114/2009 $163.45 TJMaxx
20 3116/2009 $1,544.40 UltraDiamonds
22 3119/2009 $413.40 Neiman Marcus
23 4117/2009 $828.92 Neiman Marcus
24 5/28/2009 $110.80 Village Tavern
25 5/28/2009 $1,113.20 BeBe
29
26 6/1112009 $487.60 Express

27 6/1112009 $82.48 Banana Republic
28 6/11/2009 . $54.56 Belk

29 6/11/2009 $387.95 Abercrombie & Fitch
30 6/1112009 $225.83 PF Chang'S
31 6/24/2009 $39.80 Hooters
32 6/2412009 $1,124.16 Coach
33 7/13/2009 $42.15 Hooters
34 7/20/2009 $44.69 Hooters
35 7/27/2009 $364.00 Urban Outfitters
36 7/27/2009 $793.98 BCBG
37 7/27/2009 $296.85 Fleming
38 8/1/2009 $1,753.89 Coach
39 8/14/2009 $878.00 Coach
40 8/25/2009 $250.00 Baytowne Jewelers
41 8/28/2009 $38.32 Hooters
42 8/28/2009 $1,775.00 Baytowne Jewelers
43 9/2112009 $20.12 Hooters
44 9/2112009 $1,544.40 UltraDiamonds
46 9/22/2009 $112.83 Belk
47 9/28/2009 $194.68 Francesca's
48 10/9/2009 $204.53 Belk
49 10/27/2009 $403.05 Jos. A. Bank
30
50 10/29/2009 $204.60 Francesca's
51 11129/2009 $381.76 Macy*s
52 12/5/2009 $294.19 Belk
53 12/5/2009 $152.38 Belk
54 12/14/2009 $100.06 Macy*s
55 12114/2009 $241.72 Macy*s
56 12/14/2009 $122.35 Express
57 12/16/2009 $280.10 Express
58 12116/2009 $118.78 Banana Republic
Counts 59 and 60
Mail Fraud
Title 18. United States Code. Sections 1341 and 2
out herein.
herein.
set out herein.
31
THE MAILING
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier, to wit, United Parcel Service, and willfully caused said shipments to be
delivered according to the direction thereon.
Counts 59 and 60 below as though fully set forth therein.
COUNT DATE DELIVERED TO

510 East Grand A venue
59 3/27/2009
510 East Grand A venue
60 9/25/2009
32
Money Laundering
Title 18, United States Code. Sections 1956(a)(I)(B)(i) & 2
out herein.
herein.
set out herein.
defendant
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce, that is, transfer of the monetary instrument referenced in each
Count below, a check from the x5227 account of the Alabama Small Business
33
Institute of Commerce, which involved the proceeds of specified unlawful activity,
that is, mail fraud, wire fraud, and conspiracy, to the x7917 account of Baptist
Housing Services LLC, knowing that each transaction was designed in whole and
in part to conceal and disguise the nature, location, source, ownership, and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction, knew that the property involved
in each financial transaction, that is, the monetary instrument described below, was
proceeds of some form of unlawful activity.
AMOUNT DEPOSITED
INSTITUTE
COUNT DATE INTO BHS ACCOUNT
CHECK NUMBER
x7917
61 9112/2007 #788 $ 5,000.00
62 10/1/2007 #794 $ 5,000.00
63 1117/2007 #815 $ 5,000.00
64 12/1112007 #842 $ 5,000.00
65 1129/2008 #863 $ 6,000.00
66 2/4/2008 #871 $ 6,000.00
67 3/4/2008 #892 $ 6,000.00
68 5/112008 #924 $ 6,000.00
69 6/2/2008 #944 $ 6,000.00
34
70 7/2/2008 #962 $ 6,000.00

71 8/1/2008 #989 $ 6,000.00
72 9/3/2008 #1016 $ 6,000.00
73 10/1/2008 #1054 $ 6,000.00
74 1113/2008 #1077 $ 6,000.00
75 12/2/2008 #1097 $ 6,000.00
76 1115/2009 #1145 $ 6,000.00
77 2/2/2009 #1162 $ 6,000.00
78 3/3/2009 #1179 $ 6,000.00
79 4/1/2009 #1214 $ 6,000.00
80 5/6/2009 #1247 $ 6,000.00
81 6/1/2009 #1272 $ 6,000.00
82 711/2009 #1298 $ 6,000.00
83 8/4/2009 #1347 $ 6,000.00
84 9/2/2009 #1372 $ 6,000.00
85 10/1/2009 #1407 $ 6,000.00
86 11/2/2009 #1439 $ 6,000.00
87 12/1/2009 #1465 $ 6,000.00
88 116/2010 #1521 $ 6,000.00
89 2/1/2010 #1540 $ 6,000.00
90 3/2/2010 #1560 $ 6,000.00
91 4/6/2010 #1585 $ 6,000.00
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i)
and 2.
35
Counts 92 throu~h 96
Money Launderin~
Title 18. United States Code. Sections 1957 & 2
out herein.
herein.
set out herein.
defendant
engaged in and attempted to engage in a monetary transaction, by, through, and to
a financial institution, in and affecting interstate commerce, in criminally derived
property of a value greater than $10,000.00, that is, the transfer of funds in the
36
amount set forth below, into the account listed below, such property having been
derived from a specified unlawful activity, that is, mail fraud, wire fraud, and
conspIracy.
ACCOUNT INTO
FUNDS
COUNT DATE WHICH FUNDS WERE
TRANSFERRED
DEPOSITED
Institute of Commerce LLC Account x791 7
92 5/10/2007
Check Number 737
for $25,000.00
93 5/10/2007
Check Number 738
for $15,000.00
Institute of Commerce LLC Account x791 7
94 8/1/2007
Check Number 777
for $15,000.00
Baptist Housing Johnson Marketing Group
Services LLC Check LLC Account x1459
95 4/1412009
Number 1044
for $12,000.00
Regions Bank Cashier's S&D Supporting Services
96 5/8/2009 Check # 5002068436 Account x4750
for $24,000.00
37
[ 18 U.S.C. § 981(a)(I)(C) and 28 U.S.C. § 2461(c)]
1. The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18, United States Code, Section 981 (a)(1 )(C)
and Title 28, United States Code, Section 2461 (c).
2. Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18, United States Code, Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight, and upon conviction of the offense of
conspiracy in violation of Title 18, United States Code, Section 371 set forth in
Count Two of this Indictment, the defendant,
shall forfeit to the United States of America, pursuant to Title 18, United States
Code, Section 981 (a)(1)(C) and Title 28, United States Code, Section 2461(c), any
property, real or personal, which constitutes or is derived from proceeds traceable
to the offenses. The property to be forfeited includes, but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents, $7,326,569.02.
3. If any of the property described above, as a result of any act or
38
• •
omission of the defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has 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,
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title
28, United States Code, Section 2461 (c).
All pursuant to 18 U.S.C. § 981(a)(I)(C) and 28 U.S.C. § 2461(c).
39
[18 U.S.C. § 982(a)(I)]
1. The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18, United States Code, Section 982(a)(I).
FORFEITURE
2. As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment, the defendant,
shall forfeit to the United States any property, real or personal, involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL, JR. or
any property traceable to such property. The property to be forfeited includes, but
is not limited to, the aggregate sum of two hundred seventy-three thousand dollars
$273,000.00 and all interest and proceeds derived therefrom.
3. If any of the property described above as being subject to forfeiture
pursuant to Title 18, United States Code, Section 982(a)(I), as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL, JR.:
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred to, sold to, or deposited with a third person;
(3) has been placed beyond the jurisdiction of the Court;
40
(4) has been substantially diminished in value; or
(5) has been commingled with other property that cannot be
subdivided without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code,
Section 853(p), to seek forfeiture of any other property of said defendant,
MAURICE WILLIAM CAMPBELL, JR., up to the value of the above
forfeitable property.
All pursuant to Title 18, United States Code, Section 982(a)(1).
A TRUE BILL.
JOYCE WHITE VANCE
:~Assistant United S
/'
y
41

Full Indictment MWilliam Campbell JR

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Case 2:10-cr-00186-AKK -JEO Document 4 Filed 03/30/11 Page 1 of 41 FILED

2011 Mar-31 PM 04:27

JWV/TMJ/GAM March 2011

IN THE UNITED STATES DISTRICT COURT FOR THE

UNITED STATES OF AMERICA *

THE GRAND JURY CHARGES:

At all times material to this Superseding Indictment:

1. Defendant MAURICE WILLIAM CAMPBELL, JR., in or about

Development Consortium (“the Consortium” or “ASBDC”). The Consortium was

own small business development center – as well as a procurement technical center

and an international trade center. The ASBDC’s purposes were to enhance

economic growth, to provide management and technical assistance to small

located at the University of Alabama at Birmingham in Birmingham, Alabama, and

subsequently at the University of Alabama in Tuscaloosa, Alabama. In his role as

State Director, defendant MAURICE WILLIAM CAMPBELL, JR., in addition

Consortium and its small business development centers located at four-year

2. In or about February 2005, defendant MAURICE WILLIAM

CAMPBELL, JR., incorporated the Alabama Small Business Institute of

Commerce (“the Institute” or “ASBIC”). Defendant MAURICE WILLIAM

economic development, increase employment, and reduce business failure in

shareholder, member, director, trustee, officer or other private person. The

Institute was expressly organized exclusively for purposes authorized within

the meaning of the Alabama Code.

hundred thousand dollars ($7,300,000.00) to provide education and training to

Institute’s stated purposes.

1. From in or about August 2004 and continuing to in or about August

Alabama, and elsewhere, the defendant,

MAURICE WILLIAM CAMPBELL, JR.,

representations, and promises, said scheme and artifice being in substance as

Purpose of the Scheme and Artifice

the Alabama Small Business Development Consortium (“ASBDC”) to obtain

money belonging to the State of Alabama.

letter from defendant CAMPBELL as State Director of the ASBDC in

Birmingham, Alabama to be sent by facsimile to the Governor of the State of

Alabama in Montgomery, Alabama requesting money for the ASBDC.

MAURICE WILLIAM CAMPBELL, JR. in or about September 2004 would

MAURICE WILLIAM CAMPBELL, JR. in or about September 2004 would

and did cause a “Project Questionnaire” to be completed and sent to private

State University Small Business Development Consortium.” In the questionnaire,

corporation, non-profit entity, partnership, limited liability company,

proprietorship, etc.) other than a governmental unit? If so provide details.” The

following member institutions of the Alabama Small Business Development

Consortium: University of Alabama at Birmingham, University of North Alabama,

Alabama A&M University, University of Alabama at Huntsville, University of

Alabama at Tuscaloosa, Jacksonville State University, Alabama State University,

University of West Alabama, Troy University, and the University of South

cause to be incorporated the Alabama Small Business Institute of Commerce, a

as President, Director, incorporator, and registered agent.

to be sent by facsimile to the Department of Finance documents concerning the

the “cost to run the ASBDC Program for 2 years.”

MAURICE WILLIAM CAMPBELL, JR. on or about June 2, 2005, did cause to

be mailed from the State Department of Finance in Montgomery, Alabama to

Jacksonville State University in Jacksonville, Alabama a State Warrant in the

MAURICE WILLIAM CAMPBELL, JR. on or about July 7, 2005 did cause to

be created at AmSouth Bank (now Regions Bank) in Gadsden, Alabama, an

account in the name of the Alabama Small Business Institute of Commerce.

MAURICE WILLIAM CAMPBELL, JR. on or about July 15, 2005, as

President of the Alabama Small Business Institute of Commerce (“The Institute”)

Business Development Center for The Institute to provide services to Jacksonville

State University for $1,200,000.00.

MAURICE WILLIAM CAMPBELL, JR. on or about August 1, 2005, caused

Jacksonville State University to provide a check to The Institute in the amount of

MAURICE WILLIAM CAMPBELL, JR. on or about August 4, 2005 did cause