Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: RUSSIA and THE WEST – РОССИЯ и ЗАПАД: 7:20 PM 7/27/2019 east-and-west-org.blogspot.com/2019/07/720-pm…

RUSSIA and THE WEST – РОССИЯ и ЗАПАД: 7:20 PM 7/27/2019 east-and-west-org.blogspot.com/2019/07/720-pm…


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Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites): Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: RUSSIA and THE WEST – РОССИЯ и ЗАПАД: 7:20 PM 7/27/2019 east-and-west-org.blogspot.com/2019/07/720-pm…

RUSSIA and THE WEST – РОССИЯ и ЗАПАД: 7:20 PM 7/27/2019 east-and-west-org.blogspot.com/2019/07/720-pm…


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Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites): Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Moscow Police Arrest More Than 1,000 at Election Protest nytimes.com/2019/07/27/wor…

Moscow Police Arrest More Than 1,000 at Election Protest nytimes.com/2019/07/27/wor…


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Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Arrestan a exsecretaria de Educación Julia Keleher fuera de PR – NOTICEL noticel.com/ahora/arrestan…

Arrestan a exsecretaria de Educación Julia Keleher fuera de PR – NOTICEL noticel.com/ahora/arrestan…


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Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: She was widely viewed as a controversial lightning rod for her push to adopt charter schools and private school vouchers, in addition to her decision to close hundreds of public schools on the island. fbireform.com/2019/07/27/434…

She was widely viewed as a controversial lightning rod for her push to adopt charter schools and private school vouchers, in addition to her decision to close hundreds of public schools on the island. fbireform.com/2019/07/27/434…


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Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Exclusive: Ex-Puerto Rico Schools Chief Julia Keleher, Indicted in Corruption Probe, Previously Denied She Was Federal Target @The74 the74million.org/?p=542475

Exclusive: Ex-Puerto Rico Schools Chief Julia Keleher, Indicted in Corruption Probe, Previously Denied She Was Federal Target @The74 the74million.org/?p=542475


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Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Striking defiant tone, Julia Keleher defends her tenure in Puerto Rico chalkbeat.org/posts/us/2019/…

Striking defiant tone, Julia Keleher defends her tenure in Puerto Rico chalkbeat.org/posts/us/2019/…


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Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

The Brooklyn Radio – bklynradio.com: Blogs from Michael_Novakhov (21 sites): The FBI News Review: UNITED STATES OF AMERICA, V. [1] JULIA BEATRICE KELEHER: The charges of wire fraud are known to be very broad and non-specific.This case has to be scrutinized for the signs of the politicization. To me, this whole affair smells strongly as being political and the retaliation on the part of Trump: to teach Rossello a lesson for his opposition and harsh words.

M.N.: These charges and the legal issues involved have to be examined very carefully by the lawyers, and they have to be handled legally (I do not see anything particularly tragic in them at the first glance), the charges of wire fraud are known to be very broad and non-specific. Is this case based on Rico rules and the FBI informants? 
To me, this whole affair smells strongly as being political and the retaliation on the part of Trump: to teach Rossello a lesson for his  opposition and harsh words. 

This case has to be scrutinized for the signs of the politicization. 

Michael Novakhov

 3:17 PM 7/27/2019

You can read the full indictment here:

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO ;-o c . .CJr,, UNITED STATES OF AMERICA, V. [1] JULIA BEATRICE KELEHER, Counts: 1-3, 10,12, 15-16, [2] ANGELA AVILA-MARRERO, A/K/A “ANGIE” Counts: 19-23,25 [3] ALBERTO VELAZQUEZ-PINOL, Counts: 12-32 [4] FERNANDO SCHERRER-CAILLET, Counts: 16,19,23-26, [5] GLENDA E. PONCE-MENDOZA, Counts: 1,4-11 [6] MAYRA PONCE-MENDOZA, Counts: 1,3-6,9, 11 Defendants. INDICTMENT S ^0 u3 r-ri c- o .i1U~)’^~- t-—: c? m ;=:^ t -^ -Z.:^’.u> ^.0 ^ ^ •~1 CRIMINAL NO. 19-^, r’tf>/)C^ c • CRIMINAL VIOLATIONS: 18U.S.C.§ 1349 (Wire Fraud Conspiracy) Count 1 18U.S.C.§§371,641 (Conspiracy, Theft) Counts 12, 19 18US.C. § 1343 (Wire Fraud) Counts 2-11, 13-18, 20-25 18U.S.C.§1956(h) (Money Laundering Conspiracy) Count 26 18U.S.C. § 1957 (Money Laundering) Counts 27-32 32 COUNTS & FORFEITURE ALLEGATIONS INDICTMENT THE GRAND JURY CHARGES: COUNT ONE 18 U.S.C. § 1349 (Conspiracy to Commit Wire Fraud) Unless otherwise specified, at all times material to this Indictment: 1. The Puerto Rico Department of Education (hereinafter “PR DOE”) was organized under Article V, section 6 of the Constitution of the Commonwealth of Puerto Rico. The PR DOE was responsible for the planning and administration of all public elementary, secondary Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 1 of 44 and some post-secondary education throughout Puerto Rico. 2. The PR DOE administered various federal financial assistance programs funded by the United States Department of Education (hereinafter “US ED”) intended for students in public and private schools. 3. Keleher & Associates, LLC (hereinafter “Keleher & Associates ) was a foreign for-profit limited liability company organized under the laws of the District of Columbia and duly authorized to do business in Puerto Rico from on or about April 21,2015, until on or about January 25, 2018. 4. Keleher & Associates was owned and managed by [1] JULIA BEATRICE KELEHER from April 21, 2015, until at least in or about 2017. 5. Keleher & Associates maintained a corporate bank account at Wells Fargo Bank, NA managed and controlled by [1] JULIA BEATRICE KELEHER until at least In or about June 2018. 6. On or about January 25, 2018, Individual A, an official of Keleher & Associates, was authorized to execute all legal and administrative documents to “renounce” authorization to do business in Puerto Rico. 7. [1] JULIA BEATRICE KELEHER was the Secretary of PR DOE from in or about January 2017 until on or about April 1, 2019. While serving as Secretary of PR DOE, [1] JULIA BEATRICE KELEHER was paid via professional services contracts by The Puerto Rico Fiscal Agency and Financial Advisory Authority (hereinafter “FAFAA” or “AAFAF”). 8. The PR DOE utilized divisions and units within the PR DOE to manage different functions and to coordinate the activities of the PR DOE. One such division within the PR DOE was Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 2 of 44 the “Secretaria Auxiliar de Asuntos Federales” (Federal Affairs) unit, managed and overseen by the “Secretaria AuxiUar” (Director). 9. Individual B was the Director of Federal Affairs from in or about January 2017 until in or about August 2017. As such, she had authority to seek services for the unit, including via requests for proposals under the PR DOE regulations. 10. In or about January 2017, [5] GLENDA E. PONCE-MENDOZA began working in PR DOE representing herself to be Special Assistant to the Secretary. At that time, she was not an employee nor had a contract with the PR DOE. 11. On or about March 28, 2017, [5] GLENDA E. PONCE-MENDOZA executed a professional services contract to serve as a consultant for PR DOE. The professional services contract was signed by [1] JULIA BEATRICE KELEHER and was set to expire on June 30,2017. Pursuant to the terms of the professional services contract, [5] GLENDA E. PONCE-MENDOZA would be paid a total of $30,800.00 from March 28, 2017, to June 30, 2017, at a rate of$70.00/hour. 12. Colon & Ponce, Inc. (hereinafter “Colon & Ponce”) was a for-profit corporation organized under the laws of Puerto Rico on or about April 25, 2006. 13. [6] MAYRA PONCE-MENDOZA was the sister of [5] GLENDA E. PONCEMENDOZA and acted as corporate official and owner of Colon & Pence. THE CONSPIRACY 14. From in or about January 2017 through in or about April 2018, in the District of Puerto Rico and within the jurisdiction of this Honorable Court, [1] JULIA BEATRICE KELEHER, [53 GLENDA E. PONCE-MENDOZA, and Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 3 of 44 [6] MAYRA PONCE-MENDOZA, the defendants herein, and others known and unknown to the Grand Jury, did knowingly and willfully conspire and agree with each other to commit an offense against the United States, that is, devising a scheme and artifice to defraud and obtain money and properties by means of false and fraudulent pretenses, and promises, and in doing so, transmitting and causing to be transmitted by means of wire communications in interstate or foreign commerce, writings, signals, and email communications for the purpose of executing such scheme and artifice to defraud, in violation of Title 18, United States Code, Section 1343. PURPOSE OF THE CONSPIRACY 15. The purpose of the conspiracy was to steer contracts between the Puerto Rico Department of Education and Colon & Ponce. This was accomplished through a corrupted bidding process wherein Colon & Ponce was provided with a competitive advantage based in part, on the close relationship between [1] JULIA BEATRICE KELEHER, [5] GLENDA PONCE-MENDOZA, and [6] MAYRA PONCE-MENDOZA. OVERT ACTS IN FURTHERANCE OF THE CONSPIRACY 16. In furtherance of the conspiracy, and to accomplish its purpose, the co-conspirators (both indicted and unindicted herein), committed the following overt acts in the District of Puerto Rico and elsewhere: 17. In or about 2017, while working at the PR DOE, and representing herself to be a Special Assistant to the Secretary of PR DOE, [5] GLENDA E. PONCE-MENDOZA assisted Colon & Ponce and her sister, [6] MAYRA PONCE-MENDOZA, in securing a contract Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 4 of 44 with PR DOE. 18. On or about March 29, 2017, [6] MAYRA PONCE-MENDOZA submitted a proposal to PR DOE for services to be rendered by Colon & Ponce, all via email to her sister, [5] GLENDA E. PONCE-MENDOZA. 19. On or about April 11, 2017, [5] GLENDA E. PONCE-MENDOZA forwarded the Colon & Ponce proposal from her sister [6] MAYRA PONCE-MENDOZA to [1] JULIA BEATRICE KELEHER. After receiving the proposal from Colon & Pence, [1] JULIA BEATRICE KELEHER instructed PR DOE employees to award a contract to Colon & Ponce. 20. PR DOE regulations required a selection process, known as Request For Proposal “RFP”, to award a contract for the services involved in the Colon & Ponce proposal submitted to the PR DOE. 21. Although the PR DOE Office of Federal Affairs had not requested services such as those offered by Colon & Ponce, Individual B, then Director of Federal Affairs, was instructed by [1] JULIA BEATRICE KELEHER to award such a contract to Colon & Ponce. 22. On or about May 16, 2017, a RFP was sent by PR DOE to [6] MAYRA PONCEMENDOZA and six other competitor company representatives requesting proposals for services. 23. On or about May 17, 2017, [5] GLENDA E. PONCE-MENDOZA visited Individual C, a PR DOE employee in charge of handling the RPF involving Colon & Ponce. [5] GLENDA E. PONCE-MENDOZA asked Individual C about the status of the process, despite the May 22, 2017 deadline established in the RFP. [5] GLENDA E. PONCEMENDOZA then informed Individual C that [1] JULIA BEATRICE KELEHER had Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 5 of 44 already received the proposal and wanted to know when the process would be finalized. 24. Seven vendors were invited under the RFP of which five companies, including Colon & Ponce, timely submitted proposals. 25. On or about May 23, 2017, via telephone and via email, the US Department of Education Office of Risk Management reminded and advised [1] JULIA BEATRICE KELEHER of her duty to comply with the applicable regulations for awarding procurement contracts, with specific reference to the Colon & Ponce contract. 26. On or about May 23, 2017, after evaluating the five proposals, the original RFP was amended by PR DOE. PR DOE requested that the length and hours of the contract be shortened to no more than six months. The deadline to submit an amended proposal was May 24, 2017 at 4:30 p.m. 27. After receiving the amended RPP from PR DOE, on May 23,2017, [6] MAYRA PONCEMENDOZA forwarded the amended RFP to her sister, [5] GLENDA E.PONCEMENDOZA, who was acting as a Special Assistant to [1] JULIA BEATRICE KELEHER. 28. After receiving the amended RFP from [6] MAYRA PONCE-MENDOZA, on May 24, 2017, [5] GLENDA E. PONCE-MENDOZA fox-warded the amended RFP to Individual A, an official ofKeleher & Associates. 29. On May 24, 2017, Individual A emailed and instructed [5] GLENDA E. PONCEMENDOZA on how to amend the Colon & Ponce proposal. Individual A instructed [5] GLENDA E. PONCE-MENDOZA to add her own work and experience to the Colon & Ponce proposal without disclosing [5] GLENDA E. PONCE-MENDOZA’s identity. 30. On May 24, 2017, Colon & Ponce submitted an amended proposal to PR DOE. Following Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 6 of 44 the electronic submission of the amended proposal to PR DOE, [6] MAYRA PONCEMENDOZA emailed [5] GLENDA E. PONCE-MENDOZA on May 24, 2017, confirming the submission to PR DOE. 31. On May 25,2017, a PR DOE internal memo was sent to Individual B indicating that Colon & Ponce was recommended for the contract. 32. Individual C, the PR DOE Process Official for Fund Adjudication Unit, concluded that Colon & Ponce was the only company not qualified for the contract, and was the worst applicant. Individual C refused to sign the letter selecting Colon & Pence because the selection letter claimed that Colon & Ponce was qualified, when in fact, it was not. 33. On or about June 8, 2017, Colon & Ponce executed contract 2017-AF0220 with PR DOE. The total amount of the contract was $43,550.00, and it was set to expire on December 31, 2017. 34. Individual B executed contract 2017-AF0220 on behalf of PR DOE because she was pressmed to do so by £1] JULIA BEATRICE KELEHER. 35. On or about June 17, 2017, Individual D sent an email to [1] JULIA BEATRICE KELEHER forwarding the resume of Individual E, his former 2016 gubernatorial campaign director. 36. On or about July 6, 2017, Individual D sent an email to [1] JULIA BEATRICE KELEHER, copying Individual E, so that [1] JULIA BEATRICE KELEHER could meet with her and share employment options at the PR DOE. In the email. Individual D recommended that the meeting be held outside of the PR DOE. 37. On or about July 11, 2017, [6] MAYRA PONCE-MENDOZA sent an email to [5] GLENDA E. PONCE-MENDOZA containing proposed amendments to the Colon & Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 7 of 44 Ponce contract, based on work performed with Individual A, in order to discuss with [1] JULIA BEATRICE KELEHER. The proposed amendment included an increase of $54,800.00, for a total amended contract value of $98,350.00. 38. On or about July 18, 2017, [1] JULIA BEATRICE KELEHER forwarded Individual E’s resume to Individual F, who acted as one of her Special Assistants. 39. In or about August, 2017, [1] JULIA BEATRICE KELEHER became aware that the appointment of Individual E as a government employee would not be feasible. 40. In or about August 2017, Individual E was informed by [1] JULIA BEATRICE KELEHER that her payments as a Special Assistant would be made by Colon & Ponce, a company Individual E was not familiar with. 41. On or about August 8,2017, [6] MAYRAPONCE-MENDOZA sent a draft proposal with amendments to the Colon & Ponce contract number 2017-AF0220 for review by [5] GLENDA E. PONCE-MENDOZA and Individual A. The proposal contained various options, including a proposed increase in the value of the contract. 42. On August 21, 2017, [6] MAYRA PONCE-MENDOZA submitted a proposal for an amended contract to [1] JULIA BEATRICE KELEHER. That same date, [1] JULIA BEATRICE KELEHER responded via email to [6] MAYRA PONCE-MENDOZA advising [6] MAYRA PONCE-MENDOZA that revisions were required. 43. On August 22, 2017, [6] MAYRA PONCE-MENDOZA sent a further email to [1] JULIA BEATRICE KELEHER containing a revised proposal to amend the Colon & Ponce contract. This particular proposal intended to increase the contract value to $455,100.00. 44. On or about August 24, 2017, [1] JULIA BEATRICE KELEHER forwarded [6] Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 8 of 44 MAYRA PONCE-MENDOZA’s August 22, 2017 email to Individual G, a PR DOE employee, and Individual F, advising them: “Check this; should be ok to go”. 45. In or about August 2017, at the direction of [1] JULIA BEATRICE KELEHER, Individual E was provided with an official PR DOE email address even though at that time Individual E was not an employee nor a contractor at the PR DOE. Individual E then used her official email address to communicate with Puerto Rico government officials, representing herself to be an “Ayudante Especial” (Special Assistant) in the Office of the Secretary of the Department of Education. 46. On or about September 1, 2017, [1] JULIA BEATRICE KELEHER emailed Individual B, Individual E, and [5] GLENDA E. PONCE-MENDOZA, regarding the Colon & Ponce contract. 47. On or about September 11, 2017, Individual E sent an email to a federal agent of the United States Department of Homeland Security utilizing a personal Gmail address wherein she represented herself to be an “Ayudante Especial” (Special Assistant) to the “Secretaria de Educacion” (Secretary of Education), even though at that time she was not an employee nor a contractor at the PR DOE. In the email, Individual E requested information from the federal agent in connection with her task of drafting PR DOE’S security plan. 48. On or about September 13, 2017, [1] JULIA BEATRICE KELEHER approved the request for authorization to amend the Colon & Ponce contract for an initial increase of $51,450.00. 49. On or about October 25, 2017, an amended contract, 2017-AF0220-A, was executed between Colon & Ponce and the PR DOE. The total value of the amended contract became $95,000.00. Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 9 of 44 50. Individual E was paid by Colon & Ponce from the $51,450.00 added to the original $43,550.00 contract as follows: Check Number Check 1281 Check 1284 Check 1285 Check Dated January 13,2018 April 13, 2018 April 13, 2018 Total Amount $1,593.00 $6,472.80 $7,551.60 $15,617.40 51. During the year 2017, [5] GLENDA E. PONCE-MENDOZA received monetary payments from Colon & Ponce for services rendered totaling approximately $16,425.00, plus at least $834.60 in expenses. All in violation of Title 18, United States Code, Section 1349. COUNTS TWO TO ELEVEN 18 U.S.C. § 1343 (Wire Fraud) 52. The allegations contained in Count One, paragraphs 1-51, of this Indictment are re-alleged and incorporated herein by reference. 53. On or about each of the dates set forth below, in the District of Puerto Rico, [1] JULIA BEATRICE KELEHER, [5] GLENDA E. PONCE-MENDOZA, and [6] MAYRA PONCE-MENDOZA, defendants in each count when named below, for the purpose of executing the scheme described Count One, and attempting to do so, caused to be transmitted by means of wire communication in interstate commerce the signals and sounds described below for each count, each transmission constituting a separate count: 10 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 10 of 44 Count 2. 3. 4. 5. 6. 7. 8. 9. 10. Date August 24,2017 August 22,2017 August 8, 2017 July 11, 2017 May 24, 2017 May 24, 2017 May 24, 2017 May 23, 2017 April 11, 2017 From [1] JULIA BEATRICE KELEHER [6] MAYRA PONCEMENDOZA [6] MAYRA PONCEMENDOZA [6] MAYRA PONCEMENDOZA [6] MAYRA PONCEMENDOZA Individual A [5] GLENDA E. PONCEMENDOZA [6] MAYRA PONCEMENDOZA [5] GLENDA E. PONCEMENDOZA To Individual G and Individual F [1] JULIA BEATRICE KELEHER [5] GLENDA E. PONCEMENDOZA and Individual A [5] GLENDA E. PONCEMENDOZA [5] GLENDA E. PONCEMENDOZA [5] GLENDA E. PONCEMENDOZA Individual A [5] GLENDA E. PONCEMENDOZA [1] JULIA BEATRICE KELEHER, Description Email forwarding the revised Colon & Ponce proposal to amend the existing contract with an annotation that it “should be ok to go” Email submitting a revised Colon & Ponce proposal to amend the existing contract Submitting a draft proposal with amendments to the Colon & Ponce existing contract Email containing proposed amendments to the Colon & Pence contract to be discussed with [1] Julia Beatrice KELEHER, including an increase of $54,800 Email forwarding an email with the submission of the updated Colon & Ponce proposal to PR DOE Email instructing Glenda E. PONCE-MENDOZA on how to amend the Colon & Ponce proposal to the PR DOE Email forwarding the email from Mayra PONCE-MENDOZA in which she forwarded the email from the PR DOE from May 23, 2017 requesting Colon & Ponce to update the billing rate section in the proposal for services already submitted to the PR DOE Email forwarding an email from the PR DOE from May 23,2017 requesting Colon & Ponce to update the billing rate section in the proposal for services already submitted to the PR DOE Email forwarding a Colon & Ponce proposal for services for the PR DOE 11 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 11 of 44 11. March 29, 2017 [6] MAYRA PONCEMENDOZA [5] GLENDA E. PONCEMENDOZA Email forwarding a Colon & Pence presentation for services to PR DOE All in violation of Title 18, United States Code, Section 1343. COUNT TWELVE 18 U.S.C. § 371 (Conspiracy to Commit an Offense Against the United States) Unless otherwise specified, at all times material to this Indictment: 54. The allegations contained in paragraphs 1^2 and 7-11 are re-alleged and incorporated herein by reference. 55. BDO Puerto Rico, P.S.C. was a for-profit professional services corporation originally organized under the laws of Puerto Rico on or about January 26, 2000, under its former name Scherrer, Hernandez & Co., CPA, P.S.C. 56. HLB Parissi P.S.C. (“Parissi”) was a for-proflt professional services coi*poration originally organized under the laws of Puerto Rico on or about May 2, 2002, under its former name Rodriguez-Parissi, Vazquez & Co. 57. On or about July 1, 2016, Parissi executed contract 2017-AF0007 with PR DOE to provide technical and finance assistance to the Financial Affairs unit of the PR DOE. The total value of the contract was $430,200,00, and it was set to expire on June 30, 2017. 58. BDO Puerto Rico, P.S.C. and Parissi executed a Certificate of Merger dated December 31, 2016, wherein BDO Puerto Rico, P.S.C. and Parissi memorialized an agreement to merge pursuant to the terms of an Agreement of Merger, all effective June 30, 2017. Following the merger, the company was known as BDO Puerto Rico, P.S.C. (hereinafter “BDO”), 12 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 12 of 44 59. On or about November 3, 2016, BDO executed contract 2017-AF0159 with the PR DOE to provide auditing services to the PR DOE. The total value of the contract was $199,500.00, and it was set to expire on or about June 30,2017. 60. [4] FERNANDO SCHERRER-CAILLET was the managing partner ofBDO. 61. AZUR, L.L.C. (hereinafter “Azur”) was a for-profit limited liability company organized under the laws of Puerto Rico on or about June 5, 2013. 62. [3] ALBERTO VELAZQUEZ-PINOL was the president, vice president, treasurer, subtreasurer, secretary, sub-secretary and owner ofAzur. THE CONSPIRACY 63. From in or about January 2017, through In or about April 2019, in the District of Puerto Rico and within the jurisdiction of this Honorable Court, [1] JULIA BEATRICE KELEHER, [3] ALBERTO A. VELAZQUEZ, and [4] FERNANDO SCHERRER-CAILLET, the defendants herein, did knowingly and willfully conspire, combine, confederate, and agree with each other and with other individuals known and unknown to the Grand Jury, to commit an offense against the United States, to wit: theft and conversion of government money and property in excess of $1,000.00, in relation to federal funds paid by PR DOE to BDO, in violation of Title 18, United States Code, Section 641. PURPOSE OF THE CONSPIRACY 64. The pmpose of the conspiracy and scheme to defraud was for the defendants to utilize the position of public officials within the government of the Commonwealth of Puerto Rico to benefit and enrich themselves through fraud and the theft of government funds. 13 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 13 of 44 MANNER AND MEANS OF THE CONSPIRACY As part of the manner and means of the conspiracy: 65. Defendants and other co-conspirators exchanged email communications containing internal government information regarding government contracts. 66. Government contract balances were disclosed to non-government employees for use in the submission of new contract proposals. 67. Internal government information was disclosed to non-govemmental individuals in order to aid companies and individuals in obtaining government contracts. 68. Entities seeking government contracts utilized individuals with government influence to seek and obtain government contracts. 69. Entities seeking government contracts negotiated with and paid individuals with government influence to obtain government contracts. 70. On occasion, existing government contracts were cancelled or terminated in order to award replacement or substitute contracts to vendors endorsed and promoted by individuals with government influence. 71. Government officials acted based on the political affiliation of proposed contractors. 72. Government officials granted non-governmental individuals access to facilities, offices, information, and other government operations despite the fact that the individuals were neither employees nor contractors of the government at the time access was granted. This practice provided access to non-governmental individuals to obtain internal government information and documentation. This practice allowed vendors to obtain internal government department or agency information for the preparation of contract proposals. 14 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 14 of 44 Further, this practice permitted non-governmental individuals to utilize government property and facilities for their own personal benefit. 73. Government officials allowed and permitted non-governmental individuals to exercise authority over department or agency officials. 74. Individuals misrepresented that they possessed a title or position within the government when in fact the individual was neither an employee nor contractor of the government. 75. Government officials utilized non-govemment employees and non-government contractors to perform services and direct actions to be performed by government officials. 76. Government officials instructed government contractors to hire and pay specific individuals to perform work at the direction of the government official. Government officials utilized those specific individuals, paid through government contracts, to perform services and functions outside the scope of the contracts awarded. 77. Government officials utilized personal email accounts and instructed subordinates to open and use private email accounts in order to conduct official government business. 78. Government officials and employees utilized electronic messaging applications, including Telegram, an encrypted messaging application that can be programmed by its users to autodelete messages (self-destmct). This encrypted self-deleting messaging application was often used to conduct official government business. 79. Government officials forwarded internal department and agency information from their official government email accounts to their personal email accounts. 80. Government contracts were awarded without complying with applicable government regulations and competitive proposal processes. 81. Despite express prohibitions on unauthorized subcontracting and the payment of lobbyists, 15 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 15 of 44 government contracts were executed by government officials and contractors who intended to subcontract the services and pay commissions for the contracts awarded through influence with government officials. 82. Members of the conspiracy and scheme failed to disclose that portions of the funds assigned under the contracts would be paid as commissions by the contractors to individuals with government influence in exchange for obtaining the government contract. 83. By paying unauthorized commissions, the cost of government contracts was unnecessarily inflated and increased. 84. Electronic communications were transmitted and caused to be transmitted by means of wire comnumication in interstate commerce, all in furtherance of the conspiracy, scheme to defraud, and the theft of federal funds. 85. Government officials authorized contract amendments that were utilized to increase the value of contracts and to provide employment to specific individuals through contractors. 86. Defendants made false representations and took action in violation of federal and Puerto Rico law in order to solicit, procure, and award government contracts paid with federal funds. OVERT ACTS IN FURTHERANCE OF THE CONSPIRACY 87. In furtherance of the conspiracy, and to accomplish its purpose, the co-conspirators (both indicted and unindicted herein), committed the following overt acts in the District of Puerto Rico and elsewhere: 88. On or about January 27, 2017, [1] JULIA BEATRICE KELEHER sent an email to [3] ALBERTO VELAZQUEZ-PINOL, [5] GLENDA E. PONCE-MENDOZA, and Individual F stating in part, “Alberto, Adjunto las tablas que te mencione… no recopUamos 16 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 16 of 44 datos de forma organizada. Glenda, busca las tablas de [PR DOE Employee] sobre vacante, etc y dale FW a Alberto.” (Alberto, Attached are the charts that I had mentioned to you… we don t gather data in an organized fashion. Glenda, find the charts from [PR DOE Employee] about vacancies, etc. and forward to Alberto.) 89. On or about February 1, 2017, [3] ALBERTO VELAZQUEZ-PINOL met Individual B for dinner at Suchville Plaza located in Guaynabo, Puerto Rico. 90. On or about February 2, 2017, BDO circulated a proposed engagement letter addressed to Individual B to amend contract 2017-AF0159 to increase the November 2016 contract value of $199,500.00 by an additional amount of $291,080.00 for a total of $490,580.00. 91. On or about February 5, 2017, BDO sent the engagement letter, which was addressed to Individual B, via email to [3] ALBERTO VELAZQUEZ-PINOL. BDO stated that the requested increase was based on $196,080.00 in value being transferred from a contract involving Parissi and $95,000.00 in additional value being added. 92. On or about February 6, 2017, [3] ALBERTO VELAZQUEZ-PINOL forwarded BDO’s engagement letter to Individual B at XXXX@gmail.com and requested that she verify if it appeared acceptable so that it could be submitted. 93. On or about February 7, 2017, [3] ALBERTO VELAZQUEZ-PINOL forwarded BDO’s engagement letter to [1] JULIA BEATRICE KELEHER at XXXX@gmail.com. [1] JULIA BEATRICE KELEHER responded from her personal email account to [3] ALBERTO VELAZQUEZ-PINOL, discussing language to be utilized in BDO’s contract amendment. 94. On or about February 22, 2017, [1] JULIA BEATRICE KELEHER took a photograph, using her personal telephone, of a computer screen containing an internal PR DOE 17 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 17 of 44 communication from [1] JULIA BEATRICE KELEHER to Individual B. The communication to Individual B involved personnel and hours pertaining to BDO. The photograph was sent via text message (multimedia messaging service or “mms”) to [3] ALBERTO VELAZQUEZ-PINOL’s email address. 95. On or about February 24, 2017, BDO sent a Proposal and Engagement Letter for the PR DOE to [3] ALBERTO VELAZQUEZ-PINOL for the amendment of contract 2017- AF0159. 96. Via letter dated March 1, 2017, Parissi requested the early termination of its contract with the PR DOE (2017-AF0007) set to expire on June 30,2017. Parissi requested a cancellation date of March 14,2017, and further informed PR DOE that the request was due to Parissi’s merger with BDO. On June 30, 2017, Parissi filed a Certificate of Merger with BDO at the Puerto Rico Department of State notifying that the merger would become effective for all purposes at ll:59p.m. on June 30, 2017. 97. In or about March 2017, [3] ALBERTO VELAZQUEZ-PINOL and [4] FERNANDO SCHERRER-CAILLET agreed that [3] ALBERTO VELAZQUEZ-PINOL would receive a 10% commission on any contracts he obtained for BDO. 98. On or about March 14, 2017, BDO executed an amendment to contract 2017-AF0159 with PR DOE to increase the value of the contract by $291,080.00. The amended value of the contract was $490,580.00. 99. As apart of Contract 2017-AFO 159, [4] FERNANDO SCHERRER-CAILLET certified that services under the contract did not include lobbying services and that the funds assigned under the contract would not be used to pay for lobbying services, regardless of their pmpose. 18 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 18 of 44 100. Contract 2017-AF0159 prohibited BDO from subcontracting other companies to perform the services to be provided under the contract. 101. On or about April 11,2017, [3] ALBERTO VELAZQUEZ-PINOL submitted invoice 20170411 from Azur to BDO requesting a partial payment corresponding to a 10% commission for [3] ALBERTO VELAZQUEZ-PINOl/s efforts in securing a $95,000.00 partial increase to contract 2017-AF0159. 102. On or about May 4, 2017, BDO paid [3] ALBERTO VELAZQUEZ-PINOL, via check number 14979 payable to the order of Azur, a total of $5,226.75 pertaining to commissions billed in April 2017. 103. On or about April 19, 2017, BDO executed a second amendment to contract 2017- AF0159 with the PR DOE to increase the value of the contract by an additional $589,000.00. Pursuant to the second amendment, the contract value was $1,079,580.00. 104. On or about July 10, 2017, BDO executed contract 2018-AF0019 with the PR DOE to provide consulting services to the PR DOE. The total value of the contract was $4,770,330.00, and it was set to expire on or about June 30, 2018. 105. As part of Contract 2018-AF0019, [4] FERNANDO SCHERRER-CAILLET certified that services under the contract did not include lobbying services and that the funds assigned under the contract would not be used to pay for lobbying services, regardless of their purpose. 106. Contract 2018-AF0019 prohibited BDO from subcontracting other companies to perform the services to be provided under the contract. 107. On or about October 19, 2017, BDO paid f3] ALBERTO VELAZQUEZ-PINOL a total of $47,570.16, via check number 15642 payable to the order ofAzur with memo: 19 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 19 of 44 “PS/Comisiones- BDO-PRED Contract.” (PS/Comissions-BDO-PRED Contract). Check number 15642 was signed by [4] FERNANDO SCHERRER-CAILLET. 108. On or about December 22, 2017, Individual E emailed [6] MAYRA PONCEMENDOZA and Individual F advising them that Individual E’s contract with Colon & Ponce was set to expire at the end of the year. In or about December 2017, [1] JULIA BEATRICE KELEHER met with Individual H, a partner at BDO, and instructed him to hire Individual E under BDO. Individual E was then informed by [1] JULIA BEATRICE KELEHER that her payments as a Special Assistant would now be made through BDO, a company Individual E was not associated with at the time. 109. On or about December 27, 2017, BDO’s internal accountant provided [3]ALBERTO VELAZQUEZ-PINOL with a summary of the commissions invoiced by [3] ALBERTO VELAZQUEZ-PINOL through Azur and payments by BDO to [3] ALBERTO VELAZQUEZ-PINOL through Azur for the months of July 2017 through September 2017. The chart prepared by BDO, and provided via email to [3] ALBERTO VELAZQUEZ-PINOL, detailed the amounts collected by BDO from PR DOE and the 10% commission payments by BDO to [3] ALBERTO VELAZQUEZ-PINOL. The chart provided as follows: PRDE Invoices Period Ju(-17 Jul-!7 Aug-17 Aug.17 Sep-17 Sep-17 Amount 69,656.25 9′?,583.75 223,867.50 [39,008.75 56,620.00 88,065.00 (-1.5%)Gov tax 1,344.84 1,493.76 3,358.02 2,085,14 849.30 1,320.97 Collected 88,311.41 98,089.99 220,509.-‘l^ 30 10,000 t’.l’/. ^C L)S 30 Ui,000 -‘% uf 100% i’Cr’6 Model 2 1,250,000 118,750 1,131,250 62,500 950/000 118,750 118,750 181,250 14.50% 1,068,750 85.50% 106.83 30 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 30 of 44 158. On or about January 24, 2017, [4] FERNANDO SCHERRER-CAILLET sent a proposal on behalf of BDO for advisory services to [3] ALBERTO VELAZQUEZPINOL and [2] ANGELA AVILA-MARRERO, via her personal email account. The contract amount proposed by BDO was $1,035,000.00 from inception until June 30,2017. 159. On or about January 24, 2017, [3] ALBERTO VELAZQUEZ-PINOL sent a proposal from Company C for Grant Management Staffing for Accounting Services and Other Professional Services to [2] ANGELA AVILA-MARRERO^s, personal email account. The contract amount proposed by Company C was $1,158,000.00. 160. At approximately 12:54 a.m., on or about January.25, 2017, [2] ANGELA AVILAMARRERO sent an email to Board Member A, President of Board of Directors ofASES, containing an agenda for the ASES Board of Directors meeting to be held on January 25, 2017, along with a draft of the “Informe Del Directora Ejecutivo Interina” {sic) (Acting Executive Director Report). The Acting Executive Director Report draft contained a section submitting proposals to award contracts to BDO, Company C, and Individual L, at the time a student intern at ASES, for the Board of Director’s approval. The proposals were purportedly based on the fiscal situation facing the Puerto Rico health system and the need to avoid the interruption of services. 161. At approximately 1:05 a.m., on or about January 25, 2017, [2] ANGELA AVILAMARRERO forwarded her 12:54 a.m. email to [3j ALBERTO VELAZQUEZ-PINOL. 162. On or about January 25, 2017, [2] ANGELA AVILA-MARRERO sent a letter to Company A cancelling contract 2017-000039. The letter signed by [2] ANGELA AVILAMARRERO stated, “En virtud de la clausula Cuadragesima Sexta del mencionado contrato de servicios y luego de realizar un analisis de necesidad, la ASES ha determinado 31 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 31 of 44 cancelar el acuerdo, efectivo inmediatamente.” (“Pursuant to Clause Forty-Six of the aforementioned services contract and upon an analysis of needs, ASES has determined to cancel the contract, effective immediately.”). 163. On or about January 25, 2017, the ASES Board of Directors held a meeting. [2] ANGELA AVILA-MARRERO was present at the meeting and discussed the cancellation of various contracts, including the cancellation of contracts with Company A. 164. On or about January 25, 2017, at the meeting of the ASES Board of Directors, [2] ANGELA AVILA-MARRERO recommended that some of the cancelled contracts be substituted and awarded to Company C and BDO, among others. With respect to Company C, [2] ANGELA AVILA-MARRERO recommended to the Board of Directors that a financial firm which had “la confianza de esta administracion” (the trust of this administration) should be contracted. With respect to BDO, [2] ANGELA AVILAMARRERO confirmed to the Board of Directors that BDO had the trust of the administration. 165. At the January 25, 2017 meeting of the ASES Board of Directors, [2] ANGELA AVILA-MARRERO stated as follows: Board Member B: Direc/ora, ^ estos son nuevos, son proveedores nuevos? (Director, these are new, new providers?) [2JANGELA AVILA-MARRERO: Nuevos. (New.) Board Member B: Nuevos. (New.) [2JANGELA AVILA-MARRERO: Totalmente nuevos. (Totally new.) Board Member B : Bien, (Good.) [2JANGELA 32 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 32 of 44 A VILA-MARRERO: Yque gozan de la confianza de… (And they have the trust of…} Board Member B: De su administracion. (of your administration.) [2JANGELA AVILA-MARRERO: … de nuestra adminislracion. (of our administration.) 166. On or about January 25, 2017, the ASES Board of Directors discussed the approval of contracts to BDO and Company C based on the recommendations made by [23 ANGELA AVILA-MARRERO. 167. In or about February 2017, [2] ANGELA AVILA-MARRERO was appointed Executive Director ofASES. 168. On or about March 1, 2017, [2] ANGELA AVILA-MARRERO and [3] ALBERTO VELAZQUEZ-PINOL attended the meeting of the ASES Board of Directors. [3] ALBERTO VELAZQVEZ-PINOL was identified as the “Asesor Asuntos Federales, ASES” (ASES Advisor for Federal Affairs) even though he was not an employee or contractor ofASES at the time. [2] ANGELA AVILA-MARRERO informed the ASES Board of Directors that the Puerto Rico Oficina de Gerencia y Presupuesto (hereinafter “OGP” or “Office of Management and Budget” or “0MB”) had not yet certified the contracts for BDO or Company C. 169. On or about March 1,2017, the ASES Board of Directors ratified the award of contracts to BDO and Company C. 170. On or about March 22, 2017, the “Gobiemo de Puerto Rico Oficina de Secretario de la Gobernacion” (Government of Puerto Rico Office of Chief of Staff hereinafter “Chief of Staff) approved a contract between ASES and BDO for a total amount of $828,000.00. The approval letter was signed by the Chief of Staff and Board Member B, who was also 33 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 33 of 44 an official at OGP. On or about that same date, [2] ANGELA AVILA-MARRERO sent the approval letter to [3] ALBERTO VELAZQUEZ-PINOL, as well as others, and requested that certain information be provided to [3] ALBERTO VELAZQUEZ-PINOL to perform services under the contract. [3] ALBERTO VELAZQUEZ-PINOL forwarded the approval letter to [4] FERNANDO SCHERRER-CAILLET. 171. On or about March 31,2017, Individual M, an employee of ASES, sent an email to [3] ALBERTO VELAZQUEZ-PINOL and [2] ANGELA AVILA-MARRERO containing a proposed draft letter to be sent to the Associate Regional Administrator for HHS, Medicaid Division. The proposed draft .letter informed CMS that ASES had cancelled the contract with Company B and was seeking permission to replace Company B with BDO. 172. On or about March 31, 2017, [3] ALBERTO VELAZQUEZ-PINOL responded via email to Individual M and [2] ANGELA AVILA-MARRERO that he had suggestions to edit the proposed letter to the Associate Regional Administrator for HHS, as detailed below in redacted format: Ao”i;ji AVP ^F ‘.iil’n’f; Re: Bosquejo M. ^^^^B” BDO-^^^B f{ ) ^.Angela Avila i^ AUn no. Tengo par de sngerencias para editar e) doc. Estoy a punto de despegar. Te comento luego. Saludos. Not yet) have 3 COUPIe of suggestions to edit tlie doc. I’m about to take off, I’ll tell you later. j Greetings, On Mar 31, 2017, at 12:59 PMj HotaAlberto, Este es el bosquejo. dYa hablaste con Michael? Saludos, 1 attachment: BosquejoM,^^^B re BDO-^Bdac ”:.; i(i! Hello Alberto, This is the draft. Did you talk to Michael? Greetings, 34 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 34 of 44 173. On or about April 5,2017J2] ANGELA AVILA-MARRERO emailed a revised letter to the Associate Regional Administrator for HHS, [3] ALBERTO VELAZQUEZPINOL and Individual M, requesting permission to contract with BDO. 174. The April 5, 2017 letter to the Associate Regional Administrator for HHS represented that the contract with Company B was terminated due to a potential conflict of interest. 175. The April 5, 2017 letter to the Associate Regional Administrator for HHS did not disclose that [3] ALBERTO VELAZQUEZ-PINOL had an interest in BDO’s operations or [3] ALBERTO VELAZQUEZ-PINOL’s role in drafting the April 5, 2017 letter requesting authorization to contract with BDO to perform the services previously performed by Company B. 176. On or about April 3, 2017, BDO executed contract 2017-000080 with ASES with a total value of $828,000.00, and an expiration of June 30, 2017. 177. In response to the April 5, 2017 letter, on or about June 8,2017, the Associate Regional Administrator for HHS approved ASES’ request to contract with BDO. 178. On or about June 19, 2017, BDO executed contract 2017-000085 with ASES for a total amount of $125,000.00, and set to expire on November 30, 2018. 179. On or about July 10, 2017, BDO executed contract 2018-000033 with ASES for atotal amount of $1,375,000.00 and set to expire on June 30, 2018. 180. BDO made payments to [3] ALBERTO VELAZQUEZ-PINOL, via Azur, including those identified below on or about the dates listed therein, based on contracts awarded by ASES to BDO. These payments were in addition to payments made to [3] ALBERTO VELAZQUEZ-PINOL by BDO in relation to other contracts with PR DOE. 35 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 35 of 44 From BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO BDO To AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR AZUR Check Number 14743 14956 15010 15174 15309 15461 15438 15549 15639 15701 15754 15814 15874 15954 16070 16120 16097 16214 16262 16263 16339 16345 16499 16508 16539 16617 16757 16823 16898 16963 16969 17049 17105 17173 17250 Check Date 3/6/2017 4/28/2017 5/15/2017 6/15/2017 7/14/2017 8/15/2017 8/15/2017 9/13/2017 10/19/2017 11/13/2017 11/27/2017 12/12/2017 12/20/2017 1/10/2018 2/5/2018 2/13/2018 2/13/2018 3/13/2018 3/14/2018 3/14/2018 4/9/2018 4/10/2018 5/8/2018 5/14/2018 5/15/2018 6/13/2018 7/12/2018 7/18/2018 8/14/2018 8/20/2018 8/22/2018 9/12/2018 9/14/2018 10/11/2018 10/24/2018 Amount $8,781.50 $7,120.50 $8,105.25 $12,309.37 $5,302.50 $19,619.25 $2,646.45 $28,254.75 $6,741.75 $55,449.00 $12,495.92 $27,118.50 $14,393.99 $15,486.00 $10,566.25 $31,909.40 $22,770.75 $19,278.75 $5,641.90 $34,264.83 $29,249.92 $13,095.00 $63,049.54 $15,714.00 $5,264.32 $20,661.00 $18,042.00 $20,488.82 $7,056.75 $82,358.12 $2,092.09 $17,751.00 $9,761.66 $16,950.75 $6,922.08 Memo PS March 15-31, 2017 PS April-2017 PS May 2017 PS June 2017 PS/July 2017 PS/ Comisiones PS/August 2017 PS/September 2017 PS/October 2017 PS/Novembei-2017 PS/Comisiones – BDO – ASES Contract (Sept) PS/December2017 PS/January2018 PS/February2018 PS/March2018 PS/April2018 PS/May2018 PS/June2018 PS/july2018 PS/Comisiones -BDO ASES” Contract February 201 PS/August2018 PS/Comisiones -BDO – ASES – Contract June 2018 PS/September2018 PS/Comisiones -BDO – ASES – Contract July 2018 36 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 36 of 44 BDO BDO AZUR AZUR 17283 17323 10/31/2018 11/14/2018 TOTAL $6,922.08 $26,990.25 $710,625.99 PS/Comisiones -BDO – ASES – Contract July 2018 PS/October2018 All in violation of Title 18, United States Code, Section 371. COUNTS TWENTY TO TWENTY-FIVE 18 U.S.C. S 1343 (Wire Fraud) 181. The allegations contained in Count Nineteen, paragraphs 116-180 of this Indictment are re-alleged and incorporated herein by reference. 182. On or about each of the dates set forth below, in the District of Puerto Rico, [2] ANGELA AVILA-MARRERO, [3] ALBERTO VELAZQUEZ-PINOL, and [4] FERNANDO SCHERRER-CAILLET, defendants in each count when named below, for the purpose of executing the scheme described in Count Nineteen, and attempting to do so, caused to be transmitted by means of wire communication in interstate commerce the signals and sounds described below for each count, each transmission constituting a separate count: Count 20. 21. Date January 16,2017 January 16,2017 From [2] ANGELA AVILAMARRERO [2] ANGELA AVILAMARRERO To [3]ALBERTO VELAZQUEZPINOL [3]ALBERTO VELAZQUEZPINOL Description Email forwarding internal government information pertaining to the balance of multiple ASES contracts Email forwarding an excel spreadsheet containing a list of contracts and advising [3] Alberto Velazquez- Pinol that she would be sending copies of 37 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 37 of 44 22. 23. 24. 25. January 16,2017 January 23,2017 January 24,2017 March 31,2017 [2] ANGELA AVILAMARRERO [4] FERNANDO SCHERRERCAILLET [4] FERNANDO SCHERRERCAILLET [3] ALBERTO VELAZQUEZPINOL [3]ALBERTO VELAZQUEZPINOL [3]ALBERTO VELAZQUEZPINOL [3] ALBERTO VELAZQUEZPINOL and [2] ANGELA AVILAMARMRO Individual M and [2] ANGELA AVILAMARRERO the most important contracts in individual messages Email forwarding an electronic •pdf file containing a copy of contract 2017-000040 between ASES and Company B Email with the business model outlining two options for payment of a commission for [3] Alberto Velazquez-Pmol Email containing a proposal from BDO for advisory services for the amount of $1,035,000.00 Email from Alberto VelazquezPifiol responding to Individual M and Angle Avila-Marrero that he had suggestions to edit the proposed letter to the Associate Regional Administrator for HHS All in violation of Title 18, United States Code, Section 1343. COUNT TWENTY-SIX 18 U.S.C. S 1956^) (Conspiracy to Launder Monetary Instruments) 183. The allegations contained in paragraphs 1^2, 7-11, and 54-182 of this Indictment are re-alleged and incorporated herein by reference. 184. From in or about January 2017 through in or about May 2019, in the District of Puerto Rico and within the jurisdiction of this Honorable Court, [3] ALBERTO VELAZQUEZ-PINOL and [4] FERNANDO SCHERRER-CAILLET, 38 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 38 of 44 the defendants herein, did knowingly combine, conspire, and agree with each other and with other persons hiown and unknown to the Grand Jury to commit offenses against the United States in violation of 18 U.S.C. §§ 1956 and 1957, to wit: to knowingly conduct and attempt to conduct financial transactions affecting interstate commerce and foreign commerce, which transactions involved the proceeds of specified unlawful activity, that is, proceeds from the conduct identified in Counts 12-26 above, knowing that the transactions were designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of specified unlawful activity, and that while conducting and attempting to conduct such financial transactions, knew that the property involved in the financial transactions represented the proceeds of some form of unlawful activity, in violation of 18 U.S.C. § 1956(a)(l)(B)(i); MANNER AND MEANS OF THE CONSPIRACY 185. The manner and means used to accomplish the objectives of the conspiracy included, among others, the use of company and business bank accounts to receive and make monetary transactions. 186. The manner and means used to accomplish the objectives of the conspiracy included, among others, the use of financial institutions to make monetary transactions designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of specified unlawful activity. All in violation of 18 U.S.C. § 1956(h). 39 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 39 of 44 COUNTS TWENTY-SEVEN TO THIRTY-TWO 18 U.S.C. § 1957 (Engagingjn Monetary Transactions in Property Derived from Specified Unlawful Activity) 1. The allegations contained in paragraphs 1-2, 7-11, and 54-182 of this Indictment are realleged and incorporated herein by reference. 2. On or about the dates set forth below, in the District of Puerto Rico and within the jurisdiction of this Honorable Court, [3] ALBERTO VELAZQUEZ-PINOL the defendant herein, did knowingly engage and attempt to engage in the following monetary transactions by, through or to a financial institution, affecting interstate or foreign commerce, in criminally derived property of a value greater than $10,000, that is the, deposit, withdrawal, and transfer ofU.S. currency, funds, and monetary instruments, such property having been derived from a specified unlawful activity, that is, conspiracy and theft of government funds In violation of 18 U.S.C. §§ 371 and 641 and wire fraud in violation of 18 U.S.C. § 1343. Count 27. 28. 29. 30. Check No./ Descrip tion 103 Ill 1012 1007 Date 2-2-2018 3-15-2018 7-5-2018 7-20-2018 From Name Azur, LLC Azur, LLC Azur, LLC Azur, LLC Acct xxxxx 1893 xxxxx 1893 xxxxx 1893 xxxxx 1893 To Name [3]ALBERTO VELAZQUEZPINOL [3]ALBERTO VELAZQUEZPINOL [3]ALBERTO VELAZQUEZPINOL [3]ALBERTO VELAZQUEZPINOL Acct xxxxx 6508 xxxxx 6508 xxxxx 6508 xxxxx 6508 Amount (USD) $13,950.00 $13,950.00 $13,950.00 $13,950.00 40 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 40 of 44 31. 32. Withdra wal 1025 8-13-2018 8-31-2018 Azur, LLC Azur, LLC xxxxx 1893 xxxxx 1893 Purchase of Official Check [3] ALBERTO VELAZQUEZPINOL n/a xxxxx 6508 $170,631.30 $23,250.00 All in violation of 18 U.S.C. §§ 1957. 41 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 41 of 44 FORFEITURE ALLEGATIONS The allegations contained in Counts 1-25 of this Indictment are hereby re-alleged and incorporated by reference for the purpose of alleging forfeitures pursuant to Title 18, United States Code, Section 981(a)(l)(C) and Title 28, UniMStates^ode, Section 2461(c). Upon conviction of an offense in violation of Title 18, United States Code, Sections 371, 1343, or 1349 set forth in Counts 1-25 of this Indictment, the defendants, [1] JULIA BEATRICE KELEHER, [2] ANGELA AVILA-MARRERO, [3] ALBERTO VELAZQUEZ-PINOL, [4] FERNANDO SCHERRER-CAILLET, [5] GLENDA E. PONCE-MENDOZA, and [6] MAYRA PONCE-MENDOZA, shall forfeit to the United States of America, pursuant to Title 18, United States Code, Section 981(a)(l)(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, including, but not limited to: a: HORIZONTAL PROPERTY: Apartment number 2-B in the regime of Horizontal Property known as Las Olas Condominium, located at 1505 Ashford Avenue in Condado, Santm’ce, Puerto Rico. This apartment is in the central area of the second floor of the building and has a superficial area of approximately 808 square feet, equivalent to 75.06 square meters. Bounding by the NORTH, with party wall that separates it from apartment 2-A from the same floor; by the SOUTH, with party wall that separates it from apartment 2- C from the same floor, by the EAST, with patio area in which the building enclave bounding with land property of the Electric Power Authority; and by the WEST, with common corridor that connects all apartments with elevators, stairs and other common facilities in the same floor. 42 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 42 of 44 If any of the property described above, as a result of any act or omission of the defendants (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)(l)(C) and 28 U.S.C. § 2461(c). MONEY LAUNDEmNG FORFEITURE ALLEGATIONS The allegations contained in Counts 26-32 of this Indictment are hereby realleged and incorporated by reference for the purpose of alleging forfeitures pursuant to Title 18, United States Code, Sections 982(a)(l). Pursuant to Title 18, United States Code, Section 982(a)(l), upon conviction of an offense in violation of Title 18, United States Code, Section 1956 or 1957, the defendants, [3] ALBERTO VELAZQUEZ-PINOL, and [4] FERNANDO SCHERRER-CAILLET, shall forfeit to the United States of America any property, real or personal, involved in such offense, and any property traceable to such property. The property to be forfeited includes, but is not limited to, the following: a: HORIZONTAL PROPERTY: Apartment number 2-B in the regime of Horizontal Property known as Las Olas Condominium, located at 1505 Ashford Avenue in Condado, Santurce, Puerto Rico. This apartment is in the central area of the second floor of the building and has a superficial area of approximately 808 square feet, equivalent to 75.06 square meters. Bounding by the NORTH, with party wall that separates it from apartment 2-A from the same floor; by the SOUTH, with party wall that separates it from apartment 2″ 43 Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 43 of 44 C from the same floor, by the EAST, with patio area in which the building enclave bounding with land property of the Electric Power Authority; and by the WEST, with common corridor that connects all apartments with elevators, stairs and other common facilities in the same floor. If any of the property described above, as a result of any act or omission of the defendants (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 18, Umted_States_Code, Section 982(b)(l) and Title 28, United States Code, Section 2461(c). TRUE BILL FOREPEK^ON Date: 0-7 (^ I / 7 ROSA EMILIA RODRtGUEZ-VELEZ United States Attorney (? ‘-Tjiriofhy R. Henwood First Assistant United States Attorney States Attorney al Division Marie Christine Amy Assistant United States Attorney 44

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The FBI News Review

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The Brooklyn Radio – bklynradio.com

1. New York and Brooklyn from Michael_Novakhov (111 sites): “Flatlands Brooklyn” – Google News: [BC-MCT-NEWS-BJT] | Nation – Bryan-College Station Eagle

[BC-MCT-NEWS-BJT] | Nation  Bryan-College Station Eagle

(TNS). Tribune News *Service*. News Budget for Saturday, July 27, 2019. ^<. updated at p.m. edt utc additional news stories appear on the ...>

“Flatlands Brooklyn” – Google News

1. New York and Brooklyn from Michael_Novakhov (111 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites): “Brooklyn NY” – Google News: John Fryer as BLACK NEEDLE NOISE Joins Up With For New Single “Seed Of Evil” – – mxdwn.com

John Fryer as BLACK NEEDLE NOISE Joins Up With For New Single “Seed Of Evil” –  mxdwn.com

The dark and sinister voice of Raymond Watts’ from is featured in track “Seed of Evil” by Black Needle Noise. If you can imagine an underground where music is …

“Brooklyn NY” – Google News

1. New York and Brooklyn from Michael_Novakhov (111 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites): “Brooklyn NY” – Google News: Cab Driver Shot in Head and Left for Dead in Brooklyn – Spectrum News NY1

Cab Driver Shot in Head and Left for Dead in Brooklyn  Spectrum News NY1

His body was left on the sidewalk and his vehicle was nowhere to be found.

“Brooklyn NY” – Google News

1. New York and Brooklyn from Michael_Novakhov (111 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites): Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Julia keleher arrest – Google Search google.com/search?q=Julia…

Julia keleher arrest – Google Search google.com/search?q=Julia…


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mikenov
on Saturday, July 27th, 2019 5:35pm

mikenov on Twitter

Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Investigate Douglas Leff and the entire San Juan branch of FBI! – 10:44 AM 7/27/2019 | Open Letter to Douglas Leff: Go hang your primitive propaganda noodles on your Jibaros’ ears, not mine! fbireform.com

Investigate Douglas Leff and the entire San Juan branch of FBI! – 10:44 AM 7/27/2019 | Open Letter to Douglas Leff: Go hang your primitive propaganda noodles on your Jibaros’ ears, not mine! fbireform.com


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mikenov
on Saturday, July 27th, 2019 2:54pm

mikenov on Twitter

Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Investigate Douglas Leff and the entire San Juan branch of FBI for their very likely complicity and/or roles in the Puerto Rico Coup D’Etat of July 2019 and the Governor Rossello Resignation – Google Search google.com/search?newwind…

Investigate Douglas Leff and the entire San Juan branch of FBI for their very likely complicity and/or roles in the Puerto Rico Coup D’Etat of July 2019 and the Governor Rossello Resignation – Google Search google.com/search?newwind…


Posted by

mikenov
on Saturday, July 27th, 2019 2:47pm

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Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Investigate Douglas Leff and the entire San Juan branch of FBI – Google Search google.com/search?newwind…

Investigate Douglas Leff and the entire San Juan branch of FBI – Google Search google.com/search?newwind…


Posted by

mikenov
on Saturday, July 27th, 2019 2:38pm

mikenov on Twitter

Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

1. New York and Brooklyn from Michael_Novakhov (111 sites): “Marine Park Brooklyn” – Google News: Top 5 Stories on Brownstoner This Week: Amazon in Sunset Park, Demolition in Downtown Brooklyn – Brownstoner

Top 5 Stories on Brownstoner This Week: Amazon in Sunset Park, Demolition in Downtown Brooklyn  Brownstoner

Popular stories this week include another skyscraper planned for Downtown Brooklyn, Amazon’s logistics facility in Sunset Park and a designer’s Cobble Hill …

“Marine Park Brooklyn” – Google News

1. New York and Brooklyn from Michael_Novakhov (111 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: M.N.: Would you believe that this lady, without any history of legal or financial problems, started to scheme to defraud the Government immediately on her arrival to Puerto Rico? I do not. The Puerto Ricans committed the crime against her. Investigate this in depth! #FBI #CIA pic.twitter.com/9zJLreBNAY

M.N.: Would you believe that this lady, without any history of legal or financial problems, started to scheme to defraud the Government immediately on her arrival to Puerto Rico? I do not. The Puerto Ricans committed the crime against her. Investigate this in depth!
#FBI #CIA pic.twitter.com/9zJLreBNAY



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mikenov
on Saturday, July 27th, 2019 12:00pm

mikenov on Twitter

Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): mikenov on Twitter: Investigate “Centro de Periodismo Investigativo” and their source of financing, and in their project aimed at Governor Rossello in particular. Who paid for it and for what purpose? Did Trump pay for it? trumpandtrumpism.com/2019/07/27/641…

Investigate “Centro de Periodismo Investigativo” and their source of financing, and in their project aimed at Governor Rossello in particular. Who paid for it and for what purpose? Did Trump pay for it? trumpandtrumpism.com/2019/07/27/641…


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mikenov
on Saturday, July 27th, 2019 10:44am

mikenov on Twitter

Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): Saved Stories – Michael Novakhov on Twitter: Hector Pesquera, the Homophobic Pig, Get Out Of Puerto Rico!!! #PuertoRicoNews

Hector Pesquera, the Homophobic Pig, Get Out Of Puerto Rico!!! #PuertoRicoNews


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mikenov
on Thursday, July 25th, 2019 6:59pm

Saved Stories – Michael Novakhov on Twitter

Michael Novakhov on Twitter from Michael_Novakhov (4 sites)

Michael Novakhov on Twitter from Michael_Novakhov (4 sites): Saved Stories – Michael Novakhov on Twitter: RT @nprpolitics: The committee’s report adds to the U.S. government’s now sizable reporting on Russia’s interference efforts in 2016. https…

The committee’s report adds to the U.S. government’s now sizable reporting on Russia’s interference efforts in 2016. n.pr/2YbgEE1


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Saved Stories – Michael Novakhov on Twitter

Michael Novakhov on Twitter from Michael_Novakhov (4 sites)