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,J1\T1TED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
DEL RIO DIVISION
;) :3
INDICTMENT
v.
DRI6CRO5O2
THE GRAND JURY CHARGES:
FIRM A to provide services related to a number of large construction projects from 2006 through
2012.
3.
4.
One such contract awarded to FIRM A related to the Maverick County landfill
FIRM
A,
To secure this contract and to reward support for the awarding of this contract to
7.
for services related to the landfill project, gave money to CHAVEZ for the purpose of CHAVEZ
providing a portion of that money to COMMISSIONER A as a kickback for the landfill project.
8.
On at least four (4) occasions in 2012, CHAVEZ provided kickbacks in the form
In the one year period beginning on January 1, 2012, Maverick County, Texas
was a local government that received federal benefits in excess of $10,000 from the United
Between on or about August 20, 2014 and on or about September 22, 2014,
CHAVEZ devised to create, and did in fact falsify and forge, a professional services contract
between CHAVEZ/Chace Management and CONTRACTOR A/FIRM A to conceal from
authorities the kickbacks made in the form of cash payments to COMMISSIONER A in 2012.
12.
On or about May 4, 2015, a federal Grand Jury subpoena was issued to Chace
Management to provide "any and all records regarding any subcontracting or consulting work
done for, with, on behalf of, or in association with" FIRM A.
13.
In response to the federal Grand Jury subpoena, CHAVEZ provided the forged
and falsified professional services contract between Chace Management and FIRM A. CHAVEZ
represented in writing that such contract was a true record of the matters contained therein.
14.
On or about June 25, 2015, CHAVEZ made materially false oral representations
to two federal law enforcement agents concerning the legitimacy of the forged contract
[18 U.S.C.
666(a)(2)]
Paragraphs One through Fourteen above are realleged and incorporated by reference as if
fully set forth herein.
Between on or about May 1, 2012 and on or about June 30, 2012, in the Western District
of Texas, Defendant,
HECTOR CHAVEZ, SR.
did corruptly give, offer, and agree to give a thing of value to MAVERICK COUNTY
of transactions of Maverick County involving $5,000 or more, in violation of Title 18, United
States Code, Section 666(a)(2).
COUNT TWO
[18 U.S.C.
1519]
Paragraphs One through Fourteen above are realleged and incorporated by reference as if
fUlly set forth herein.
Between on or about August 1, 2014 and on or about June 30, 2015, in the Western
District of Texas, Defendant,
HECTOR CHAVEZ, SR.
did knowingly falsify a document with the intent to impede, obstruct, and influence the
COUNT THREE
[18 U.S.C. 1512(c)(2)]
Paragraphs One through Fourteen above are realleged and incorporated by reference as if
fully set forth herein.
Between on or about August
1,
Jury by forging a professional services contract and submitting such forged contract as true in
response to a federal Grand Jury subpoena, in violation of Title 18, United States Code, Section
15 12(c)(2).
ru
COUNT FOUR
[18 U.S.C.
1001]
Paragraphs One through Fourteen above are realleged and incorporated by reference as if
fully set forth herein.
On or about June 25, 2015, in the Western District of Texas, Defendant,
willfully
and knowingly make a materially false, fictitious, and fraudulent statement and
A TRUE BILL.
PiREPERSO7
RICHARD L. DURBIN, JR.
United States Attorney
By:
/1
J'ATIE GRIFF
Assistant United States Attorney
SEALED:
UNSEALED: XX
COUNTY: MAVERICK
LANGUAGE: ENGLISH
1: 18
U.S.C.
1001
666(a)(2)
18 U.S.C.
1512(c)(2)
1519
Falsification of
Obstruction of Justice;
1:
years of
supervised release, and a $100 special assessment; Counts 2 and 3: 0-20 years imprisonment, a
$250,000 fine,
years of supervised release, and a $100 special assessment; Count 4: 0-5 years
imprisonment, a $250,000 fine, 3 years of supervised release, and a $100 special assessment.