Академический Документы
Профессиональный Документы
Культура Документы
-v.- 09 Cr.
MIGUEL MARTINEZ,
Defendant.
- - - - - - - - - - - - - - - - - - - - x
COUNT ONE
bUdget.
Chapter 68, Section 2604(b) (3). The New York City Charter also
their official duties. See New York City Charter, Chapter 68,
Section 2604(b) (2). New York City law also requires Council
-2-
members of the Council have had broad discretion to designate the
organizations.
funding for the Arts Center. Since 2003, the City of New York
UCAN by the City of New York. During that time, the City of New
York has provided the majority of UCAN's funding and, largely due
for UCAN.
-3-
The Means And Methods Of The Conspiracy
Overview
$106,000 of the money for his personal benefit. Although the New
described below.
-4-
The False Council Expense Invoice Scheme
MARTINEZ knew, neither CC-1 nor the Greater Manhattan Group had
his Council office expense budget and sent them to the City of
personal benefit.
-5-
11. In an effort to conceal his fraudulent activity,
Reports.
sponsor for the Arts Center by the City of New York. Since that
time, the City of New York has provided the majority of the Arts
after-school programs.
$15,000 from the Arts Center's bank account to MARTINEZ for his
personal benefit.
-6-
The UCAN Scheme
15. During 2004 and 2005, the New York City Housing
in the Bronx.
-7-
18. From in or about August 2004 to in or about
Statutory Allegation
violate Title 18, United States Code, Sections 1341 and 1346.
-8-
to devise a scheme and artifice to defraud the public of
Postal Service, and took and received therefrom such matter and
Overt Acts
-9-
a. On or about October 12, 2004, in his capacity
approximately $4,000 from the Arts Center's bank account for his
personal benefit.
(Title 18, united States Code, Sections 1341, 1346, and 1349.)
COUNT TWO
(Mail Fraud)
-10-
attempting so to do, did place in a post office and authorized
personal benefit.
COUNT THREE
-11-
known and unknown to violate of Title 18, United States Code,
Section 1956.
Overt Acts
elsewhere:
-12-
b. On or about October 18, 2005, MARTINEZ wrote
FORFEITURE ALLEGATION
Section 981(a) (1) (C) and Title 28, United States Code, Section
diligence;
a third person;
-13-
(3) has been placed beyond the jurisdiction of the
court;
LEV L. DASSIN
Acting United States Attorney
-14 -