UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA

 

BILL OF INFORMATION FOR CONSPIRACY TO
COMMIT BRIBERY AND HONEST SERVICES WIRE FRAUD

UNITED STATES OF AMERICA CRIMINAL NOSECTION:    33?
IRA THOMAS VIOLATION: 18 U.S.C. 371

The United States Attorney charges that:

COUNT 1

CONSPIRACY TO COMMIT BRIBERY
AND HONEST SERVICES WIRE FRAUD

A. AT ALL TIMES MATERIAL HEREIN:

1. The Orleans Parish School Board consists of seven (7) board members.
Each member serves a four (4) year term.

2. The defendant, IRA THOMAS served as a member of the OPSB.
As an OPSB member, IRA THOMAS shared responsibility for awarding OPSB contracts to
private entities, including local businesses.

3. The OPSB was a local government entity within the State of Louisiana that

received federal assistance in excess of $10,000 annually from 2013 through 2015.

 

 

4. OPSB Employee was an employee of the OPSB.

5. Private citizen was associated with THOMAS as a consultant.
B. THE CONSPIRACY:

Beginning on or about September 2013, and continuing through January 2015, in the
Eastern District of Louisiana, and elsewhere, the defendant, IRA THOMAS, and others known
and unknown to the United States Attorney, did knowingly and willfully combine, conspire and
agree with each other: I

1. To corruptly accept and agree to accept anything of value from any person,
intending to be in?uenced and rewarded as an agent of an organization, government, or agency
in connection with any business, transaction, and series of transactions involving anything of
value of $5,000 or more of an organization, government, or agency that receives more than
$10,000 under a federal program during a one-year period, in violation of Title 18, United States
Code, Section and

2. To devise and intend to devise a scheme and arti?ce to defraud the Parish of
Orleans, and its citizens of their intangible right to receive the honest services of THOMAS and
OPSB Employee through bribes and payoffs, involving the use of interstate wire
transmissions, in violation of Title 18, United States Code, Sections 1343 and 1346.

C. OVERT ACTS:

On or about the following dates, in furtherance of and to conceal the conspiracy and
accomplish its purposes, the defendant, IRA THOMAS, and others, committed the following
overt acts, among others, in the Eastern District of Louisiana and elsewhere:

1) Beginning in or near September 2013, a cooperating witness was approached

by OPSB Employee who offered CW a janitorial services contract that would
soon be up for bid by the OPSB in exchange for a monetary payoff.

 

During the fall of 2013, the CW, THOMAS, OPSB Employee and at times
Private citizen met to discuss this contract. These conversations were recorded

by the CW.

Ultimately, it was decided that the CW would pay $5,000 to THOMAS in the form of
a ?campaign contribution? in exchange for and OPSB Employee 
assistance regarding the janitorial services contract.

In December 2013, the CW delivered $5,000 in cash to Private Citizen which was
video recorded. Private Citizen then delivered that cash payment to THOMAS.
THOMAS and Private Citizen agreed that Private Citizen would deposit the
money in Private Citizen bank account and withdraw from that account a portion
of the $5,000 to be retumed in cash to THOMAS, which Private Citizen did in fact

do.

During the fall of 2014, THOMAS and OPSB Employee discussed over
recorded telephone conversations how to alter the bid process so that the CW would
be given an imprOper advantage in bidding for the janitorial services contract, which
was valued over $5,000.

In completing this payoff and during recorded conversations between THOMAS and
OPSB Employee THOMAS caused electronic wire transmissions to travel
outside of the State of Louisiana, Eastern District of Louisiana, and across state lines
for the purpose of executing the scheme and arti?ce to defraud.

From in or near September 2013, and continuing through in or near January 2015,
THOMAS and OPSB Employee used their public offices and official capacities to
obtain a corrupt illicit payment from the CW bene?ting THOMAS and OPSB
Employee in exchange for their help in the bid?process.
All in violation of Title 18, United States Code, Section 371.
NOTICE OF FORFEITURE

The allegation of Count 1 of this Bill of Information is realleged. and incorporated

by reference as though set forth fully herein for the purpose of alleging forfeiture to the United

States of America pursuant to the provision of Title 18, United States Code, Sections 371,

666(a)( 1), and 1343, made applicable through Title 28, United States Code, Section 2461(c).

2.

As a result of the offense alleged in Count 1, defendant, IRA THOMAS, shall

forfeit to the United States pursuant to Title 18, United States Code, Sections 371, 666(a)(l), and

 

1343, made applicable through Title 28, United States Code, Section 2461(c), any and all
property, real or personal, which constitutes or is derived from proceeds traceable to violations of

Title 18, United States Code, Sections 371, 666(a)( 1), and 1343.

3. If any of the property subject to forfeiture, as a result of any act or 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 person;

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 subdivided without
dif?culty;

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 up to the value of the above forfeitable
property.

All in violation of Title 18, United States Code, Section made applicable

through Title 28, United States Code, Section 2461(c),

KENNETH ALLEN JR.
UNITED STATES ATTORNEY

em 

SEAN TOOMEY 
Assistant United States Attorney

New Orleans, Louisiana
March 6, 201 5