FII.ED IN THE FLoRENCE, r. NAKAKLTNT United States Attorney uN'rED:*[5iSftllifil,fo'ot #2286 JAN i g 2016 ,-=*,*-*oi,P--0, sue THOMAS J. BRA Dy #4472 Chief, Criminal Division LA*RENCELroNG oEmnJILnr<- SEA["ED #3040 ny oRDER OF THE couRT chief, Fraud and Financial crimes section Room 6- 100, PJKK Federal Building 300 Ala Moana Boulevard Honolulu, Hawaii 96850 Telephone: (808) 541-2850 Facsimile: (808) 541-2958 E-mai I : Larry.Tong@usdo-i. gov Attorneys for Plainti ff UNITED STATES OF AMEzuCA IN TI-IE LINITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII uNrrEDSrArESoFAMERrCA, ) cR.NdRl Plaintiff, 0 00 76 JM$ INDICTMENT ) vs. KAREN M. ) 6 ) ) ) KAPUA, Defendant. ) ) 18 U.S.C. g 666(aX1XA) (Theft From Organization Receiving Federal Funds) 18 U.S.C. $ 1es7 (Money Laundering) ) ) INDICTMENT COLJNT 1 The Grand Jury charges: On or about December 23,2A13, in the District of Hawaii, defendant KAREN M. KAPUA, being an agent of the County of Kauai, namely, a Lieutenant of the Kauai Police Depaftment, an organization which during calendar year 2013 received benefits in excess of'$ 1 0,000 in the form of grants from the federal goveffrment, including grants from the United States Drug Enforcement Administration, did knowingly embezzle, steal and intentionally misapply property having a value of more than $5,000, namely, approximately $25,000 in funds under the care, custody and control of the County of Kauai. In violation of Title 18, United States Code, section 666(aX l XA). COLNT 2 The Grand Jury further charges: On or about June I 3, 2014, in the District of Hawaii, defendant KAREN M. KAPUA, being an agent of the County of Kauai, namely, a Lieutenant of the Kauai Police Department, an organization which during calendar year 2014 received benefits in excess of $ 10,000 in the fonn of grants fi orn the federal government, including grants from the United States Drug Enforcement Administration, did knowingly embezzle, steal and intentionally misapply properly having 2 a value of \ I more than $5,000, namely, approximately $25,000 in funds under the care, custody and control of the County of Kauai. In violation of Title 18, United States Code, section 666(a)(lXA). COTINT 3 The Grand Jury furlher charges: On or about December 5,2014,inthe District of Hawaii, defendant KAREN M. KAPUA, being an agent of the County of Kauai, namely, a Lieutenant of the Kauai Police Department, an organization which during calendar year 2014 received benefits in excess of $10,000 in the form of grants from the federal governrnent, including grants from the United States Drug Enforcement Adrninistration, did knowingly embezzle, steal and intentionally misapply property having a value of more than $5,000, namely, approxirnately $25,000 in funds under the care, custody and control of the County of Kauai. In violation of Title 18, United States Code, section 666(a)(1XA). coLrNT 4 The Grand Jury further charges: On or about December 8,2A14, in the District of Hawaii and elsewhere, defendant KAREN M. KAPUA did knowingly engage and attempt to engage in a monetary transaction by, through and to a financial institution, affecting ir-rterstate 3 commerce, in criminally derived property of a value greater than $ 1 0,000, namely, said KAREN M. KAPUA initiated a wire transfer of $1 1,457.98 to pay ofT personal debts, knowing that such funds had been derived from a specified unlawful activity, namely, the offense charged in count 3 of this indictment involving the embezzlement and misapplication of $25,000 belonging to the County of Kauai. In violation of Title 18, United States Code, section 1957. Dated: Honolulu, Hawaii, January t3 2016, A TRUE BILL /s/ Foreperson FOREPERSON, GRAND JURY F'LORENCE T. NAKAKLNI THOMAS KtsRADY Chief, Criminal Divi LAWRENCE L. TONG Assistant U.S. Attorney United States v. Karen M. Kapua Cr. No. "Indicttnent" 4