IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA

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v.
RUFUS SETH WILLIAMS

CRIMINAL NO. 17DATE FILED: March 21, 2017
VIOLATIONS:
18 U.S.C. § 1952 (Travel and Use of
Interstate Facilities to Promote and
Facilitate Bribery Contrary to
Pennsylvania Law - 10 counts)
18 U.S.C. § 1951 (Hobbs Act Extortion
- 2 counts)
18 U.S.C. §§ 1343 & 1346 (Honest
Services Wire Fraud - 5 counts)
18 U.S.C. § 1343 (Wire Fraud - 6 counts)
Notice of Forfeiture

INDICTMENT
THE GRAND JURY CHARGES THAT:
COUNTS ONE TO FIVE
(Travel and Use of Interstate Facilities to Promote
and Facilitate Bribery Contrary to Pennsylvania Law)
Introduction
1.

At all times relevant to Counts One to Five of this Indictment:
a.

Defendant RUFUS SETH WILLIAMS was the District Attorney

for the City and County of Philadelphia, Pennsylvania, the largest prosecutor’s office in
Pennsylvania. He was elected to his first four-year term on or about November 3, 2009, was
sworn into office on or about January 4, 2010, and was reelected on or about November 6, 2013.
In this capacity, defendant WILLIAMS received an annual salary of approximately $170,000.
Defendant WILLIAMS was the chief law enforcement officer for the City and County of

 Philadelphia and served approximately 1.5 million residents. Defendant WILLIAMS supervised
approximately 300 Assistant District Attorneys, in addition to numerous detectives and support
staff. As the District Attorney, defendant WILLIAMS was in a position to influence, and did
influence, actions taken by and on behalf of the District Attorney’s Office (the “DAO”) and other
City and County law enforcement personnel, including with respect to cases handled by the
DAO. From in or about 2005 to in or about 2008, defendant WILLIAMS served as Inspector
General of the City of Philadelphia. As Inspector General, defendant WILLIAMS was
responsible for the investigation of corruption, fraud, waste, abuse, and employee misconduct
among municipal workers and companies doing business with the City of Philadelphia.
b.

Business Owner #1 owned a business that sold prepaid telephone

cards. Defendant WILLIAMS first met Business Owner #1 in or about early 2010.
c.

Person #1 was the subject of a criminal case being prosecuted by

the DAO and was a friend of Business Owner #1.
d.

Person #2 was defendant WILLIAMS’s girlfriend.

e.

Police Official #1 was an official in the Philadelphia Police

Department (the “PPD”), whose responsibilities included supervising security matters at the
Philadelphia International Airport.
2.

As the District Attorney for the City and County of Philadelphia,

defendant WILLIAMS had an obligation to file Statements of Financial Interest (“SFI”) with the
City of Philadelphia reporting financial interests that he held during the previous calendar year,
according to the City of Philadelphia’s Code of Ethics. Defendant WILLIAMS was required to
disclose the name and address of any person (not including family members) who gave him gifts
during the prior calendar year that were worth $200 or more in the aggregate. For each gift,
2

 defendant WILLIAMS was required to disclose the name and address of the source, its amount
or value, and the circumstances of the gift. Gifts included anything of value, such as services,
loans, entertainment, meals and tickets to sporting events, including: (1) the value of any benefit
worth $200 or more received by virtue of a loan made upon terms that were commercially
unreasonable in the ordinary course of business; and (2) any transaction in which the amount of
money or property value received by the office holder (or a member of his immediate family)
exceeded the money or property value that was paid or exchanged by the office holder (or a
member of his immediate family). Defendant WILLIAMS also was required to report each loan
or debt over $5,000 (except for the mortgage on his principal residence) and any direct or
indirect source of income of $500 or more.
3.

As a public official of the Commonwealth of Pennsylvania, defendant

WILLIAMS also had an obligation to file an SFI with the Commonwealth of Pennsylvania,
according to Pennsylvania’s Public Official and Employee Ethics Act. For each source of gifts
having an aggregate value of $250 or more, defendant WILLIAMS was required to disclose the
name and address of the source; the circumstances, including a description, of each gift; and the
value of each gift. Defendant WILLIAMS’s Commonwealth disclosure requirements, however,
did not obligate him to disclose gifts from friends or family members when the circumstances
made it clear that the motivation for the action was a personal or family relationship. Further,
under his Commonwealth disclosure obligations, defendant WILLIAMS was required to disclose
the source and amount of each payment or reimbursement by the source for transportation,
lodging, or hospitality that he received in connection with his public position if the aggregate
amount of each such payment or reimbursement by the source exceeded $650 for the calendar
year. Under his Commonwealth disclosure obligations, defendant WILLIAMS also was required
3

 to report each loan or debt over $6,500 and any direct or indirect source of income of $1,300 or
more.
Defendant WILLIAMS’s Unlawful Arrangement with Business Owner #1
4.

From in or about July 2010 to in or about May 2015, defendant

WILLIAMS engaged in an arrangement with Business Owner #1 pursuant to which defendant
WILLIAMS would solicit, accept, and agree to accept a stream of concealed pecuniary benefits
(“benefits”) for himself and Person #2, such as travel, money, and other things of value, from
Business Owner #1 and, as consideration and in exchange for these benefits, defendant
WILLIAMS would reciprocate by performing and agreeing to perform official acts on behalf of
Business Owner #1 and by violating his legal duties as specific opportunities arose.
Defendant WILLIAMS’s and Person #2’s Acceptance
of Valuable Benefits from Business Owner #1
5.

From in or about July 2010 to in or about May 2015, defendant

WILLIAMS and Person #2 solicited, accepted, and agreed to accept the following valuable
benefits provided and arranged by Business Owner #1 on or about the dates listed below:
DATE

VALUABLE BENEFITS

January 2012

A Louis Vuitton tie for defendant WILLIAMS worth approximately
$205, and an iPad for defendant WILLIAMS worth approximately
$300.

February 1, 2012 to
February 5, 2012

Expenses for defendant WILLIAMS and Person #2 to travel to, and stay
at, an all-inclusive resort in Punta Cana, Dominican Republic (the
“Punta Cana Resort”) worth approximately $4,805, to include “royal
service” bracelets that permitted defendant WILLIAMS and Person #2
access to a private beach and personal butler services for their luxury
suite, round-trip airline tickets for defendant WILLIAMS and Person #2
worth approximately $1,576, and meals and amenities received during
such trip.

4

 DATE

VALUABLE BENEFITS

February 24, 2012
to April 24, 2012

A custom sofa for defendant WILLIAMS worth approximately $3,212.

August 22, 2012

A $502 dinner for defendant WILLIAMS and Person #2 at a restaurant
in Philadelphia, Pennsylvania.

March 15, 2013

A $7,000 check for defendant WILLIAMS.

October 2013

$2,000 cash for defendant WILLIAMS.

July 2010 to May
2015

A Burberry watch for defendant WILLIAMS, a Burberry purse for
Person #2, and meals and other valuable benefits for defendant
WILLIAMS and Person #2.

Defendant WILLIAMS’s Agreement to Perform Official Acts
in Favor of Business Owner #1
6.

From in or about July 2010 to in or about May 2015, as consideration and

in exchange for these benefits, defendant WILLIAMS agreed to use his official position to assist
Business Owner #1, to include the following:
DATE

USE OF OFFICIAL POSITION

Between in or about
December 2011 and in
or about September
2014

To assist Business Owner #1 in limiting security screening by law
enforcement authorities at the United States border when attempting
to return to the United States after foreign travel, to include: (a)
defendant WILLIAMS’s numerous contacts with Police Official #1
to exert pressure on and advise Police Official #1 in an attempt to
cause Police Official #1 to assist Business Owner #1 with such
encounters, and (b) defendant WILLIAMS’s repeated offers to write
an official letter, under defendant WILLIAMS’s authority as the
District Attorney, to another public official on behalf of Business
Owner #1 in an attempt to exert pressure on and advise such public
official to assist Business Owner #1 with such encounters.

Between in or about
February 2012 and in
or about September
2012

To assist Business Owner #1’s associate, Person #1, in connection
with a criminal case and matter under investigation by the DAO, to
include obtaining a more favorable plea offer for Person #1.

5

 Defendant WILLIAMS’s Failure to Timely Report Valuable Benefits
that Defendant WILLIAMS Accepted from Business Owner #1
7.

From in or about June 2013 to in or about April 2014, defendant

WILLIAMS signed, filed, and caused to be filed State and City SFIs for the reporting years 2012
and 2013 that intentionally omitted reference to valuable benefits received in those years by
defendant WILLIAMS from Business Owner #1, as described in paragraph 5 above, in order to
conceal defendant WILLIAMS’s unlawful arrangement with Business Owner #1.
8.

On or about July 29, 2016, and August 15, 2016, well after the federal law

enforcement investigation had become known to him, defendant WILLIAMS filed amended City
and State SFIs, reporting his receipt of a number of valuable benefits, including many of the
benefits that he received from Business Owner #1, as described in paragraph 5 above.
The Charges
9.

On or about the dates listed below, in the Eastern District of Pennsylvania,

and elsewhere, defendant
RUFUS SETH WILLIAMS
and Business Owner #1 knowingly and intentionally did travel and cause, procure, and induce
travel in interstate and foreign commerce and use and cause, procure, and induce the use of
facilities in interstate and foreign commerce, as set forth below, with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of unlawful activity – namely, bribery contrary to 18 Pa. C. S. § 4701 – and,
thereafter, performed and attempted to perform acts to promote, manage, establish, carry on, and
facilitate the promotion, management, establishment, and carrying on of the unlawful activity, as
set forth below:

6

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

ONE

On or about February 1, 2012,
defendant WILLIAMS and Person #2
traveled from Philadelphia to Punta
Cana, Dominican Republic.

(a) Between on or about February 1,
2012 and February 5, 2012, defendant
WILLIAMS caused, induced, and
procured Business Owner #1 to pay for
the significant expenses for defendant
WILLIAMS’s and Person #2’s travel
to, and stay at, the Punta Cana Resort,
including lodging in the “Royal Service
Presidential Suite” there.
(b) Between on or about February 1,
2012, and February 5, 2012, while in
Punta Cana, defendant WILLIAMS
was asked by Business Owner #1 for
official assistance in connection with a
criminal case and matter under
investigation by the DAO against
Person #1, and defendant WILLIAMS
agreed to provide such official
assistance.
(c) On or about February 8, 2012, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages 1
with Business Owner #1 regarding
defendant WILLIAMS providing
official assistance to Person #1 and
receiving further valuable benefits from
Business Owner #1:
(i) Defendant WILLIAMS received
a text message from Business Owner
#1, requesting defendant WILLIAMS’s
official assistance in connection with a
criminal case and matter under
investigation by the DAO against
Person #1, which stated: “the guy
pleaded guilty, he will take any

1

All of the text messages, letters, and other materials quoted in this indictment bear the
same spelling, punctuation, and grammar as found in the originals of these records.
7

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

punishment but he just doesn’t wanna
do jail! . . . If you can do anything for
him it would be very appreciative (as
long as you have no problem with it).”
(ii) Defendant WILLIAMS sent a
text message to Business Owner #1,
stating: “I will look into it.”
(iii) Very shortly after the text
message referenced as Subsequent Act
(c)(ii) of this Count, defendant
WILLIAMS sent Business Owner #1 a
text message, asking: “April?”,
referring to scheduling a second
anticipated trip to Punta Cana paid for
by Business Owner #1.
(iv) Defendant WILLIAMS sent a
text message to Business Owner #1,
stating: “I am merely a thankful beggar
and don’t want to overstep my bounds
in asking... but we will gladly go,”
referring to the second anticipated free
trip to Punta Cana paid for by Business
Owner #1.
(d) On or about February 24, 2012, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages
with Business Owner #1 regarding
defendant WILLIAMS receiving
further valuable benefits from Business
Owner #1:
(i) Defendant WILLIAMS received
a text message from Business Owner
#1, which included a photograph of a
sofa, asking: “Is that it?”
8

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

(ii) Defendant WILLIAMS sent a
text message to Business Owner #1,
replying: “That is the exact one...but
the special order color Chocolate.”
TWO

On or about February 24, 2012, in
Philadelphia, defendant WILLIAMS
caused, procured, and induced Business
Owner #1 to pay approximately $3,212
by use of a credit card transaction in
interstate commerce to purchase a sofa
for defendant WILLIAMS.

(a) On or about April 6, 2012,
defendant WILLIAMS exchanged the
following text messages with Business
Owner #1 regarding defendant
WILLIAMS’s receipt of the sofa from
Business Owner #1:
(i) Defendant WILLIAMS sent
Business Owner #1 a text message,
stating: “The sofa will be delivered
tomorrow . . . how would you like me
to re-pay you?”
(ii) Defendant WILLIAMS received
a text message from Business Owner
#1, replying: “Stop it! I don’t expect
anything in return when I gift my
friends :) .... Enjoy!”
(iii) Defendant WILLIAMS sent a
text message to Business Owner #1,
replying: “Well I sincerely appreciate
the gift . . . but I didn’t expect that, and
I don’t want you to think I mentioned it
so that you would get us a gift. That is
a wonderful gift and we are very, very
thankful.”
(b) On or about April 7, 2012,
defendant WILLIAMS caused the sofa
to be placed in his home in
Philadelphia.

9

 THREE

On or about August 22, 2012,
defendant WILLIAMS caused,
procured, and induced Business Owner
#1 to pay approximately $502 by use of
a credit card transaction in interstate
commerce for the expenses in
connection with dinner with defendant
WILLIAMS and Person #2 at a
restaurant in Philadelphia.

(a) On or about September 18, 2012, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages
with Business Owner #1 regarding
defendant WILLIAMS providing
official assistance to Person #1:
(i) Defendant WILLIAMS received
a text message from Business Owner
#1, stating: “Boss man, sorry to bother
you, remember a few months back I
asked you if you can help with a case
for a friend of my friends at [a
Philadelphia] night club! They been
asking me, and to be honest I was shy
to ask you!!! He has a court tomorrow
an he is looking at 1.5-3 years In Jail
plus 6 years probation! Is there
anything you can do for him.... he
regret it badly and he was begging me
if he can get 1 year or so, so he can be
in Philly prison not out of state.
Believe me I feel bad asking you!
Thank u Seth. This is his case info:
[Case Number]. Feb 17th suppression
hearing. [Person #1].”
(ii) Defendant WILLIAMS sent a
text message to Business Owner #1,
replying: “Was he already found
guilty?”
(iii) Defendant WILLIAMS
received a text message from Business
Owner #1, replying: “Yes he was! He
pleaded guilty! And they gave him till
tomorrow to take the deal which is 1.5
to 3 + 6 years probation.”
(iv) Defendant WILLIAMS sent a
text message to Business Owner #1,
replying: “If he pleaded guilty, and
from the sentence it seems that there is
a mandatory sentence. There is very

10

 little I can do the day before without it
looking extremely suspicious...”
(v) Defendant WILLIAMS received
a text message in response from
Business Owner #1, stating: “Sorry
Seth he just texted me, I’ll text you
what he just sent me: No not yet. My
trial date is tomorrow. [Assistant
District Attorney] offered me 1.5-3
years. I am trying to get a slightly
better offer. 11.5-23 months. I have a
very strong case for dismissial but if I
don’t get it I probably will get 5 yrs....”
and “So he didn’t plead guilty yet!”
(vi) Defendant WILLIAMS sent a
text message to Business Owner #1,
replying: “It seems like he has the
possibility of having it thrown out or
continued ... if it gets continued I will
then ask for the file and see what can be
done to make it a county sentence...”
(vii) Defendant WILLIAMS
received a text message from Business
Owner #1, replying: “Thank you Seth!
I appreciate it. Ill let him know. Sorry
again Seth.”
(viii) Defendant WILLIAMS sent a
text message to Business Owner #1,
replying: “In the future always give me
at least a week to help a friend ... I have
no problem looking into anything... I
can’t promise I will drastically change
anything once it has gotten to the trial
stage but I can always look into it[.]”
(ix) Defendant WILLIAMS
received a text message from Business
Owner #1, replying: “You know I was
hesitating to ask!!! I know you would
help me but I wasn’t sure if it’s
something that can bring suspicion, and
this is the last thing I want To do to a
11

 friend like you Seth! I care about you, I
want to see you the next mayor and the
next governor and maybe the next
president :)”
(b) On or about November 15, 2012, in
Philadelphia, defendant WILLIAMS
sent a text message to Business Owner
#1, stating in part: “If you are planning
more trips to Punta or Vegas feel free to
drag me along[.]”
FOUR

On or about March 12, 2013, in
Philadelphia, defendant WILLIAMS
used a facility in interstate commerce to
receive an email sent by a DAO
employee to defendant WILLIAMS,
and members of defendant
WILLIAMS’s security detail who were
responsible for transporting defendant
WILLIAMS, to schedule and arrange
transportation for defendant
WILLIAMS to attend a March 15, 2013
meeting among defendant WILLIAMS,
Business Owner #1, and Police Official
#1.

(a) On or about March 15, 2013, in
Philadelphia, defendant WILLIAMS
attended a meeting with Business
Owner #1 and Police Official #1 at
which defendant WILLIAMS asked
Police Official #1 to assist Business
Owner #1 in connection with security
screening by law enforcement
authorities at the United States border
when attempting to return to the United
States from foreign travel. Specifically,
WILLIAMS asked Police Official #1 to
assist Business Owner #1 in avoiding
secondary screening on the occasions
that Business Owner #1 reentered the
United States at the Philadelphia
International Airport upon returning
from overseas trips.
(b) On or about March 15, 2013,
immediately after their meeting with
Police Official #1 in Philadelphia,
defendant WILLIAMS accepted a
$7,000 check from Business Owner #1.
(c) On or about March 16, 2013, in
Philadelphia, defendant WILLIAMS
deposited into his account at a financial
institution the $7,000 check that he
accepted from Business Owner #1.

12

 FIVE

On or about February 24, 2014, in
Philadelphia, defendant WILLIAMS
sent a text message in interstate
commerce to Business Owner #1,
offering and agreeing to draft and send
an official letter in an effort to
influence the conduct of law
enforcement officials conducting
screenings of Business Owner #1 upon
Business Owner #1’s return flights
from abroad, including by stating,
“Give me the information of the
Homeland Security folks that were
running the investigation so I can send
a letter.”

From on or about February 24, 2014, to
on or about February 28, 2014, in
Philadelphia, defendant WILLIAMS
sent additional text messages to
Business Owner #1, offering and
agreeing to draft and send an official
letter in an effort to influence the
conduct of law enforcement officials
conducting screenings of Business
Owner #1 upon Business Owner #1’s
return flights from abroad, specifically
stating:
(a) “No, I want to send a letter to
whomever the people in [the public
official’s] office spoke with at
Homeland Security.”
(b) “I need the info...case number,
agent anything so I can write a letter to
the correct person of supervisory
authority.”
(c) “I want there to be a letter in your
file from the D.A. of Philadelphia.”
(d) “So get me whatever info you think
I need. Thanks.”
(e) “[Business Owner #1]…I still want
the info so I can send the letter.”
(f) “That plus the exact agency and
agent that conducted the original
investigation.”

In violation of Title 18, United States Code, Section 1952(a)(3) and Section 2.

13

 COUNT SIX
(Obstructing and Affecting Interstate and Foreign Commerce
by Extortion Under Color of Official Right)
1.

Paragraphs 1 to 8 of Counts One to Five of this Indictment are

incorporated here.
2.

At all times relevant to Count Six of this Indictment:
a.

Business Owner #1 traveled and paid for goods and services in

interstate and foreign commerce.
b.

Person #1 was charged with offenses that subjected Person #1 to a

potential term of imprisonment in a correctional facility run by the Pennsylvania Department of
Corrections and the Philadelphia Department of Prisons, which were government agencies
engaged, and who purchased goods and services, in interstate commerce.
3.

From in or about July 2010 to on or about May 5, 2015, in the Eastern

District of Pennsylvania, and elsewhere, defendant
RUFUS SETH WILLIAMS
did knowingly and willfully obstruct, delay, and affect interstate and foreign commerce, and
attempt so to do, by extortion under color of official right – that is, by agreeing to obtain and
obtaining money and other things of value from Business Owner #1, with consent, in exchange
for defendant WILLIAMS’s exercise of, and agreement to exercise, official authority and
influence as specific opportunities arose, including with respect to:
a.

Assisting Business Owner #1 in limiting security screening by law

enforcement authorities at the United States border when attempting to return to the United
States after foreign travel, to include: (i) defendant WILLIAMS’s numerous contacts with Police
Official #1 to exert pressure on and advise Police Official #1 in an attempt to cause Police
Official #1 to assist Business Owner #1 with such encounters, and (ii) defendant WILLIAMS’s
14

 repeated offers to write an official letter, under defendant WILLIAMS’s authority as the District
Attorney, to another public official on behalf of Business Owner #1 in an attempt to exert
pressure on and advise such public official to assist Business Owner #1 with such encounters;
and
b.

Assisting Business Owner #1’s associate, Person #1, in connection

with a criminal case and matter under investigation by the DAO, to include obtaining a more
favorable plea offer for Person #1.
In violation of Title 18, United States Code, Sections 1951(a) and (b)(2) and
Section 2.

15

 COUNTS SEVEN TO ELEVEN
(Travel and Use of Interstate Facilities to Promote
and Facilitate Bribery Contrary to Pennsylvania Law)
1.

Paragraphs 1(a) and (d) and 2 to 3 of Counts One to Five of this

Indictment are incorporated here.
Introduction
2.

At all times relevant to Counts Seven to Eleven of this Indictment:
a.

Business Owner #2 was an associate of defendant WILLIAMS

who, along with Business Owner #2’s relative, Business Owner #3, owned and operated bars in
Philadelphia and San Diego, California. On or about June 29, 2010, Business Owner #2 pled
guilty to corruptly endeavoring to impede the due administration of the federal tax code, and
Business Owner #2’s business entity pled guilty to two counts of federal tax evasion. On or
about November 16, 2010, Business Owner #2 was sentenced to 3 years’ probation and a
$30,000 fine, and the business entity was sentenced to 5 years’ probation and a $562,063.04 fine.
A federal judge in Philadelphia terminated Business Owner #2’s probation on or about April 9,
2013.
b.

The California Department of Alcoholic Beverage Control

(“CDABC”) was responsible for presiding over, and making determinations on, administrative
hearings related to the acquisition and retention of California liquor licenses. On or about June
6, 2013, the CDABC filed an Accusation under the Alcoholic Beverage Control Act and State
Constitution (the “Accusation”) seeking suspension or revocation of the liquor license of a
business entity of which Business Owner #2 was President, Secretary, Director and a corporate
stockholder. The Accusation alleged that Business Owner #2’s federal tax conviction was

16

 grounds for suspension or revocation of the liquor license because it was for “a crime, under the
circumstances, involving moral turpitude.”
c.
3.

Person #3 was an associate of Business Owner #2.

Pursuant to a Philadelphia city ordinance 21-2000, et seq., police accident

reports were confidential and not available to the public, except as provided under
Commonwealth of Pennsylvania law. Police accident reports were available to persons involved
in the accident, their attorney or insurer, the Federal Government, and Commonwealth agencies.
See 75 Pa. C.S. § 3751(b)(1); see also Section 1 of the City of Philadelphia Department of
Records Police Accident Report Regulation (hereinafter “Section 1”) at Section 1(1). Persons
legally eligible to receive police reports were required to fill out an application to the City of
Philadelphia Department of Records, submit an affidavit swearing that they were eligible,
present valid photo identification or other adequate proof of identity, and pay a $25 fee. Section
1(2). Regulations governing the City of Philadelphia Department of Records, which set forth the
procedure for obtaining police reports, provided that police accident reports should not be made
available from the Department of Records in any manner except as provided in this Regulation.
Defendant WILLIAMS’s Unlawful Arrangement with Business Owner #2
4.

From in or about March 2012 to in or about July 2015, defendant

WILLIAMS engaged in an arrangement with Business Owner #2 pursuant to which defendant
WILLIAMS would solicit, accept, and agree to accept a stream of concealed pecuniary benefits
for himself, his family members, and Person #2, such as airline tickets, money, an automobile,
and other things of value, from Business Owner #2 and, as consideration and in exchange for
these benefits, defendant WILLIAMS would reciprocate by performing and agreeing to perform

17

 official acts on behalf of Business Owner #2 and by violating WILLIAMS’s legal duties as
specific opportunities arose.
Defendant WILLIAMS’s Acceptance of Valuable Benefits from Business Owner #2
5.

From in or about March 2012 to in or about July 2015, defendant

WILLIAMS solicited, accepted, and agreed to accept the following valuable benefits provided
and arranged by Business Owner #2 on or about the dates listed below:
DATE

VALUABLE BENEFITS

March 2012

Round-trip airline tickets for defendant WILLIAMS and two family
members to Florida, worth approximately $856.80.

October 2012

Round-trip airline tickets to, and lodging for defendant WILLIAMS and
Person #2 in, San Diego, California, worth approximately $2,000.

March 2013

Round-trip airline tickets for defendant WILLIAMS and two family
members to Florida, worth approximately $1,200.

June 2013

A pre-owned 1997 Jaguar XK8 convertible, worth approximately
$4,160, and the value of insurance premiums paid by Business Owner
#2 of approximately $380 for a policy on that vehicle from in or about
June 2013 to in or about November 2013.

December 2013

Round-trip airline tickets to, and lodging and hospitality for defendant
WILLIAMS and Person #2 in, Las Vegas, Nevada, worth approximately
$2,000.

August 2014

Round-trip airline tickets to, and lodging for defendant WILLIAMS and
two family members in, San Diego, California, worth approximately
$2,000.

March 2015

Round-trip airline tickets for defendant WILLIAMS and two family
members to Florida, worth approximately $1,048.72.

March 2015 – July
2015

Cash payments to defendant WILLIAMS totaling at least approximately
$900.

18

 Defendant WILLIAMS’s Agreement to Perform Official Acts
in Favor of Business Owner #2
6.

From in or about November 2012 to in or about July 2015, as

consideration and in exchange for these benefits, defendant WILLIAMS agreed to use his
official position to assist Business Owner #2, to include the following:
DATE

USE OF OFFICIAL POSITION

November 2012

To appoint Business Owner #2 as Special Advisor to the DAO, to
include: (a) defendant WILLIAMS issuing an official DAO badge
and leather badge holder for Business Owner #2; (b) defendant
WILLIAMS issuing a letter in his capacity as the District Attorney,
issued in or about May 2013 and back-dated to November 30, 2012,
appointing Business Owner #2 to, and outlining official
responsibilities for, the position of Special Advisor to the DAO; and
(c) defendant WILLIAMS assigning, and agreeing to assign, certain
matters to Business Owner #2 in Business Owner #2’s capacity as
Special Advisor to the DAO.

June 2, 2014

To issue a letter in his capacity as the District Attorney to the
CDABC to influence a then-pending proceeding before the CDABC
to determine whether or not Business Owner #2 could continue as an
officer and corporate stockholder of a business entity that held a
California liquor license.

July 2015

To obtain an official police accident report for, and provide it to,
Business Owner #2 related to a car accident involving Person #3.
Defendant WILLIAMS’s Failure to Timely Report Valuable Benefits
that Defendant WILLIAMS Accepted from Business Owner #2
7.

From in or about March 2013 to in or about May 2016, defendant

WILLIAMS signed, filed, and caused to be filed State and City SFIs for the reporting years 2012
through 2015 that intentionally omitted reference to valuable benefits received in those years by
defendant WILLIAMS from Business Owner #2, as described in paragraph 5 above, in order to
conceal defendant WILLIAMS’s unlawful arrangement with Business Owner #2.

19

 8.

On or about July 29, 2016, and on or about August 15, 2016, well after the

federal law enforcement investigation had become known to him, defendant WILLIAMS filed
amended City and State SFIs, reporting his receipt of a number of valuable benefits, including
many of the benefits that he received from Business Owner #2, as described in paragraph 5
above. On or about January 17, 2017, defendant WILLIAMS entered into a settlement
agreement with the City’s Board of Ethics in which defendant WILLIAMS represented and
warranted that, except for his receipt of additional valuable benefits set forth in that agreement,
the information in his amended City SFIs was accurate and complete in all material respects.
However, defendant WILLIAMS’s amended City and State SFIs and his settlement agreement
with the City’s Board of Ethics still failed to report defendant WILLIAMS’s receipt of the preowned 1997 Jaguar XK8 convertible and payment of insurance premiums from Business Owner
#2.
The Charges
9.

On or about the dates listed below, in the Eastern District of Pennsylvania,

and elsewhere, defendant
RUFUS SETH WILLIAMS
and Business Owner #2 knowingly and intentionally did travel and cause, procure, and induce
travel in interstate and foreign commerce and use and cause, procure, and induce the use of
facilities in interstate commerce, as set forth below, with the intent to promote, manage,
establish, carry on, and facilitate the promotion, management, establishment, and carrying on of
unlawful activity – namely, bribery contrary to 18 Pa. C. S. § 4701 – and, thereafter, performed
and attempted to perform acts to promote, manage, establish, carry on, and facilitate the

20

 promotion, management, establishment, and carrying on of the unlawful activity, as set forth
below:
COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

SEVEN

On or about October 9, 2012, defendant
WILLIAMS and Person #2 traveled
from Philadelphia to San Diego,
California using airline tickets provided
by Business Owner #2.

(a) In or about November 2012, in
Philadelphia, defendant WILLIAMS
appointed Business Owner #2 as
Special Advisor to the DAO.
(b) On or about November 6, 2012, at
approximately 2:11 p.m., in
Philadelphia, defendant WILLIAMS
sent an email to the Executive Director
of his Political Action Committee,
forwarding an invoice from a vendor to
pay for an official DAO badge and
leather badge holder that defendant
WILLIAMS obtained for Business
Owner #2, stating: “Attached please
find an invoice for the badge and wallet
[Business Owner #2] wanted. He paid
for my trip in 2009 to visit the D.A. in
San Diego and D.A. of San
Francisco. He has given $$$$, will
max and will host events at his bars.”
(c) On or about November 6, 2012, at
approximately 2:30 p.m., in
Philadelphia, defendant WILLIAMS
received an email from the Executive
Director of his Political Action
Committee in response to defendant
WILLIAMS’s email referenced in
Subsequent Act (b) of this Count,
stating: “ok.”
(d) On or about November 20, 2012, in
Philadelphia, defendant WILLIAMS
sent Business Owner #2 a text message,
asking: “Have you flashed your badge
lately?”, referring to the official DAO

21

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

badge that defendant WILLIAMS
obtained and provided to Business
Owner #2.
(e) On or about November 29, 2012, in
Rockledge, Pennsylvania, defendant
WILLIAMS caused the Executive
Director of his Political Action
Committee to use a credit card to pay a
vendor approximately $141.63 for the
official DAO badge and leather badge
holder for Business Owner #2.
(f) On or about February 5, 2013,
defendant WILLIAMS exchanged the
following text messages with Business
Owner #2 regarding defendant
WILLIAMS receiving further valuable
benefits from Business Owner #2:
(i) Defendant WILLIAMS sent a
text message to Business Owner #2,
stating: “It’s time again for me to plan
for [defendant WILLIAMS’s family
members’] spring break. I have lined up
a friend’s home in Key West again. Can
you help me with the flight
arrangements again. I looked online and
saw the tickets were around $230 a
piece round trip for the three of us. You
may have points you are willing to
trade or I could pay u back over 2
months. Thanks.”
(ii) Defendant WILLIAMS received
a text message from Business Owner
#2, stating: “yes I will check today.”
(iii) Defendant WILLIAMS sent a
text message to Business Owner #2,
22

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

stating: “And not to be greedy but
maybe we can all go to your place in
San Diego before you sell it...maybe
August before they start school.”
(iv) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “ok. not greedy at
all.”
(v) Defendant WILLIAMS sent a
text message to Business Owner #2,
stating: “I case u need the info…” and
listing dates of birth for defendant
WILLIAMS and his family members.
(g) On or about February 7, 2013, in
Philadelphia, defendant WILLIAMS
caused, procured, and induced Business
Owner #2 to book Air Canada airline
tickets for defendant WILLIAMS and
his family members for travel on or
about March 20, 2013 from
Philadelphia, through Charlotte, North
Carolina, to Fort Lauderdale, Florida.
EIGHT

On or about March 20, 2013, defendant
WILLIAMS and two family members
traveled from Philadelphia, through
Charlotte, North Carolina, to Fort
Lauderdale, Florida using airline tickets
provided by Business Owner #2.

(a) On or about April 14, 2013,
defendant WILLIAMS sent a text
message to Business Owner #2, stating:
“This is the mechanic that has the
Jaguar,” referring to the pre-owned
1997 Jaguar XK8 convertible that
defendant WILLIAMS was receiving
from Business Owner #2, and providing
Business Owner #2 with contact
information for a mechanic for the
Jaguar.
(b) On or about May 7, 2013, in
Philadelphia, defendant WILLIAMS

23

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

received a text message from Business
Owner #2, stating: “sorry to bother, can
I get a letter from your office stating
that I am and have been since you
appointed me your special advisor.
Thanks.”
(c) On or about May 9, 2013, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages
with Business Owner #2 regarding
defendant WILLIAMS issuing a letter
under his authority as District Attorney
pertaining to the appointment and
responsibilities of Business Owner #2
as Special Advisor to the DAO and
defendant WILLIAMS receiving
further valuable benefits from Business
Owner #2:
(i) Defendant WILLIAMS received
a text message from Business Owner
#2, stating: “what’s your office phone
number that goes to your secretary?!”
(ii) Defendant WILLIAMS sent
Business Owner #2 a text message
containing the telephone number for
defendant WILLIAMS’s secretary at
the DAO.
(iii) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “thanks. I emailed a
draft, see if your ok with it and let me
know. also, I am heading back to sd
after the 21st if you and [Person #2]
want to do vegas in the beginning of
June, let me know.”

24

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

(iv) Defendant WILLIAMS sent
Business Owner #1 a text message,
replying: “1. I will write the letter
tomorrow. 2. Ok, thanks!”
(d) On or about May 10, 2013, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages
with Business Owner #2 regarding
defendant WILLIAMS issuing a letter
under his authority as District Attorney
pertaining to the appointment and
responsibilities of Business Owner #2
as Special Advisor to the DAO and
defendant WILLIAMS receiving
further valuable benefits from Business
Owner #2:
(i) Defendant WILLIAMS sent a
text message to Business Owner #2,
stating: “This is the mechanic that has
the Jaguar,” referring again to the preowned 1997 Jaguar XK8 convertible
that defendant WILLIAMS was
receiving from Business Owner #2, and
providing Business Owner #2 with
contact information for a mechanic for
the Jaguar.
(ii) Defendant WILLIAMS sent
Business Owner #2 a text message,
asking: “Did you get the letter,”
referring to the Special Advisor
appointment letter.
(iii) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “yes. thank you very
much. is it ok if I change the date to
November 30, 2012?”

25

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

(iv) Defendant WILLIAMS sent
Business Owner #2 a text message,
replying: “Sure.”
(v) Defendant WILLIAMS sent
Business Owner #2 a text message,
asking: “Does your mechanic know the
problems with the jag?”
(vi) Defendant WILLIAMS sent
Business Owner #2 a text message,
asking: “What type of assignments
would you like as Special Advisor.”
(e) On or about May 10, 2013, in
Philadelphia, defendant WILLIAMS
provided Business Owner #2 with a
letter on official DAO letterhead,
backdated to November 30, 2012,
bearing defendant WILLIAMS’s
signature as “District Attorney,”
stating, among other things: “It is my
pleasure to appoint you as a Special
Advisor to the Philadelphia District
Attorney’s office”; “This appointment
is effective immediately”; “This
position plays an important role within
my office and for the citizens of the
City of Philadelphia”; and “I know you
will take this responsibility seriously
and I expect that you will make the
time available to participate as needed.”
(f) In or about June 2013, in
Philadelphia, defendant WILLIAMS
accepted from Business Owner #2 a
pre-owned 1997 Jaguar XK8
convertible, whose insurance Business
Owner #2 paid up to on or about
November 19, 2013.
26

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

(g) On or about August 24, 2013,
defendant WILLIAMS exchanged the
following text messages with Business
Owner #2 regarding defendant
WILLIAMS and Person #2 receiving
further valuable benefits from Business
Owner #2:
(i) Defendant WILLIAMS received
a text message from Business Owner
#2, asking: “Vegas November 12?,”
referring to Business Owner #2’s offer
to provide defendant WILLIAMS and
Person #2 with airline tickets to Las
Vegas, Nevada.
(ii) Defendant WILLIAMS sent a
text message to Business Owner #2,
stating: “I am 95% positive. Let me
check Monday. November 12-?”
(iii) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “Tuesday is 12 I
think but we can do 11 I guess for 3
days.”
(iv) Defendant WILLIAMS sent a
text message to Business Owner #2,
stating: “12 is perfect.”
(h) On or about September 10, 2013, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages
with Business Owner #2 regarding
defendant WILLIAMS receiving
further valuable benefits from Business
Owner #2:
27

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

(i) Defendant WILLIAMS sent a
text message to Business Owner #2,
stating “If it is still possible for [an
associate of Business Owner
#2’s]...early Thursday November 7
until the evening of Sunday November
10th works best for me to go to Vegas.”
(ii) Defendant Williams received a
text message from Business Owner #2,
stating “ok I will check with him and
make reservations and let [Business
Owner #3] know.”
(i) On or about October 31, 2013,
defendant WILLIAMS sent a text
message to Business Owner #2, stating:
“We still have December 2nd through
December 6th blocked,” referring to the
anticipated Las Vegas trip.
(j) On or about November 8, 2013,
defendant WILLIAMS received a text
message from Business Owner #2,
asking: “is December 3-5 still good for
vegas for u guys?”
(k) On or about November 14, 2013,
defendant WILLIAMS exchanged the
following text messages with Business
Owner #2:
(i) Defendant WILLIAMS sent
Business Owner #2 a text message,
asking: “My secretary asked me about
the flight info going to Vegas with the
[Business Owner #2’s] family....have
you decided yet?”

28

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

(ii) Defendant WILLIAMS received
a text message from Business Owner
#2, stating: “I just emailed it to you.”
(l) On or about November 26, 2013, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages
with Business Owner #2:
(i) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “Dude....I never want to feel
like a drag on your wallet...but we are
ALWAYS ready for an adventure.”
(ii) Defendant WILLIAMS and
Business Owner #2 exchanged text
messages about Business Owner #2
arranging a trip for defendant
WILLIAMS and Person #2 to Las
Vegas and, in the midst of that
exchange, defendant WILLIAMS sent a
text message to Business Owner #2,
stating “I would love to take [defendant
WILLIAMS’s family members] to see
your house and zoo in San Diego
before you sell your house.”
(iii) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “ok. that sounds
good.”
NINE

On or about December 3, 2013,
defendant WILLIAMS and Person #2
traveled from Philadelphia to Las
Vegas, Nevada using airline tickets
provided by Business Owner #2.

29

(a) From in or about January 2014 to at
least in or about December 2015, in
Philadelphia, defendant WILLIAMS
and Person #2 continued to use the preowned Jaguar provided by Business
Owner #2.

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

(b) On or about May 1, 2014,
defendant WILLIAMS sent a text
message to Business Owner #2, stating:
“You can breathe easy now…I finally
transferred title of the JAG today!”
(c) On or about May 3, 2014,
defendant WILLIAMS sent a text
message to Business Owner #2, stating:
“We got more stuff done to the Jag, and
drive it to DC for my Army Reserve
Unit…it did very well on the highway.
Thanks again!”
(d) On or about May 30, 2014, in
Philadelphia, defendant WILLIAMS
received a text message from Business
Owner #2 referring to a letter from
defendant WILLIAMS to the CDABC,
asking: “hey seth, can you get that letter
to me by Monday evening?”
(e) On or about June 2, 2014, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages
with Business Owner #2 regarding
defendant WILLIAMS issuing a letter
under his authority as District Attorney
concerning a then-pending proceeding
before the CDABC:
(i) Defendant WILLIAMS received
a text message from Business Owner
#2, asking: “hey seth, can you try to get
that letter done today ? thanks.”
(ii) Defendant WILLIAMS sent
Business Owner #2 a text message,
asking: “Are you near a computer? Can
you resend it to [defendant
30

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

WILLIAMS’s personal email
address].”
(iii) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “sent.”
(iv) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “if your bringing
[your family members] out to sd this
summer, let me know when so we can
make arrangements.”
(v) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “I scanned the letter and
emailed it to you.”
(vi) Defendant WILLIAMS
received text messages from Business
Owner #2, stating: “thank you,” and “I
will let you know when I get it.”
(f) On or about June 2, 2014, in
Philadelphia, defendant WILLIAMS
gave Business Owner #2 a letter on
official DAO letterhead, bearing
defendant WILLIAMS’s signature as
“District Attorney,” and addressed to a
hearing examiner at the CDABC,
stating, among other things:

31

•

“I have personally known and
worked with [Business Owner #2]
for almost a decade and wanted to
write this letter for his hearing”;

•

“[Business Owner #2] served on my
transition team and currently serves
as one of my Special Advisors”;

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

•

“I am fully aware of [Business
Owner #2’s] conviction in 2010 and
do not believe this to be a crime of
moral turpitude and there was no
financial loss to the government nor
any individual citizen”;

•

“I Understand this hearing is to
determine whether or not [Business
Owner #2] can continue as an
officer and stock holder of
[Business Owner #2’s California
corporate entity], a California
corporation which holds a liquor
license”;

•

“The Commonwealth of
Pennsylvania has ruled that
[Business Owner #2] may rejoin
[Business Owner #2’s] company in
our state, where he also holds a
liquor license”;

•

“I believe that both of our states
have similar laws about moral
turpitude”;

•

“You may find it persuasive that
after an investigation, the
Pennsylvania Liquor Control Board
ruled in [Business Owner #2’s]
favor, and restored [Business
Owner #2] to all of the rights and
privileges that [Business Owner #2]
enjoyed previously.”

(g) On or about June 3, 2014,
defendant WILLIAMS sent Business
Owner #2 a text message, stating:
“Camp ends August 8th for my [family
32

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

members]. So August 9th -16 would be
the best times for us to visit San
Diego.”
TEN

On or about August 9, 2014, defendant
WILLIAMS and two of his family
members traveled from Philadelphia to
San Diego, California, using airline
tickets provided by Business Owner #2.

(a) On or about August 16, 2014,
defendant WILLIAMS exchanged the
following text messages with Business
Owner #2 regarding defendant
WILLIAMS’ August 9, 2014, San
Diego trip and the prospect of receiving
further valuable benefits from Business
Owner #2:
(i) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “Thanks for everything! We
had a great time!”
(ii) Defendant WILLIAMS received
a text message from Business Owner
#2, stating: “your welcome. anytime. is
was a pleasure hanging out with you
guys.”
(iii) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “We can’t thank you and
[Business Owner #3] enough for your
generosity!!!”
(iv) Defendant WILLIAMS
received text messages from Business
Owner #2, stating: “that’s what friends
do” and “Anytime you want to visit is
ok with us.”
(v) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “We will take you up on that.”
(b) On or about November 1, 2014,
defendant WILLIAMS exchanged the

33

 COUNT

TRAVEL OR USE OF FACILITY
IN INTERSTATE AND FOREIGN
COMMERCE

SUBSEQUENT ACTS

following text messages with Business
Owner #2 regarding defendant
WILLIAMS receiving further valuable
benefits from Business Owner #2:
(i) Defendant WILLIAMS sent
Business Owner #2 a text message,
asking: “Can we use some of your
points again this spring so I can fly
[defendant WILLIAMS’s family
members and Person #2] and I to Key
West! We can stay at my friends house
for free...March 22-29? I would greatly
appreciate it.”
(ii) Defendant WILLIAMS received
text messages from Business Owner #2,
stating: “yes.”
(c) On or about November 12, 2014,
defendant WILLIAMS exchanged the
following text messages with Business
Owner #2:
(i) Defendant WILLIAMS sent
Business Owner #2 a text message,
asking: “What does your badge say.”
(ii) Defendant WILLIAMS received
a text message from Business Owner
#2, , which included a photograph of a
badge, replying: “district attorney
special advisor.”
(iii) Defendant WILLIAMS sent
Business Owner #2 a text message,
replying: “Fancy.”

34

 ELEVEN

On or about March 22, 2015, defendant
WILLIAMS and two of his family
members traveled from Philadelphia,
through Atlantic City, New Jersey, to
Fort Lauderdale, Florida, using airline
tickets provided by Business Owner #2.

(a) On or about March 30, 2015, in
Philadelphia, defendant WILLIAMS
exchanged the following text messages
with Business Owner #2, addressing
defendant WILLIAMS’s personal
financial problems and arranging to
meet with and receive a cash payment
from Business Owner #2.
(i) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “I came home and gave [Person
#2] a chck for $748...the car plus $130
for clothes [Person #2] got [for
defendant WILLIAMS’s family
member].”
(ii) Defendant WILLIAMS received
from Business Owner #2 a text
message, asking: “so what time will
you drive by my house.” and
(iii) Defendant WILLIAMS
received from Business Owner #2 a text
message, stating: “I only need a
minute,” and asking defendant
WILLIAMS to bring with him a copy
of the “car rental contract” from
defendant WILLIAMS’s recent Florida
vacation.
(iv) Defendant WILLIAMS sent
Business Owner #2 a text message,
asking: “What is your exact address I
will type it into my GPS and let you
know.”
(v) Defendant WILLIAMS received
from Business Owner #2 a text message
listing Business Owner #2’s
Philadelphia address.
(vi) Defendant WILLIAMS sent
Business Owner #2 text messages,
stating: “14 minutes” and “Be there in 2
minutes so come down.”

35

 (vii) Defendant WILLIAMS
received from Business Owner #2 a text
message, stating: “ok.”
(viii) Defendant WILLIAMS sent
Business Owner #2 text messages,
stating: “Thank you very much for
helping,” and “I’m still actually in
shock,” and “That helped out me right
over if she cashes her check.”
(ix) Defendant WILLIAMS
received from Business Owner #2 a text
message, stating: “good.”
(b) On or about March 30, 2015, in
Philadelphia, defendant WILLIAMS
accepted a cash payment of at least
approximately $500 from Business
Owner #2.
(c) On or about March 30, 2015,
defendant WILLIAMS deposited $500
in cash into his personal account at a
financial institution in Philadelphia.
(d) On or about June 1, 2015,
defendant WILLIAMS exchanged the
following text messages with Business
Owner #2, addressing defendant
WILLIAMS’s personal financial
problems and arranging to meet with
and receive a cash payment from
Business Owner #2:
(i) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “I need your help regarding a
personal matter...will you be able to
meet me briefly tomorrow ?”
(ii) Defendant WILLIAMS received
from Business Owner #2 a text
message, stating: “what time were you
36

 thinking or I can meet you today or
tonight at anytime. if you need me to, I
can come to you.”
(iii) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “I may call you from a random
pay phone tonight.”
(iv) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “My problems stem from
[Person #2] not helping with utility bills
but enjoying heat, electricity, cable,
water and food.”
(e) In or about early June 2015,
following the text messages referenced
in Subsequent Acts (d) of this Count, in
Philadelphia, defendant WILLIAMS
accepted a cash payment of
approximately $400 from Business
Owner #2.
(f) On or about July 8, 2015, defendant
WILLIAMS sent Business Owner #2 a
text message, stating: “I got the police
report today.”
(g) On or about July 25, 2015,
defendant WILLIAMS exchanged the
following text messages with Business
Owner #2:
(i) Defendant WILLIAMS received
a text message from Business Owner
#2, asking: “did you get the police
report for [Person #3]?”
(ii) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “Yes I have it.”

37

 (iii) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “ok. if [defendant
WILLIAMS’s secretary] has a copy can
I call her on Monday and have her
email it to me.”
(iv) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “The truth is I could get into
serious trouble if I called that company
and told them to pay [Person #3] $400.”
(v) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “They would claim the fact that
I even suggested them to take care of
the damaged they caused would be me
using my position to threaten them.”
(vi) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “yea. Don’t send the
letter just get the police report if you
could.”
(vii) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “I wasn’t going to
give him the letter I was just going to
talk to [Person #3] and tell [Person #3]
it’s not worth it. but the police report
isn’t a problem is it?”
(viii) Defendant WILLIAMS
received a text message from Business
Owner #2, stating: “I think [Person #3]
needs that for his insurance company.”
(ix) Defendant WILLIAMS sent
Business Owner #2 a text message,
stating: “The police report is fine.”
(x) Defendant WILLIAMS received
a text message from Business Owner
38

 #2, stating: “ok yea. just email me that.
I will take care of the rest.”
(xi) Defendant WILLIAMS sent
Business Owner #2 text messages
regarding Person #3 and defendant
WILLIAMS’s debt to Business Owner
#2, stating:
•

“I wish I could help more. I really
like [Person #3] and [Person #3’s
associate]”;

•

“As you know. I hate to let people
down”;

•

“Can I be a greeter or celebrity
bartender to work off my debt to
you and [Business Owner #3]?
LOL”; and

•

“No. I was serious about just doing
whatever I can to help you guys!”

In violation of Title 18, United States Code, Section 1952(a)(3) and Section 2.

39

 COUNT TWELVE
(Obstructing and Affecting Interstate and Foreign Commerce
by Extortion Under Color of Official Right)
1.

Paragraphs 1 to 8 of Counts Seven to Eleven of this Indictment are

incorporated here.
2.

At all times relevant to Count Twelve of this Indictment:
a.

Business Owner #2 traveled and paid for goods and services in

interstate and foreign commerce. Business Owner #2 also owned and operated bars in
Philadelphia, Pennsylvania and San Diego, California, which were businesses engaged, and who
purchased goods and services, in interstate commerce.
3.

From in or about July 2010 to in or about July 2015, in the Eastern District

of Pennsylvania, and elsewhere, defendant
RUFUS SETH WILLIAMS
did knowingly and willfully obstruct, delay, and affect interstate commerce, and attempt so to do,
by extortion under color of official right – that is, by agreeing to obtain and obtaining money and
other things of value from Business Owner #2, with consent, in exchange for defendant
WILLIAMS’s exercise of, and agreement to exercise, official authority and influence as specific
opportunities arose, including with respect to:
a.

Appointing Business Owner #2 as Special Advisor to the DAO, to

include: (a) defendant WILLIAMS issuing an official DAO badge and leather badge holder for
Business Owner #2; (b) defendant WILLIAMS issuing a letter his capacity as the District
Attorney, issued in or about May 2013 and back-dated to November 30, 2012, appointing
Business Owner #2 to, and outlining official responsibilities for, the position of Special Advisor
to the DAO; and (c) defendant WILLIAMS assigning, and agreeing to assign, certain matters to
Business Owner #2 in Business Owner #2’s capacity as Special Advisor to the DAO;
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 b.

Issuing a letter in his capacity as the District Attorney to the

CDABC to influence a then-pending proceeding before the CDABC to determine whether or not
Business Owner #2 could continue as an officer and stock holder of a business entity that held a
California liquor license; and
c.

Obtaining an official police accident report for, and providing it to,

Business Owner #2 related to a car accident involving Person #3.
In violation of Title 18, United States Code, Sections 1951(a) and (b)(2) and
Section 2.

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 COUNTS THIRTEEN THROUGH SEVENTEEN
(Scheme to Defraud the City and County of Philadelphia and its Citizens
of Defendant WILLIAMS’s Honest Services)
1.

Paragraphs 1 to 8 of Counts One to Five and Counts Seven to Eleven of

this Indictment are incorporated here.
2.

At all times relevant to Counts Thirteen to Seventeen of this

Indictment, the DAO, the City and County of Philadelphia, and the citizens of the City and
County of Philadelphia had an intangible right to the honest services of their employees and
elected public officials. As District Attorney for the City and County of Philadelphia,
defendant WILLIAMS owed the City and citizens of Philadelphia a duty to, among other
things, refrain from receiving bribes and kickbacks in exchange for defendant WILLIAMS’s
official action and influence, and for violating his duties as District Attorney.
3.

At all times relevant to Counts Thirteen through Seventeen of this

Indictment, defendant WILLIAMS and/or the City of Philadelphia electronically transmitted,
or caused to be transmitted, SFIs to computer servers in Dallas, Texas operated by a data
company (the “Data Company”), which contracted with the City of Philadelphia to facilitate
the filing of SFIs.
4.

From in or about July 2010 to in or about January 2017, in the Eastern

District of Pennsylvania, and elsewhere, defendant
RUFUS SETH WILLIAMS
and others knowingly and intentionally did devise and intend to devise a scheme and artifice to
defraud the DAO, the City and County of Philadelphia, and its citizens of the right to defendant
WILLIAMS’s honest services as the District Attorney for the City and County of Philadelphia
by means of materially false pretenses, representations, and promises.

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 5.

The purpose of this scheme and artifice to defraud was for defendant

WILLIAMS to deprive the DAO, the City and County of Philadelphia, and its citizens of the
honest services of defendant WILLIAMS through deceit and trickery; namely by accepting and
agreeing to accept a stream of concealed bribes and kickbacks (a) from Business Owner #1 in
exchange for defendant WILLIAMS’s official action and influence, and for violating his official
duties, in matters relating to (i) a criminal case and matter under investigation by the DAO
related to Person #1; and (ii) security screening of Business Owner #1 by law enforcement
authorities at the United States border when Business Owner #1 was attempting to return to the
United States after foreign travel; and (b) from Business Owner #2 in exchange for defendant
WILLIAMS’s official action and influence, and for violating his official duties, in matters
relating to (i) the appointment of Business Owner #2 as Special Advisor to the DAO; (ii) the
CDABC’s determination of whether or not Business Owner #2 could continue as an officer and
stock holder of a business entity that held a California liquor license; and (iii) an official police
accident report related to a car accident involving Person #3.
6.

On or about the dates listed below, in the Eastern District of

Pennsylvania, and elsewhere, for the purpose of executing and attempting to execute this
scheme and artifice to defraud, defendant
RUFUS SETH WILLIAMS
and co-schemers knowingly and intentionally transmitted and caused to be transmitted in
interstate and foreign commerce by means of wire, radio, and television communications
certain writings, signs, signals, pictures, and sounds as set forth below:

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 COUNT

DATE

DESCRIPTION OF WIRE TRANSMISSION

THIRTEEN

January 30,
2012

Email communication from Business Owner #1, in the
Eastern District of Pennsylvania, to representatives of
the Punta Cana Resort, in Punta Cana, Dominican
Republic, for the purpose of confirming that defendant
WILLIAMS’s and Person #2’s trip to the Punta Cana
Resort would be on February 1, 2012, through February
5, 2012, and booking rooms at the Punta Cana Resort,
including the “presidential suite in Royal Service,” for
defendant WILLIAMS and Person #2.

FOURTEEN

February 24,
2012

Electronic transmittal from a furniture store in
Philadelphia to a Delaware corporation with processing
facilities in Nebraska and Arizona of a credit card
payment of approximately $3,212 by Business Owner
#1 for a custom sofa for defendant WILLIAMS.

FIFTEEN

March 12,
2013

Email communication in interstate commerce received
by defendant WILLIAMS and members of his security
detail sent by a DAO employee in Philadelphia with the
subject line “Schedule,” attaching a schedule that listed
“Meeting with [Police Official #1], [a social club in
Philadelphia], per DA,” on March 15, 2013, and
arranging transportation for such meeting.

SIXTEEN

June 7, 2013

Electronic transmittal of defendant WILLIAMS’s 2012
City SFI by the City of Philadelphia to computer servers
operated by the Data Company in Dallas, Texas, which
omitted reference to benefits that defendant
WILLIAMS received from Business Owner #1 and
Business Owner #2 during the 2012 calendar year.

SEVENTEEN

November 17,
2014

American Express credit card transaction in interstate
commerce by Business Owner #2, who was in
Philadelphia, to book Spirit airline tickets for defendant
WILLIAMS and his family members for travel on or
about March 22, 2015, from Atlantic City, New Jersey
to Fort Lauderdale, Florida.

In violation of Title 18, United States Code, Sections 1343, 1346, and 2.

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 COUNTS EIGHTEEN TO TWENTY-THREE
(Wire Fraud)
THE GRAND JURY FURTHER CHARGES THAT:
1.

Paragraph 1 of Counts One to Five of this Indictment is incorporated here.

2.

At all times relevant to Counts Eighteen to Twenty-Three of this

Indictment:
a.

There was an individual who was defendant WILLIAMS’s relative

(“Williams’s Relative”).
b.

There was a nursing home in Pennsylvania where Williams’s

Relative resided beginning in or about February 2012 (the “Nursing Home”). During in or about
2012, after Williams’s Relative’s admission to the Nursing Home, Williams’s Relative still was
receiving income in the form of pension and Social Security income, which was being deposited
into a joint bank account that Williams’s Relative shared with defendant WILLIAMS.
Defendant WILLIAMS signed admission agreements with the Nursing Home confirming that, as
the “Responsible Person” for Williams’s Relative, he had access to Williams’s Relative’s income
and that he would apply this income to the costs of Williams’s Relative’s care. Further,
defendant WILLIAMS represented and agreed to use Williams’s Relative’s income only for
Williams’s Relative and not for defendant WILLIAMS’s own personal benefit.
c.

There were two individuals who were longtime friends of

Williams’s Relative (the “Friends”).
3.

From in or about February 2012 to in or about November 2013, in the

Eastern District of Pennsylvania, defendant
RUFUS SETH WILLIAMS

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 knowingly and intentionally did devise and intend to devise a scheme and artifice to defraud the
Nursing Home and the Friends, and to obtain money and property by means of materially false
and fraudulent pretenses, representations, and promises.
4.

It was part of the scheme that:
a.

During in or about 2012, instead of applying Williams’s Relative’s

income to the Nursing Home as he had agreed, defendant WILLIAMS diverted a total of
approximately $10,319 of Williams’s Relative’s income for his own personal benefit, through
cash withdrawals and his payment of personal expenses, including his mortgage and electrical
services at his home. To conceal his diversion of these funds, in or about May 2012, defendant
WILLIAMS falsely represented to employees of the Nursing Home that Williams’s Relative –
and not defendant WILLIAMS – was the one spending Williams’s Relative’s pension and Social
Security income instead of forwarding such income to the Nursing Home.
b.

In or about October 2013, the Friends provided a check for

$10,000 to Williams’s Relative to help defray Williams’s Relative’s expenses at the Nursing
Home. This check was payable to defendant WILLIAMS, who deposited the check into his
account at a financial institution in Philadelphia. Although he knew that this money was
intended for Williams’s Relative’s care at the Nursing Home, defendant WILLIAMS spent the
entire $10,000 for his own personal benefit, including through cash withdrawals, restaurant
expenses, and his payment of personal expenses, including mortgage payments and tuition.
5.

On or about the dates set forth below, in the Eastern District of

Pennsylvania, and elsewhere, for the purpose of executing and attempting to execute this scheme
and artifice to defraud, defendant
RUFUS SETH WILLIAMS
46

 knowingly and intentionally transmitted and caused to be transmitted in interstate commerce by
means of wire, radio, and television communications certain writings, signs, signals, pictures,
and sounds as set forth below:
COUNT

DATE

DESCRIPTION OF WIRE TRANSMISSION

EIGHTEEN

May 30, 2012

Electronic transmission in interstate commerce, by a
mortgage company in Bryn Mawr, Pennsylvania, of
image of check in the amount of $500, written by
defendant WILLIAMS, using funds from Williams’s
Relative’s pension and Social Security income that was
due to the Nursing Home.

NINETEEN

August 10, 2012

Electronic transmission in interstate commerce, by a
mortgage company in Bryn Mawr, Pennsylvania, of
image of check in the amount of $564, written by
defendant WILLIAMS, using funds from Williams’s
Relative’s pension and Social Security income that was
due to the Nursing Home.

TWENTY

September 11, 2012

Electronic transmission in interstate commerce, by a
mortgage company in Bryn Mawr, Pennsylvania, of
image of check in the amount of $570, written by
defendant WILLIAMS, using funds from Williams’s
Relative’s pension and Social Security income that was
due to the Nursing Home.

TWENTYONE

October 30, 2013

Electronic transmission in interstate commerce, by a
mortgage company in Bryn Mawr, Pennsylvania, of
image of check in the amount of $2,324.71, written by
defendant WILLIAMS, using funds provided by the
Friends that were intended for Williams’s Relative’s
care at the Nursing Home.

TWENTYTWO

November 7, 2013

Electronic transmission of check card transaction in the
amount of $117.90 by defendant WILLIAMS at a
supermarket while vacationing in St. Michaels,
Maryland to defendant WILLIAMS’s PFCU account in
Philadelphia, using funds provided by the Friends that
were intended for Williams’s Relative’s care at the
Nursing Home.

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 TWENTYTHREE

November 8, 2013

Electronic transmission of check card transaction in the
amount of $170.88 by defendant WILLIAMS at a
restaurant while vacationing in St. Michaels, Maryland
to defendant WILLIAMS’s PFCU account in
Philadelphia, using funds provided by the Friends that
were intended for Williams’s Relative’s care at the
Nursing Home.

In violation of Title 18, United States Code, Section 1343 and Section 2.

48

 NOTICE OF FORFEITURE
THE GRAND JURY FURTHER CHARGES THAT:
1.

As a result of the violations of Title 18, United States Code, Sections 1343, 1951

and 1952, set forth in this Indictment, defendant
RUFUS SETH WILLIAMS
shall forfeit to the United States of America, pursuant to Title 18, United States Code, Section
981(a)(1)(C) and Title 28, United States Code, Section 2461, all property, real and personal, that
constituted and was derived from proceeds traceable to the commission of such offenses,
including, but not limited to, approximately $54,465.48, representing the sum of approximately
$34,145.52 worth of bribe proceeds and approximately $20,319.96 worth of fraud proceeds.
2.

If any of the property subject to forfeiture, as a result of any act or

omission of defendant WILLIAMS:
(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;

it is the intent of the United States, pursuant to Title 28, United States Code, Section 2461(c),
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other

49

 property of defendant WILLIAMS up to the value of the property subject to forfeiture.
Pursuant to Title 28, United States Code, Section 2461(c) and Title 18, United
States Code, Section 981(a)(1)(C).

A TRUE BILL:

FOREPERSON
JEFF B. SESSIONS
Attorney General of the United States

WILLIAM E. FITZPATRICK
Acting United States Attorney
for the District of New Jersey
Acting Under Authority Conferred by 28 U.S.C. § 515

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