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UNITED STATES DISTRICT COURT

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SOUTHERN DISTRICT OF CALf FORNIA

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11

June 2017 Grand Jury
UNITED STATES OF AMERICA,

I N D I C T M
N T
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.

E

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18 CR 3 65 7 JLS

Case No.

Title 18, U.S.C., Secs. 1349, 1346
and 1343 - Conspiracy To Commit
Honest Services Fraud; Title 18,
U.S.C., Sec. 981 (a) (1) (C), and
Title 28, u.s.c., Sec 2461(c) Criminal Forfeiture

v.
BROOKS ALONZO PARKS,

15

Defendant.

16
17

The grand jury charges that, at all times relevant:

18

1.

Defendant BROOKS ALONZO PARKS,

("PARKS"), was an active-duty
From December 2005 to

19

enlisted sailor

in the United States Navy.

20

September 2011,

PARKS served as a

21

September 2011,

PARKS was promoted to Chief Petty Officer,

22

that capacity from September 2011 until his retirement in January 2016.

23

2.

and in

serving in

From on or about December 2005 to November 2008, PARKS was a

24

Logistics Lead Petty Officer

25

Navy Seventh Fleet.

.26

Petty Officer First Class,

( "LPO")

on the staff of Commander,

U.S.

As a Logistics LPO, PARKS' s duties included managing

part of the logistics budget, signing and processing invoices, and other

27

logistics

functions.

From December 2008

28

assigned as Staff Support, an Assessor, and an Instructor at the Afloat
MWP:PAHO:nlv:San Diego:8/16/18

until

May 2013,

PARKS was

 1

Training Group, Western Pacific; and from May 2013 until his retirement

2

in January 2016, PARKS was a Material and Supply Lead Petty Officer at

3

the Naval Supply Systems Command in Naples,

4

3.

As a

Italy.

senior enlisted sailor in the U.S.

Navy,

PARKS was a

5

"public official" within the definition of Title 18, United States Code,

6

Section 201(a) (1), and as such owed a fiduciary duty to both the United

7

States Navy and the American public.

9

Leonard Glenn Francis

4.

8

citizen of Malaysia,

residing

("Francis") ,

charged elsewhere,

in Singapore.

Francis

was

was a

the

Chief

10

Executive Officer and President of Glenn Defense Marine (Asia)

11

a multi-national

corporation with headquarters

12

September

2013,

GDMA

13

including

Japan,

14

Australia,

15

involved the "husbanding" of marine vessels, a service it had provided

16

across

17

contracts with the U.S.

18

involves

19

procurement of items and services required by ships and submarines when

20

those vessels arrive at port.

21

included,

22

fees;

23

and transfer of

24

others.

25

5.

26
27
28

had

operating

Thailand,

Malaysia,

Philippines,

the

Seventh

the

in

Hong

and the United States.

Fleet's

area

Navy for

coordinating,

among others,

security; food;

in Singapore.

locations
Korea,

of

countries,

Kong,

Indonesia,

fenders;

under

and

indirect

items and services

port authority or customs

fuel; water; trash removal; collection,

liquid waste

Alex Wisidagama

( "CHT");

and transportation,

( "Wisidagama"),

various

"Ship husbanding"

direct

Examples of these

tugboats;

of

GDMA' s main business

over 25 years.
and

As

many

responsibility

scheduling,

( "GDMA") ,

holding,

among many

charged elsewhere, a

citizen

of Singapore, was GDMA's Global Manager for Government Contracts.
6.

Neil Peterson

("Peterson"),

charged elsewhere,

Singapore, was GDMA's Vice President of Global Operations.

2

a citizen of

 1
2

Count 1

3

Conspiracy To Commit Honest Services Fraud

(18

4

6

§§

1349, 1346 & 1343)

The allegations in Paragraphs 1 through 6 of this Indictment

7.

5

u.s.c.

are hereby re-alleged and incorporated herein.
From in or about March 2006 until at least in or about March

8.

7

8

2010,

on the high seas and out of the jurisdiction of any particular

9

district,

defendant

BROOKS

ALONZO

("PARKS"),

PARKS,

Leonard

Glenn

10

Francis,

("Francis") , charged elsewhere, and others did knowingly and

11

intentionally conspire and agree to devise a material scheme and artifice

12

to defraud the U.S. Navy and the citizens of the United States of their

13

rights

14

actions,

15

concealment of material information; and for the purpose of executing

16

this scheme, defendants and their conspirators

17

to

18

communication in interstate and foreign commerce.

to PARKS' s

be

and

honest,

loyal,

performance,

transmitted

19

and faithful,

through

writings,

signs,

bribery

and

services,

and

decisions,

kickbacks

and

the

transmitted and caused

signals

by

means

of

wire

OBJECT OF THE CONSPIRACY
9.

20

It was

the object of the conspiracy for

PARKS to use his

21

position and influence in the U.S. Navy to advance GDMA's interests, as

22

opportunities arose,

23

favor of GDMA; providing Francis and others with internal, proprietary

24

U.S.

25

confidential

26

Francis and other GDMA personnel would offer and give things of value

27

to or on behalf of PARKS, such as gifts, transportation, hotel expenses,

Navy

by,

information;
information

among other things,

and
about

taking official acts in

providing

Francis

GDMA's

competitors,

28

3

and
and

others
in

with

return,

 j

1

and airline tickets,

2

public of their rights to PARKS's honest services.

3

MANNERS AND MEANS OF THE CONSPIRACY
10.

4

5

thereby depriving the U.S. Navy and the American

In

furtherance

of

this

conspiracy,

and

to

accomplish

its

object, the following manners and means were used, among others:
a.

6

PARKS, Francis, Peterson, and others devised a material

7

scheme and artifice to deprive the U.S. Navy and the American public of

8

their rights to PARKS's honest services.
b.

9

PARKS would demand, seek, receive, and accept things of

10

value from Francis and others,

11

expenses, and airline tickets.

12

c.
of

including gifts,

transportation,

Francis and other GDMA personnel would offer and give

13

things

14

transportation, hotel expenses, and airline tickets.

15

value

d.

hotel

to

or

on

behalf

of

PARKS,

In return for these things of value,

including

gifts,

PARKS would agree

16

to use his position and influence with the U.S. Navy to advance GDMA's

17

interests, as opportunities arose.

18

e.
with

In return for these things of value, PARKS would provide

19

GDMA

internal,

20

confidential information about GDMA's competitors.

21
22
23
24

proprietary

U.S.

Navy

information

as

well

as

OVERT ACTS
11.

In furtherance of the conspiracy and to effect its objects,

the following overt acts, among others, were committed:
a.

On or about June 20, 2006, PARKS emailed a GDMA executive,

25

who forwarded the email to Francis, asking GDMA to reserve a hotel suite

26

for an upcoming vacation for PARKS.

27

feels good living like a KING on an E-6's salary!!!"

In the same email, PARKS wrote: "It

28
4

 On or about January 31, 2007, PARKS requested that GDMA

b.

1

2

reserve him a hotel suite and a hotel room for his friend, another U.S.

3

Navy enlisted sailor, during a port visit by the USS Blue Ridge to Hong

4

Kong.

5

of his request,

6

checking to see if you had the chance to locate me a nice suite and

7

executive

room for

8

different

hotel,

9

Ultimately, GDMA paid for a studio suite at the Renaissance Harbor View

10

in Hong Kong and a room for his friend, at a total cost of over $3,000.

PARKS sent a follow-up email on February 1, 2007 reminding GDMA
"I feel

Hong

PARKS

awkward stressing the

Kong."

When offered a

replied,

"I'd like

issue but

standard

something

I

was

just

room at

a. lot

a

nicer."

11

c.

On or about February 23, 2007, in connection with a USS

12

Blue Ridge port visit,

13

Carlton Suite at the Ritz Carlton Hotel in Singapore, a room that would

14

have cost over $4,000 per night.

15

the room for one of PARKS's friends, at the Hilton Hotel in Singapore,

16

at a total cost of over $3,000.

GDMA instead paid for his room, and

On or about February 28, 2007, PARKS again requested that

d.

17

PARKS requested that GDMA reserve him the Ritz

18

GDMA reserve him the Ritz Carlton Suite at the Ritz Carlton Hotel in

19

Kuala Lumpur, Malaysia, in connection with a USS Blue Ridge port visit

20

there.

21

replied: "What is he doing for us and can we make any money out of him?"

22

Ultimately,

23

friends at his request, at the Trader's Hotel in Kuala Lumpur.

Peterson forwarded the email to another GDMA executive,

GDMA paid for his room and the room for one of PARKS' s

On or about March 31,

e.

24

who

2007,

Peterson emailed PARKS and

25

another U.S. Navy official asking about the status of payment for a GDMA

26

invoice.

27

would assist GDMA in processing the invoice, noting the U.S. Navy would

28

"take

care

PARKS replied on April 3,

of

this

immediately."

2007,

informing Peterson that he

Peterson
5

forwarded

the

email

to

 1

Wisidagama, saying, "Finally he's doing something for us! ! . . .

2

make good use of him since he's going to be onboard until 2009! !"
f.

3

On or about April 4,

2007,

[We] will

Peterson replied to PARKS's

4

pledge to assist, noting, "[Francis] was saying that u got bitten by the

5

Glenn [GDMA] Bug man!!"

6

right!!! The Glen Bug has bit the s***

7

of me! ! ! ... You know I've got your back 1 ike you've got mine."

8

g.

PARKS answered, "You know Mr. Francis is quite
[no alteration in original] out

On or about June 2, 2007, PARKS emailed Peterson a copy

9

of the internal, proprietary itinerary to the Philippines for the USS

10

Blue Ridge Supply Officer, asking that GDMA provide him off-the-books

11

transportation and a driver while he was in Manila.

12

the email to .Francis, who replied that GDMA needed sensitive competitor

13

information related to another ship's port visit to Cebu, Philippines.

14

PARKS sent the requested competitor information to Peterson on June 5,

15

2007,

16

through for us again... haha".

who forwarded it to Francis,

h.

17

saying,

Peterson forwarded

"Looks like PARKS pulled

On or about June 22, 2007, PARKS emailed GDMA the upcoming

18

internal, proprietary port visit schedule for the USS Paul Hamilton and

19

the USS Stethem.

20

i.

On or about January 9, 2008, at Peterson's request, PARKS

21

sent GDMA additional sensitive pricing information,

22

taxi pricing by GDMA's competitor in the Philippines.

23

j.

On

or

about

January

15,

2008,

at

related to water

the

direction

of

24

Peterson, GDMA provided PARKS with hotel rooms at the Renaissance Harbor

25

View in Hong Kong for himself and three friends.

26

k.

On or about February 27, 2008, Wisidagama emailed PARKS

27

saying that he was doing research on port visits to Qingdao,

28

asking

if

PARKS

could provide

internal,
6

proprietary U.S.

China,

Navy cost

 1

information.

PARKS replied,

2

It may be a tidbit

3

you know for you I will try."

difficult getting info on another ship.

On or about March 22,

1.

4

[sic]

"I will check on this as soon as possible.

2008,

But

Wisidagama emailed PARKS

5

asking for new copies of competitor pricing and competitor invoices for

6

Cebu, Philippines.

7

and Wisidagama,

8

related to competitor pricing in Cebu, Philippines.

9

must investigate [the competitor's] prices now since our last contract!

On or about March 24, 2008, Francis emailed Peterson

asking if PARKS could provide still more information

10

We must finish [the competitor] once and for all."

11

2008,

12

documentation.

PARKS

provided

competitor's

On or about March 31, 2008,

m.

13

the

14

PARKS attached a competitor's voucher,

15

in Pat ta ya

16

make sure I have 2 suites in both places."

17

[Thailand]

n.

internal,

proprietary

in an email chain in which
"Brothas,

I' 11 be

from 1-4 May and Singapore 7-10 May ...... please

On or about April 24, 2008, PARKS again asked for a hotel

room in Singapore.

19

up with 2 King/Executive suites at a

20

(May 6-10)

21

Center] Singapore, so you may see me a lot."

... I

0.

On or about March 3 0,

PARKS wrote,

18

22

Francis wrote, "We

In an insistent email, PARKS wrote: "PLEASE hook me
really nice hotel in Singapore

may be taking orders to

In or about May 2008,

[the Fleet Industrial Supply

PARKS asked GDMA to purchase

a

23

ticket so he could fly back to the United States to visit his sick

24

grandmother.

25

and others, saying, "I'd like to simply thank you all for your guidance

26

in my travels back to the U.S. for my Grandmother's passing under such

27

short notice ... Again, I can't thank you enough.

28

Thank you ! ! ! ! "

On or about June 2, 2008, PARKS emailed Francis, Peterson,

7

Thank you ...... Thank you .... .

 p.

1

On or about June
saying,

2 008,

PARKS

emailed Peterson and

2

Wisidagama,

3

Hennessey for me??? Pleeeeease."

4

a case of White Hennessey delivered to PARKS's house in Japan,

5

request.

q.

6

"Brotha' s,

3,

Can you please follow up on the White

In January 2009,

In approximately autumn 2008, GDMA had

PARKS emailed

Peterson asking

7

"major hook up."

8

and

9

there!!! ... I need the suite to be especially nice.

2

regular

"Please put my bid for a

rooms

because

I

have

a

5 star

very

at his

[s] uite

special

for

a

(Shangri La)

lady meeting me

Let me know if you

1 o and the Boss need anything! ! ! . "

r.

11

On or about March 10, 2010,

PARKS emailed Peterson with

12

the subject line "Need a Big Favor," asking for GDMA to reserve him a

13

suite for his upcoming vacation to Singapore with his fiancee.

14

All in violation of Title 18, United States Code,

15

and 1343.

Sections 1349,

1346

FORFEITURE ALLEGATIONS

16
12.

17

The

allegations

set

forth

in Count

1

are

incorporated by

18

reference for the purpose of alleging forfeiture pursuant to Title 18,

19

United States Code,

20

Code, Section 2461 (c) .

21

II
II
II
II
II
II
II
II

22
23
24
25
26
27
28

Section 981 (a) (1) (C),

8

and Title 28,

United States

 1

13.

Upon conviction of the offense set forth in Count 1 defendant

2

BROOKS ALONZO PARKS shall forfeit to all property, real and personal,

3

which constitutes or is

4

pursuant to Title 18,

5

Title 28, United States Code, Section 246l(c), including but not limited

6

to a money judgment in an amount

7

offense set forth in Count 1.

derived from proceeds traceable to Count 1

United States Code,

A TRUE BILL:

9

g~Y:VG,

10
11

13
14

)oreperson
ADAM L. BRAVERMAN
United States Attorney
By:
MARK W. PLETCHER
Assistant U.S. Attorney

15
16
17
18

and

not less than the proceeds of the

DATED: August 16, 2018.

8

12

Section 981(a) (1) (C),

By:
PATRfCK HOVAK MIAN
Assistant U.S. Attorney

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27
28

9