'Eneo UNITED STATES DISTRICT COURT 1 5 2019 WESTERN DISTRICT OF TEXAS . - AUSTIN meow - seamstressforesaw UNITED STATES OF AMERICA, .- . Criminal NoCounts One?Three: 13 U.S.C. . 1341 (Mail Fraud) I KYLE GERALD PRALL, . - I . afkfa ?Jacob Collins,? Counts Four?Six: 13 U.S.C. afkfa ?John Holloway," I 1343 (Wire Fraud) Defendant. . . Counts Seven?Twelve: 18 1956 (Money Laundering) Counts Thirteen?Fourteen: 18 U.S.C. 1957 (Money Laundering) Counts Fifteen, Seventeen, . Nineteen: 18 U.S.C. 1001(a)(2) (False Statements) - Counts Sixteen, Eighteen, Twenty: 13 U.S.C. 1519 (Falsi?eation of Federal Records) INDICTMENT The Grand ury charges: BACKGROUND ALLEGATIONS l. . At all times. material to this indietment: 2. Defendant KYLE GERALD PRALL was a resident of Austin, Texas; in the .. IE WeStern DiStriet of Texas. i . 3. Person A worked for PRALL as a digital marketer. 4. Person worked for PRAILL as a bookkeeper. . S. The Federal Election. was an agency of the United States Government responSibie for'regulating, among other things; politi?eal committees formed to i. 1 . support candidates for'federal, elected of?ce through fundraising and expenditures. 6. During the 2016 election cycle for the Office of the President of the United States, political were required to report to the FEC all contributions and expenditures of $200 or more. Reports of contributions of $200 or more were required to include the amount of the contribution, the date of receipt, the donor?s name and address, and the donor?s occupation and employer. Reports of expenditures of $200 or more were required to include the amount of the expenditure, the date of payment, the name and address of the payee, and the purpose of the disbursement. 7. - On. or about December 30, 2015, PRALL registered the political committee ?Feel Bern? with the FEC for the stated purpose of supporting Presidential Candidate A?s candidacy for President of the United States. The name of the committee was later changed. to ?Socially - Responsible Government,? although the website associated with the committee continued to use ?Feel 136111.?. 3. On or about January 19, 2016, PRALL registered the political committee ?HC4President? with the FEC, . PRALL registered HC4President fer the stated purpose of supporting Presidential Candidate B's candidacy for President of the United States. 9. On or about March 25, 2016, PRALL registered the political corhmitteef?Trump Victory? with the PRC. PRALL registered Trump Victory for_the stated purpose of supporting Presidential Candidate C?s candidacy for President of the United States. The name of the committee was later changed to ?Make America Great.? 10. A?er registering each political committee, PML opened or causedto be opened :a corresponding bank account for each committee at Financial Institution A. I I . I 11. opened LLCs and corresponding bank accounts at Financial Institutions 2 and to serve as anonymous shells to launder funds from the political conunittees and to distribute them to PRALL. PRALL used a preexisting Limited Liability Company and: bank account at Financial .InstitutionB to operate Feel 'Bern'initially and later used the account as a final -I layer to further launder meney raised by the political committees .and transfer it to personal accounts. Most of the bank accounts were closed shortly after. the end of the 2016 election cycle. The LLCs and-acco?nts are re?ected below: Entity Formed .0 . Modi?ed::% LRQ dfb/af Feel the Bern December 2015 November 2015 . -- Financial Institution - DMF Marketing Solutions January 2016 February'2016, . December 2016 Financial Institution . - NHT Productions January 2016 January 2016, February 201'? - - Financial Institution - . - Apex Marketing (?Apex?) June 2016 June 2016, Financial August 2017 - Institution THE SCHEME TO DEFRAUD 12. Beginning in December 2015 and continuing until no later than August 20 in the I Western District of Texas and elsewhere, the defendant, PRALL, did knowingly devise and intend I to devise a scheme and arti?ce to den-and and to obtain money. by means of material :false 'and daudulent pretenses, representations, and promises; speci?cally, PRALL solicited contributions- from the general public for multiple political committees, including Feel Bern, HC4President, and Trump Victory, based on misrepresentations, including but not limited to, that the money . contributed by. donors would be used to support candidates for the Of?ce of the President of the i United States by: (1) paying for transportation for voters to the polls; (2) paying for training for volunteers to make phone calls and canvass neighborhoods to support the respective candidates; (3) paying to help voters obtain appropriate identi?cation documents; and (4) making contributions 3 . I directly to Presidential Candidate and to other organizations supporting his campaign, when in - reality PRALL did not intend to, and did not, use the contributions for any of these purposes and b. instead transferred much of the money to himself through- sham LLC accounts and used the other funds to generate additional contributions to his fraudulent political committees. PURPOSES on THE SCHEME 13.. It was a purpose of the scheme for the defendant, PRALL, to enrich himself by, I obtaining contributions under-false pretenses from supporters-of candidates for the Of?ce of the . President of the United States during the 2016 election cycle. 14. It was a purpose of the scheme for the defendant, PRALL, to conceal-from the public, his donors, and the FEC the fact that he was regularly transferring funds from his political committees to bank accounts that he controlled for his personal enrichrhent 15: It was a purprise of the scheme for the defendant, PRALL, to conceal from the . - public, his donors, and the EC that he was spending moneyr contributed to his political committees directly from the political committee bank accounts on personal expenses unrelated to the candidates or the 2016 presidential election. MANNER AND MEANS - 16. The manner and means by which the defendant, PRALL, and others carried ?out the - scheme included, but were not limited to, the following: 17. Beginning in December 2.01.5, PRALL began registering political committees with the FEC for the stated purpose of soliciting contributions and making expenditures 1n support of candidates for the Of?ce of the President of the United States. 18. Beginning in January 2016, PRALL established LLCs and opened bank accounts in the namesof the LLCs to receive transfers from the political committees to allow PRALL t0- 4 transfer political conunittee money to himself without being subject to FEC reporting requirements and public-scrutiny. 1 i 19. Beginning no later than January 2016, PRALL: (1) set up websites soliciting contributions for his political committees based on misrepresentations as to how the money Would be. spent; (2) advertised the existence of his political committees online, including through internet search engines and Social networking sites; and (3) posted content on his political committee. websites to make them appear legitimate. I 20. Beginning in January 2016,- transferred contributions from the political-j 'l committee accounts to LLC banls: accounts that he controlled. PRALL then transferred funds to his personal checking and savings accounts for his personal use, concealing from the FEC, the public. and the contributors'to his political committees that he was-taldng a largeportion of the contributions for his personal enrichment. - - I I 21. Beginning no later than February 2016, PRALL spent money directly from the political committee accounts on purely personal espenclitures. PRALL concealed the true nature of many cf these espenditures by reporting them to the FEC as legitimate eitpenses when they . were purely personal in nature and mirelated to the political committees. ACTS IN FURTHERANCE OF THE SCHEME Bern A. Solicitations 22. On or about December 30, 2015, PRALL caused to be ?led an FEC Form 1 - Statement oi-Organization registering ?fFeel Bern? as a political committee to support, Presidential Candidate A. On March 7, 2016,- PRALL caused to be filed] an FEC Form 1_ Statement. of Organization changing the name of the political to ?Socially Responsible Goyernmentd? 5 . 23. No later than January 2016, PRALL designed and launched a website at '3 identifying the host organization as the Feel Bern Committee to Elect Presidential Candidate All PRALL solicited donations through the website and falsely clairned: ?We are volunteers helping [Presidential Candidate win the US Presidential election-arid usher in a new government for the people by helping raise awareness with voters PRALL also falser represented: ?The donations will be used primarily to charter buses for transportation to Voting polls . . . ._This money will go directly to chartering buses and paying for ?iel to transport yoters . to Presidential election polls.? 24 Between December 2015 and July 2016, PRALL raised over $300, 000 in contributions to Feel Bern Despite representations, of this $300, 000, PRALL paid no expenses for transportation, chartering buses, or ?sel. PRALL donated less than $4,000 to political . causes. B. Stealing the Contributions 25. Between February 2, 2016, and January 12 201?, on or abdut the dates listed below, PRALL transferred a total of $49, 361. 33 from Feel Bern to the NHT account and $41, 405. 31 to - the DMF account, both of which he controlled, as set forth below:. ?us/6W1}: trja??gisf ??ftwaf; I Date - Amount 2/23/2016 39,575.00 3/4/2016 $3,570.00 5/4/2016 $7,690.00 4/5/2016 $3,345.00 5/26/2016 $5,674.33 5/4/2016 $5,670.00 7/26/2016 $4,563 .34 $26,201,; $435 66.37 3/3/2016 . $9,653.09 .. . - 3/11/2016 $9,463.93 6/2/2015 . 35163993 3/15/2016 $2,741.59 - 3/3/2016 $3,563.96 Total $49,361.33 Total - - 341,405.31 - 26. In addition, between January and June 2016, paid himself a salary. of - approximately $46,153 .30. 27. . . Additionally, PRALL used the debit card for the political Committee?s bank account at Financial Institution A to pay 'for the following personal expenditures: a. $1,167.64 for a two-night stay at The Palms Hotel Spa in Miami Beaeh, Florida on February 25, 2016; . . b. $3,101.92 at the E1 IEVFZN in Miami, Florida 13133.33, Hookah, alcohol I and bottle service, and $1,476 forlf?eiub dances performed by entertainers? on February 26, 2016; $1,073.31, for a three?night stay at the Omni Barton Creek Resort in Austin, Texas on March 14, 2016-; and I $728.47 for room service and minibar charges, a deepftissue massage, and a pet- cleaning fee, during a three-night stay at the Omni Barton-Creek Resortj'in Austin, I Texas on March 18, 2016. C. False Statements to the FEC I 23. I On'or about April 14, 2016, PRALL, under the pseudonym, ?Jacob Collins,? for I the purpose of reporting expenditures to the FEC, falsely informed the treasurer of Peel Bern, Person B, that the following were legitimate-political conunittee expenditures for ?meals entertaimnen (1) $3,101.92 spent in Miami, Florida, on February 26, 2016, at the EIIEVEN in Miami for hookah, food, alcohol, and bottle service, and $1,470 for ?club dances performedby entertainers,? all paid for betvireen the hours of 1:44 am. and 5:l8 am; and (2) $710.79 for a deep-tissue massage, pet-cleaning fee, room service, and mini-bar charges during his stay at the Omni Barton Creek Resort in Austin, Texas, from March 14-17, 2016-. PRALL falsely categorized these expenditures knowing that they had been entirely personal in nature and knowing that they would be falsely reported to the FEC. A. Solicitations 29. On or about January 19, 2016, PRALL caused to be ?led an FEC Form 1 Statement of Organization registering ?HC4President? as a political committee to support Presidential Candidates. 30. No .later than April 201b, PRALL designed and launched. a' website 'at' identifying the host organization as the to Elect [Presidential Candidate PRALL solicited donations through the website and falsely claimed: ?We are volunteers helping [Presidential Candidate win the US Presidential election and usher in a new government for the people by helping raise awareness with yoters.? PRALL also falsely represented: ?Your contribution goes directly toward paying for training volunteers to knock on doors, make phone calls and spread the word about [Presidential Candidate B]?s movement. It 3' also helps pay for our initiatives to help voters obtain the appropriate ID and transportation to. voting facilities.? I I i I 31. Between January 2016 and November 2016, PRALL raised over $73,000 in contributions to HC4President. Despite representations, of this $73,000, PRALL paid no expenses for training volunteers, helping?voters obtain identi?cation, or arranging or providing transportation to voting facilities. PRALL donated less to political causes. 13. ?Stealing the Contributions 32. Between April 29, 20 1 6, and December 5, 2016, on or about the dates listed below, PRALL ttansferred a total from HC4President to the NHT account and $7,753.30 to the DMF account, both of which he controlled, as set forth below: ?3?33 Date Amount . 4129/2016 . $7,564.00 4(29f2016 $3,221.00 612412016 - $6,742.30 _8!8f2_016 $4,532.83 11/312016 $9,784.50 Total $7,753.88 1111412016 . $4,356.45 - 121512016 $6,096.52 Total $34,543.77 - 33. Additionally, PRALL used the debit card for the political committee?s banlr account at Financial Institution A to pay for the following personal expenditures: . a. $952. 40 for roundtrip airfare for PRALL and his girlfriend to Jacksonville, Florida on April 25, 2016; 12. $460.36 for room service, drinks at the lobby bar, and dinner at the Ornni Hotel in Dallas, Texas on May 5, 2016; and 9 c. $812.43 for roundtrip airfare to Belize on June 29, 2016. C. False Statements to the FEC 34. On or about June-29, 2016, PRALL, for the purpose of reporting expenditures to - the FEC, falsely informed the bookkeeper of HC4President, Person B, that the following were I - legitimate political committee expenditures for ?travel expenses?: $460. 36 spent in Dallas Texas, I on May 3, 2016, for. room service, drinks at the lobby bar, and dinner at the hotel restaurant. PRALL falsely categorized these expenditures knowing that they had been entirely personal in nature and knowing that they would be falsely reported to the FBC. Trump Victog A. Solicitations '35. On or about March 22, 2016, PRALL caused to be ?led an FEC Form 1 Statement - of Organization registering ?Trump Victory? as a political committee to support Presidential Candidate C. On May 24, 2016, PRALL, caused to be'?led an FEC .Form 1 Statement of Organization changing the name of the political committee to ?Make America Grea. 36. No later than June 2016, PRALL designed or caused to be designed and launched or caused to be. launched a website at identifying the host organization as the Committee to Elect [Presidential Candidate PRALL solicited donations through the website and falser claimed: ?We are a group of volunteers from all walks of life who are looking for a real change in leadership and we believelPresidential Candidate can delineafi'rPRALL 1 - also falsely represented: ?We'also donate the maximum allowed legal limits directly to,? [Presidential Candidate and other organization and nonpro?ts that are supporting [Presidential- Candidate 3 campaign for President.? 37._ Between March 2016 and November 2016, PRALL raised over $165, mom I 10 I contributions to Trump Victory. Despite representations, of this $165,000, Ir - made nodonations to Presidential Candidate or other organizations or-nonpro?ts supporting- Presidential Candidate I B. Stealing the Contributions . 3 8. Between June 29, 2016, and December 2016, on or about the dates listed below, transferred a total of $72,431.39 front Trump Victory to the Apex account, which he controlled, as set forth below: 6729/2016 $3,577.50 772512016 $9,339.67 372/2016 $7,567.73 37312016 . $3,423.73 117372016 $9,954.22 117'91'2016 $9,354.33 1111072016 $3,737.39 12/5/2016 $9,376.77 Total $72,431.39 39. Additionally, Prall used the debit card for the political committee?s bank account at Financial Institution A to withdraw $103 front the ATM at Bernie?s Beach House bar and restaurant in Port Aransas, Texas on October 11, 2016. C. False Statements to the FEC 40. On or about October 26, 2016, PRALL, for the purpose of reporting PAC expenditures to the FEC, falsely informed the bookkeeper of Trump Victory, Person B, that a $103 cash withdrawal at Bernie?s Beach'House bar and restaurant in Port Aransas, Texas on October 11,2016, was for Goo gle AdWords PRALL falsely categorized this expenditure knowing that it 4 11 had beenentirely personal in nature and knowing that it would be falsely reported, to the FEC. Transfers to Personal Accounts - 41. After moving funds from the political accounts to his LLC accounts, . PRALL withdrew or transferred nearly all of the money to his personal accounts, either directly or . through the LRQ account. 42. On or about the dates listed below, PRALL transferred funds or wrote checks to! himself frorn'DMF and NET and deposited the checks into his personal checking and savings amounts:- eea?'ett a . eke-?4641411? 2614's sane/sea? 433626373 . Date - Amount 3/29/2016 $7,000.00 3/28/2016 $5,000.00 4/28/2016 $4,000.00 5/3/2016 $4,000.00 5/3/2016 $4,000.00 4/28/2016 $4,000.00 6/27/2016 $530030 6/27/2016 $5,000.00 . - 5/5/2016 $4,000.00 Total $23 000.00 7/5/2016 $5,000.00 7/5/2016 $5,000.00 . Total $29,000.00 '43. Additionally, on or about the dates listed below, PRALL made therollowing - Iransfers from the Apex, DMF, accounts into the LRQ account: Dateaitf?l? Fro?riv? Amount: 8/18/2016 Apex Marketing LRQ $12,693 .3 5 8/24/2016 DMF Marketing LRQ $9,823 .3 3 8/24/201 6 NHT Productions LRQ :13 14,67 8 .90 12/ 13/2016 NHT Productions LRQ $44,879.15 12/13/2016 Apex Marketing LRQ $5 5,000 .00 - 12/13/2016 DMF Marketing LRQ $5,303.48 3/23/2017 Apex Marketing LRQ $4,841.57 TOTAL: $147,719.78 12 44, Beginning in January 2017, on or about the dates listed below, PRALL wrote a check to himself from LRQ 1n the amount of $130,000 arid deposited it into his personal checking account and transferred $20,000 from the LRQ account to a business checking accOunt that he controlled: ""tr?aemt?ali I i Date mAmount Accourit 111212017 $130,000,00 Personal Checking 31712017 - $10,000.00 Business Checking 311512017 $4,000.00 . Business Checking 3127120171 $3,000.00 Business Checking 3112912017 $3,000.00 Business Checking Total $150,000.00 45. On or about January 17, 2017, PRALL transferred $100,000 from his personal checking account to his personal savings account, COUNTS ONE THROUGH THREE 18 U.S-.C. 1341 (Mail Fraud) .46. Paragraphs one through forty-?ve are incorporated and reaileged as if full)r set forth herein. 4'1. 011 or about the dates set forth below, in the Western .District of Texas and elsewhere, the defendant, PRALL, for the purpose of executing and attempting to execute the above- described scheme and arti?ce to defraud, and to obtain money and property by means of material false and fraudulent pretenses, representatiOns, and promises, knowingly and intentionally .- deposited, caused to be deposited, and aided and abetted the deposit of, the following matter and thing to be sent and delivered by the United States Postal Service and other private and commercial I interstate carriers: 13 I 125E503 agar? "eases FEC Form 1, Statement of Organization, 'Feel . Texas D.C. Bern 2 0111812016 Austin, Texas Washington FEC Form 1, Statement of Organization, I-IC4President - . 3 031231201 6 Austin, Texas Washington FEC Form 1, Statement of Organization, D.C. Trump Victory - Allin violation of 13 use. 1341. COUNTS FOUR THROUGH SIX - rs U.S.C. 1343 - (Wire Fraud) 43. I . Paragraphs one through forty-five are incorporated and realleged as if ft?lyset forth herein. 49. On or- about the dates set forth below, in the Western District of Texas and elsewhere, the defendant, PRALL, for the purpose of executing and attempting to execute the above-described scheme and arti?ce to defraud, and to obtain money and property by means of- material false and fraudulent pretenses, representations, and pro?mi ses, knowingly and intentionally transmitted, caused to be transmitted, and aided and abetted the transmission of, writings, signs, signals, pictures, and sounds, by means-of wire communication in interstate commerce for the following transactions: I 6411595618 $506 Feel Bern. 06f211'2016 $2,700 contribution to HC4President 6 A11 in violation of 13 Use. 1343. $500 contribution to Trump Victory 14' . COUNTS SEVEN THROUGH TWELVE 18 U.S.C. 1956 (Money Laundering) 50. Paragraphs one through forty-?ve are incorporated and Tealleged as if Fully set?lfor-th 'hereinabout the dates listed below, in the Western District-of Texas and elsewhete, the defendant, PRALL, knowing that the] property involved in thc'?nancial transactions listed below represented the proceeds of some form' of unlawful activity, and'intentionally conducted and caused to be conducted the ?nancial transactions designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of speci?ed unlawtul activity, lwhich was mail and Wire hand in violation of-Title 13, United States Code, Sections 1341 and 1343, and each transaction affecting interstate commerce, in that the defendant transferred funds from- various ?nancial institutions to the shell LLC I below: ?7 . . Transfer from Feel Bern, Acct at Financial $8,563.96 Institution A to DMF, Acct at Financial Institution B. 8 1/9f2016 Transfer from HC4President, Acct WWI-5 at $9,734.50 Financial Acct at . - Financial Institution C. 9 11/9/2016 Transfer from Trump Victory, Acct 8 at $9,954.22 Financial Institution A to Apex, Acct XXIOIGOQS at . Financial Institution C. . 15 10 31812016 Transfer from Apex, Acct WESOQS at Financial Institution to LRQ, Acct 1900:0325 at Financial Institution for ?Marketing Services.? $12,693.35 11' 8124;2016 Transfer from DMF, Acct M4497 at Financial Institution to LRQ, Acct at Financial . Institution for ?Online Marketing Consulting.? $9,323.33 12 anathema Transfer from NHT, Acct 5 53 at Financial Institution to LRQ, Acct more 325 at Financial Institution for ?Marketing Services.? .r . $14,678.90 Allin violation. of 18 U.S.C. 1956. herein. COUNTS THIRTEEN AND FOURTEEN is U.S.C. 1957 (Money Laundering) 52. Paragraphs one through forty-?ve are incorporated and realleged as if fully'set forth. On or about the following dates, in the Western District of Texas and elsewhere: the defendant, PRALL, did knoWingly and intentionally engage in 'a monetary transaction in criminally derived property of a value greater than $10,000.00 which was derived from speci?ed unlawful activity, that is, mail and wire fraud, in violation of Title 13, United States Code, Sections 1341 and" 1343, to wit, on or about the dates alleged below, PRALL transferred funds from the LRQ account to his personal checking account and transferred fluids from his personal checking account to his personal savings account in the amounts set forth below: 16 Count Date. .. Institution to PRALL's checking account, Acct 1500:3335 at Financial Institution C. 1'3- 1/12/2017 $130 000 {i0 $033835 at Financial Institution to savings account, Acct mama at Financial Institution C. 14 111722017 Transfer from checking account, Acct $100,000l00 Allin violation a 18 use. 1957. COUNT 18 U.S.C. 1001(a)(2) (False Statements) 54. . Paragraphs one through tom-five are incorporated and realleged as if ?Jlly set forth herein. I I 55. On or about April 14, 2016, in the Western District of Texas and elsewhere, the defendant, PRALL, knowingly and willfully, caused the submission of a material false, ?ctitious, and-fraudulent statement-and representation in a'matter within the jurisdiction of the_ executiire branch of the government of the United States, to wit, causing the Feel Bern political committee . to falser record 1n a report to the Federal Election Commission dated April 15, 2016, $3,101. 92 in expenditures at E1 night club in Miami, Florida, as meals and entertainment expenses of the committee, and $710.79 in expenditures at the Omni Barton Creek Resort in Austin, Texas, as' travel expenSes of the committee, when in fact the expenditures were purer personal innature and unrelated to the committee. All in Violation of 18 U.S.C. 1001(a)(2). COUNT SIXTEEN 18 U.S.C. 1519 . (Causing False Records) 56. Paragraphs one through forty??ve are incorporated and realleged as if fully set forth 17' herein. On or about April 14, 2016', in the Western District of Texas and elsewhere, the, defendant, PRALL, with the intent to impede, obstruct, and in?uence, and in relation to and contemplation of, the investigation and proper administration of matters within the jurisdiction of departments and agencies of the United States, knowingly concealed, covered up, falsi?ed, and . made a false entry in a record, document, and tangible object, to wit, Feel Bern political. committee to falsely record in a report to the Federal Election Commission dated April 15, 2016, $3,101.92 in expenditures at E-11EVEN night club in Miami, Florida, as meals and entertainment expenses of the committee, and $710.79 in expenditures at the Omni Barton Creek Resort in Austin, Texas, as travel expenses of the committee, when in 'fact the expenditures were purely personal in nature and unrelated to the committee,- which falsification the defendant well knew and contemplated was related to the proper administration of the Fed Bern committee?s?reduired disclosures under the Election Act by the Federal Election Commission. - All in violation .of18 use. 1519. I COUNT SEVENTEEN is use. 1001(a)(2) . (False Statements) 58. - Paragraphs one through forty??ve are incorporated and realleged as if fully set forth - I I herein. - . 59. On or about June 29, 2016,1111 the Western District of Texas and elsewhere, the defendant, PRALL, knowingly and willfully, caused the submission of a material false, ?ctitious, and fraudulent statementand representation in a matter within the jurisdiction of the executive . branch of the government of the United States, to wit, causing the HC4President political committee to falsely record in a report to the Federal Election Committee dated July; 15, 2016, 18 $460.36 in expenditures at the Omni Hotel in Dallas, Texas, as travel expenses of the cdmmittee,- when in fact the expenditure was purely personal in nature and unrelated to the committee. All in violation of 18 U.S.C. 1001(a)(2). COUNT EIGHTEEN 18 U.S.C. 1519 (Causing False Records) 60. Paragraphs one through forty-?ve are incorporated and realleged as if fully set forth herein. 61. On or about June 29, 2016, in the Western District of Texas and elseWherc, the defendant, PRALL, with the intent to impede, obstruct, and in?uence, and in relation to and- contemplation of, the investigation and proper administration of matters within the jurisdiction of departments and agencies of the United States, knowingly concealed, covered up, falsi?ed, and made a false entry in a record, document, and tangible object, to wit, causing the HC4President political committee 'to falsely record in a report to the Federal Election Committee dated July 15, . 2016, $460.36 in expenditures at the Omni Hotel in Dallas, Texas, as travel expenses of the committee, when in fact the expenditure was purer personal in nature and unrelated to- Ithe_' committee, which falsi?cation the: defendant well knew and centernplated was related to the proper administration of the HC4President committee?s required disclosures under the Election Act by the Federal Election Committee. All in violation'of 13 U.S.C. 1519. COUNT NINETEEN 18 U.S.C. 1001(a)(2) (False Statements) 62. Paragraphs one through forty?five are incorporated and realleged as if ?illy set forth . herein. l9 63. on or about October 26, 2016, in the Western District of Texas and elsewhere, the - defendant, knowingly and willfully, caused the submission'of a material false, ?ctitious, and fraudulent statement and representation in? a matter within the jurisdiction of the executive . branch of the government of the United States, to wit, causing the Trump Victory political conunittee to falsely record in a report to the Federal Election Committee dated November 3, 2016, a $103 cash' withdrawal, as advertising and promotions expenses of the committee, when in fact the expenditure was purely personal in nature and unrelated to the committee. I All in violation of 18 U.S.C. 1001(a)(2). - COUNT TWENTY 18 U.S.C. 1519 (Causing False Records) 64. Paragraphs one through forty-?ve are incorporated and realleged as. 1f fully set forth herein. 65,? 011 Dr about October 26, 2016, in the Western District of Texas and elsewhere, the defendant, PRALL, with the. intent to impede, obstruct, and in?uence, and in relation to and contemplation of, the investigation and proper administration of matters within the jurisdiction of departrnents and agencies of?the United States, knowingly concealed, covered up, falsi?ed, and made a false entry in a record, document, and tangible object, to wit, causing the Trump Victory political committee to falsely record in a report to the Federal Election Committee dated November 3, 2016, a $103 cash withdrawal, as advertising and promotions expenses of the committee, when in fact the expenditure was purely personal in nature and unrelated to the committee, which falsi?cation the defendant well knew and contemplated was related tothe proper administration of the Trump Victory committee?s required disclosures under the Election Act by the federal-i: Election Committee. 20 All in violation of 18 U.S.C. 1519. NOTICE on FORFEITURE (sauna. ?2461(c); 13 use. 66. Pursuant to Title 28, United States Code, Section 2461(c) and Title 18, United States Code Section the United States gives notice to the defendant, that in the event of his conviction of any of the offenses charged in Counts One through Six of this Indictment, all property, real or personal, which represents or is traceable to the gross receipts: obtained, directly or indirectly, from such offense, is subject to forfeiture. NOTICE OF FORFEITURE - (is U.S.C. 982(a)(1)) .67. . Pursuant to Title 18, United States Code, Section 982(a)( 1), the United States gives notice to the defendant, PRAPL, that upon conviction of any of offenses charged in Counts Six through Fourteen, all property, real or personal, involved in money laundering offenses or traceable to such property, is subject to forfeiture. mm 63. Defendant is noti?ed that upon conviction, a money judgment may be imposed equal to the total value of the property subject to forfeiture. I I I 69. Defendant 1s notified that in the event that property subject to forfeiture, as a result of any act or omission of the defendant, (A) cannot be lecated upon the enercise 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 21. (E) has been commingled with other property- that cannot be divided without I dif?culty, the United Siates will seek to forfeit any other property of the defendant up to the total value of the property subject to forfeiture pursuant to Title 21, United States Code, Section 353(p), as incorporated by reference in Title 28, United States Code, Section 2461(c) and Title 18', United States Code, Section 932(b)(l). i TRUE ORIGINAL SIGNATURE $44 . . REDACTED PURSUANT TO ANNALOU .TJROL .E ACT DE 2002 Acting Chief, Public Integrity Sectid JOHN KELLER, Deputy Chief JAMES C. MANN, Trial Attorney 22