Case Document 3 Filed 08/05/14 Page 1 of 21 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION UNITED STATES OF AMERICA - v. I - CRIMINAL CHRISTOPHER B. EPPS and CECIL MCCRORY 18 U.S.C. 1349 18 U.S.C. 7 18 U.S.C. 666(a)(2) 18 U.S.C. 1956(h) 18 1346 31 U.S.C. 5324(a)(3) 18 U.S.C. 1956(a)(1)(B)(i) 26 U.S.C. 7206(2) The Grand Jury charges: At all times relevant to this indictment: 1. The Mississippi Department of Corrections was a state government agency as that term is de?ned in Section 666(d), Title 18, United States Code, and which received bene?ts in. excess of $10,000 annually between 2007 and 2014 under Federal programs I providing Federal assistance to the MDOC. 2. I Defendant CHRISTOPHER B. EPPS was the Commissioner of the Mississippi Department of Corrections and as such was an agent of the MDOC, as that term is de?ned in Section 666(d), Title 18, United States Code. I 3. Defendant CECIL MCCRORY was a local businessman from Rankin County, MiSsissippi, who owned companies that contracted, signed leases or otherwise did business with I MDOC, including but not limited to Correctional Communications, Inc.; College Street Leasing, . - American Transition Services, and GT. Enterprises of Mississippi, Inc. Page 1 of21 Case Document3 Filed 08/05/14 Page-2 of21 MCCRORY was also paid consulting fees by other companies seeking or receiving contracts - with MDOC or for work completed for MDOC, including but not limited to Cornell Corrections, Inc.; The GEO-Group, Inc.; Management Training Corporation; Centric Group, LLC d/b/a Keefe Commissary Network, Adminpros, Wexford Health Sources, Inc.; Blantryi Group; and Branan Medical. COUNT 1 4.1 The allegations contained in paragraphs 1 through 3 of this indictment are realleged and incorporated by reference as though ?illy set forth herein. From in or about 2007 through in or about March 12, 20.14, in Hinds and Rankin County in the Northern Division of the Southern District of Mississippi, and elsewhere, the defendants, CHRISTOPHER B. EPPS and CECIL MCCRORY, did knowingly and intentionally combine, conspire, Confederate, and agree with each other, to commit one or more - of the following offense: to devise and intend to devise a scheme and arti?ce to defraud the Mississippi Department of Corrections and the State of Mississippi and its citizens of their intangible right to CHRISTOPHER B. honest services, through bribes and kickbacks, by useof interstate wire transmissions, in violation of Sections 1343 and 1346, Title 18, United I States Cede. 6. It was the object of the conspiracy that defendant, CECIL MCCRORY, would bribe or provide kickbacks to CHRISTOPHER B. EPPS, Commissioner of the Mississippi Department of Corrections, in exchange for the awarding of MDOC contracts, leases, or-W'ork to . companies owned by MCCRORY or to companies seeking contracts or providing services to Page 2 of 21 Document3 Filed 08/05/14 Page3 of 21 MDOC who had agreed to pay, were paying or already had paid MCCRORY as a consultant. I 7. It was part of the conspiracy that companies owned by defendant MCCRORY- . would be awarded contracts, leases or other work from MDOC. I 8; It was also part of the conspiracy that defendant EPPS, in his position as -- Commissioner of the Mississippi Department of Corrections, would steer and direct such centracts to defendant companies, sometimes recommending to the Mississippi State Personnel Board that companies owned by or associated with MCCRORY be. giVen I contraCts by MDOC on a no-bid or sole source procurement basis. I 9. I It was further part of the conspiracy that defendant MCCRORY secretly paid defendant EPPS, either in cash, through checks made payable to- ?nancial institutions holding the 7 mortgage for-EPPS?s home, or through wire transfers to ?nancial institutions holding loans for I I EPPS or to investment accounts owned by EPPS, in return for assistance in ensuring MDOC awarded or renewed contracts and leases to companies owned by or- to companies which had hired MCCRORY as a consultant. 10. It was ?lrther part of the conspiracy that, in order to keep their relationship and ?nancial arrangement con?dential, defendant EPPS would store cash bribe payments received I from defendant MCCRORY in safe at home, wherein EPPS WOuldlater structure the . deposits of such cash into various bank accounts or purchase cashier?s checks, all in amounts. not greater than $10,000. In furtherance of the conspiracy and to carry out its objectives, the following acts, among others, were committed: Page 3 of 21 Case Document 3- Filed 08/05/14 Page 4 Of 21 11. On or about November 2, 2007, defendant EPPS signed a no-bid MDOC. "contract I awarded to G.T. Enterprises, a company owned by defendant MCCRORY, for lcommissary I services at state prisons and private facilities which housed state inmates. 12. In or about 2007, defendant EPPS solicited money from defendant MC-CROY in exchange for the contract that defendant company had with MDOC at that time. 13. In or about 2007, defendant MCCRORY paid defendant EPPS multiple cash. payments in the. amount of $3,000 to $4,000 on approximately ?fteen occasions for the MDOC contract that had?been awarded to defendant company. 14. In or about March 2008, defendant EPPS approved the assignment of the MDOC I I contract held by defendant company, G.T. Enterprises, to another company, the Centric Group, doing business as Keefe Commissary, LLC,.resulting in a large pro?t for MCCRORY. 15. Shortly thereafter, defendant EPPS solicited defendant MCCRORY to pay off home mortgage. I 16. On July 25, 2008, defendant MCCRORY purchased a cashier?s check in the amount of $100,000 ?om his personal bank account at Community Bank, and had such check made payable and sent to Bank, which held the mortgage for defendant home, with such check being applied to the mortgage for defendant home in Flowoo-d, Mississippi. 2 17. On October 2, 2008, defendant MCCRORY purchased a second cashier?s check in the amount of $100,000'from his personal bank account at Community Bank, and had such Page 4 of 21 Case Documents Filed'O8/05/14 Page50f21- check made payable and-sent to Bank, which held the mortgage for defendant home, with such check being applied to the mortgage for defendant home in I Flowood, Mississippi. 2 i 18.? On October 24, 2008, defendant EPPS signed a contract awarded by MDOC to Adminpros, LLC, which was a company that later paid defendant MCCROY. 19. :On or'about December 9, 2008, defendant EPPS signed a lease between MDOC- and College Street Leasing, a company owned by defendant MCCRORY, for the use of land and facilities upon which to operate a new inmate transition facility for males in Walnut Grove, .- Mississippi. - 20. On January 5, 2009, defendant MCCRORY purchased a third cashier?s check ?om his personal bank account at Community Bank in the amount of $50,000 and made payable . to Bank, which held the mortgage for defendant home, with such check being applied to the mortgage for defendant home in Flowood, Mississippi. 21. . On April 2, 2009, defendants EPPS and MCCRORY signed a lease between MDOC and College Street Leasing, a company owned by defendant MCCRORY, for the use of land and facilities upon which to operate an inmate transition facility for females in Walnut Grove, Mississippi. . 22. On July 16, 2009, defendants EPPS and MCCRORY signed a contract awarded by MDOC to American Transition Services, a company owned by defendant MCCRORY, to operate and manage the men?s facility at the Walnut Grove Transition Center. - 23. On? July 28, 2009, defendant MCCRORY purchased a fourth Cashier?s check at Page 5 of 21 Case Document 3 Filed 08/05/14 Page 6 of 21 Community Bank in the amount $101,309.81, made payable to [Bank of America] Home I I Loan Servicing, which had succeeded Bank in servicing defendant home mortgage, with such check being applied to and ?nally paying off the mortgage of I I defendant home in Flowood, Mississippi. .24. A short time later, after defendant home had been completely paid Hoff by a - defendant MCCRORY, EPPS told MCCRORY that MCCRORY could get anything he wanted in the future from MDOC through EPPS. I 25. On July 30, 2009, Epps deposited (1) $9,000 cash at the Regions bank branch in Flowood, Mississippi at 2:16 pin; (2) $9,000 cash at the Bankle in Flowood, Mississippi at - 2:31 pm; (3) $9,000 cash at the RegiOns bank branch in Jackson, Mississippi at 2:53 pm; and (4) $9,000 cash at the Mississippi Public EmployeesCredit Union in Jackson, Mississippi, the latter of ?which was used to purchase a $9,000 of?cial check which was made payable to Edward Jones investment account. 26. . On August 15, 2009, defendants EPPS and MCCRORY signed a contract awarded by MDOC to American Transition Services, a company owned bydefendant to operate and manage the women?s facility at the Walnut Grove-Transition Center. I 27. On July 29, 2010, defendant EPPS signed a contract awarded by MDOC to Adminpros, LLC, which was a company that paid defendant MCCRORY. I 28. On January 24, 2011, defendant EPPS signed a contract awarded by MDOC to Adminpros, LLC, which was a company that paid defendant MCCRORY. Page 6 of 21 Case Document 3 Filed 08/05/14 Page 7 of 21 29. On July 29, 2011, defendant EPPS signed a contract awarded by MDOC to Adminpros, LLC, which was a company that paid defendant MCCRORY. 30. In or about July 2012, defendant EPPS signed a contract awarded by MDOC to Adminpros, LLC, which was a company that paid defendant MCCRORY. 31. In August 2012, defendant EPPS signed a contract awarded by MDOC to Management Training Corporation, which was a company that paid defendant-MCCRORY. I 32. On August 21, 2012, defendant MCCRORY wired $34,000 from his business account at Merchant Farmers Bank directly to Wells Fargo Home Mortgage, which held the loan for-defendant condominium in Biloxi, Mississippi, with such money being used to pay down Biloxi condominium loan. .- 33. On September 14, 2012, defendant EPPS signed a contract awarded by to - I Management Training-Corporation, which was a company that EPPS had persuaded to hire defendant MCCRORY as a consultant and a company with whom EPPS had personally negotiated consulting fee, telling MCCRORY later, got-us $12,000 per month,? which they ultimately divided evenly after calculating the taxes that MCCRORY would be reSponsible for as having received the income. I 34. - On September 25', 2012, defendant MCCRORY wired $14,000 ?om his business account at Merchant Farmers Bank directly to Wells Fargo Home Mortgage, which held the loan. for defendant condominium in Biloxi, Mississippi, with such money being used to pay down Biloxi condominium loan. 35. On or about October 18, 2012, defendant EPPS signed a no-bid contract awarded Page 7 of 21 Case Document 3 Filed 08/05/14 Page 8 of 21 - by MDOC to Management Training Corporation, which was a company that paid defendant MCCRORY. I 36. On February 14, 2013, defendant MCCRORY wired $40,000 from his buSiness account at Merchant Farmers Bank directly to defendant Edward Jones investment account ending in x??6410, falsely labeling the wire transaction as a consignment sale of farm equipment to conceal and disguise the scheme. 37. On or about July 15, 2013, defendant EPPS signed a no-bid contract awarded by MDOC to Management Training Corporation, which was a company that paid defendant MCCRORY. . 38. On or about July 17, 2013, defendant EPPS wrote a letter to the. Mississippi State Personnel Board requesting ?sole source procurement? for Adminpros, LLC, resulting in Adminpros being awarded a no-bid contract by MDOC later that month. 39, 7 On September 4, 2013, defendant MCCRORY wired $50, 000 from his business account at Merchant Farmers Bank directly to defendant Edward Jones investrnent . account ending in x-6410. I I 40. 'On or about October 8, 2013, defendant EPPS wrote a letter to the. Mississippi State Personnel Board stating that Adminpros ?is the only vendor that performs Medicaid I eligibility services for inmates? and ?is the only vendor that can provide the services as outlined in the attached resulting in Adminpros being awarded a no-bid contract by MDOC later that month. 41. Beginning in or about 2010, defendant MCCRORY gave defendant EPPS a cash Page 8 of21 Case Document 3 I Filed 08/05/14 Page 9 of 21 bribe payment of several thousand dollars each month emanating from the consulting fees that MCCRORY had earned from companies doing business With MDOC, including, but not limited - to, on or about the following dates: A. November 18, 2013 I $8,000 B. December 24, 2013 $8,000 C. February 7, 2014 $8,000 D. March 6, 2014 $8,000 42. During the time period of the conspiracy, defendant MCCRORY never provided defendant. EPPS or the Internal Revenue Service with a Form 1099 reporting the income provided to EPPS by MCCRORY throughout the time period of the conspiracy. I I 43. From January 2008 through June 2014,'defendant EPPS structured over $900,000.00 in cash either by depositing such cash into his checking accounts or by purchasing I cashier?s checks with such cash, almost all such transactions in amounts not greater than . $110,000.00, in order to avoid the reporting requirements of the ?nancial institutions and to further conceal the defendants? bribery and kickback scheme. All in violation of Section 1349, Title 18, United States Code. I I - COUNTS 2?13- 44. The allegations-contained in paragraphs 1 thrOugh 44 of this indictment are realleged and incorporated by reference as though fully set forth herein. 45. That beginning and continuing through in or about the dates listed below, in Hinds and Rankin County in the Northern Division of the Southern-District of Mississippi, the . defendant, CHRISTOPHER B. EPPS, did corruptly solicit and demand for the bene?t of any person, things of value from a person, that is from CECIL MCCRORY, intending to be Page.9 of21 Case Document 3 Filed 08/05/14 Page 10 of 21 in?uenced and rewarded in connection with a transaction and series of transactions of the Mississippi Department of Corrections involving $5,000 or more: COUNT DATES AMOUNT 2 August 21, 2012 . $34,000 3 September 25, 2012 $14,000 4 February 14, 2013 $40,000 5 September 4, 2013 $50,000 6 September 24, 2013 $9,000 7 November 18, 2013 $8,000 8 December 24, 2013 $8,000 9 February 7, 2014 $8,000 10 March 6, 2014 4 $3,000 11 April 9,2014 $8,000 12 May 9, 2014 $8,000 13 June 19,2014 $18,000 Allin violation of Section Title 18, United States Code. . I COUNTS 14-22 46; The allegations contained in paragraphs 1 through 45 of this indictment are realleged and incorporated by reference as though'fully set forth herein. 47. That beginning and continuing through in or about the dates listed below, in Hinds I and Rankin County in the Northern Division of the Southern District of Mississippi, the defendant, CECIL MCCRORY, did corruptly give, offer, and agree to give a thing of value to any person intending to in?uence and reward CHRISTOPHER B, EPPS, Commissioner of the Mississippi Department of Corrections, in connection with a transaction and series of transactions of the Mississippi Department of Corrections involving $5,000 or more: Page 10 of21 Case Document3 Filed 08/05/14 Page 11?0f21 COUNT DATES AMOUNT 14 August 21, 2012 - $34,000 15 September 25, 2012 $14,000 16 February 14, 2013 $40,000 17 September 4, 2013 $50,000 18 September 24, 2013 $9,000 19 November 18, 2013 $8,000 20 December 24, 2013 $8,000 21 - February 7, 2014 . $8,000 22 March 6, 2014 . $8,000 - All in violation of Section 666(a)(2), Title 18, United States Code. COUNT 23 - 48. The allegations contained in paragraphs 1 through 47 of this indictment are realleged and incorporated by reference as though fully set forth herein. 49. From in or about 2007 through in or about March 12,2014, in Hinds and Rankin . County in the Northern Division of the Southern District of Mississippi, and elsewhere, the defendants, CHRISTOPHER B. EPPS and CECIL MCCRORY, di?d knoWingly combine, conspire, and agree with each other and with other persons known and unknown to the Grand Jury to commit offenses against the United States in violation-of Title 18, United States Code, Section 1956, to wit: to knowingly conduct and attempt to conduct ?nancial transactions affecting interstate commerce and foreign commerce, which transactions involved the proceeds- of speci?ed unlawful activity, that is, bribery and kickbacks, knowing that the transactions were designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of speci?ed unlawful activity, and that while conducting and attempting to conduct such ?nancial transactions, knew that the property involved in the ?nancial Page 11 of21 Case Document 3 Filed 08/05/14 Page 12 of 21 transactions represented the proceeds of some form of unlawful activity, in violation of Title 18, United States Code, Section The manner and means used to accomplish the objectives-of the conSpiracy included, among others, the following: I 50. During the time period of the conspiracy, defendant MCCRORY wired several I large bribe payments to the ?nancial institutions that held the mortgage for defendant home in Flowood, Mississippi, with EPPS later using the equity from the proceeds of that I speci?ed unlawful activity to take out a loan to purchase a condominium in Biloxi, Mississippi, thus concealing and disguising the-nature and source of the proceeds from the speci?ed unlaw?ll activity. I 51. During the time period of the conspiracy, defendant MCCRORY gave cash - bribes and kickbacks to defendant EPPS, which EPPS Would put in his safe at home until he was ready to deposit such cash bribes into his various bank accounts or use such cash to purchase - cashier?s checks, later structuring such deposits and purchases in order to conceal and disguise the nature and source of these proceeds of this speci?ed unlawful activity. I 52. During the time period of the conspiracy, defendant MCCRORY alsowired a large bribe payment. to defendant Edward Jones Investment Account, from which EPPS was able to wire money and trade'in his Biloxi condominium for a larger, more expensive condominium in Pass Christian, Mississippi, thus continuing to conceal and disguise the nature I and source of the proceeds of the speci?ed unlawful activity. All in violation of Section 1956(h), Title 18, United States Code. Page 120f21 - Case Document 3 Filed 08/05/14 Page 13 of 21 COUNTS 24-27 53; I The allegations contained in paragraphs 1 through .52 of this indictment are I realleged and incorporated by reference as though fully set forth herein. 7 I 54. From in or about 2007 through in for about June 24, 2014, in Hinds and Rankin . County in the Northern Division of the Southern District of Mississippi, and elsewhere, the . defendants, CHRISTOPHER B. EPPS and CECIL MCCRORY, and others knoWn and unknown to the Grand Jury, devised, intended to devise, and participated in a scheme and arti?ce to de?aud- and deprive the citizens of the State of Mississippi, the State of Mississippi, and the Mississippi Department of Corrections of money, property and the intangible right to the honest services of defendant EPPS and the concealment of material information. I 55. The purpose of the scheme and arti?ce described in Count 1 was for defendant I - EPPS to secretly use his of?cial position to enrich himself and others by soliciting and accepting gifts, payments, and other things of value from defendant MCCRORY in exchange for favorable I of?cial. action and for MCCRORY to enrich himself by secretly obtaining favorable of?cial . action for himself, his companies, and his clients through corrupt means. . The scheme and arti?ce was carried in the following mannerrand means, among others: 56.. The defendant EPPS solicited and accepted gifts,'payments, and other things Iof value from defendant MCCRORY, as detailed below. I I. . 57. . The defendant EPPS provided favorable of?cial action on behalf of defendant MCCRORY as requested and as opportunities arose, including the directing or awarding of contracts or leases to companies owned or controlled by defendant MCCRORY or to companies Page 13 of21 Case DocumentB Filed 08/05/14 Page14 of21 that were paying MCCRORY consulting fees. 58. The defendants EPPS and MCCRORY took steps to hide, conceal, and cover up their activity and the nature and scope of their dealings with each other, including. I A. The wiring of money from one of defendant business accounts to Wells Fargo Home Mortgage, the ?nancial institution holdingth'e mortgage for defendant condominium in Biloxi, Mississippi. - B. The wiring of money from defendant Tractor Store I business account to the Edward Jones investment account owned and controlled by defendant EPPS, with MCCRORY falsely labeling the wire transaction as a consignment sale of farm equipment and similarly falsely recording the wire- transaction in the books and records of the Tractor Store, in order to conceal and . disguise the Scheme. 59. On or about the dates listed below, in Rankin and Hinds County in the Northern Divisionlof the Southern District of Mississippi, and elsewhere, the defendants, CHRISTOPHER B. EPPS and CECIL MCCRORY, for the purpose of executing the above- - I described scheme and artifice to defraud and deprive, transmitted or caused to be transmitted by means of wire communication in interstate commerce, the following writings, signals and sounds?: COUNT DATE AMOUNT PAID FOR THE BENEFIT OF EPPS 24 August 21, 2012 $34,000.00 25 September 25, 2012 . $14,000.00 26 February 14, 2013 $40,000.00 27 September 4, 2013 $50,000.00 Page 14 of 21 Case Document3 Filed 08/05/14 Page715 of21 All in violation of Sections 1343, 1346, and 2, Title 18, United States Code. COUNTS 2841 60. The allegations contained in paragraphs 1 through 59 of this indictment are I realleged and incorporated by reference as though fully set ferth herein. - 61. Title 31, United States Code, Section 5313 and the regulations promulgated thereunder require any ?nancial institution that engages in a currency transaction (6. g. adeposit or Withdrawal) in excess of $10,000 with a customer to report the transaction to the Departrhent of the Treasury-by ?ling a Currency TransaCtion Report These regulations also require that multiple transactions be treated as a single transaction if the ?nancial institution has knowledge that they are by, or on behalf of, the same person, and they resultin either currenCy received or disbursed by the ?nancial institution totaling more than $10,000 during any one business day. 62. . Currency Transaction Reports are often used by law enforcement to uncover a wide variety of illegal activities such as money laundering; Many individuals engaged in such i? illegal activities are aware of such reporting requirements and take active stepsto cause ?nancial institutions to fail to ?le CTRs, such as, for example, making multiple cash deposits ini'amountsp not more than $10,000 on the same day or on consecutive days. These active steps are often referred. to as ?structuring,? Structuring cash transactions to avoidtriggering the ?ling of a CTR by a ?nancial institution is prohibited by Section 5324(a), Title 31, United States Code. I 63. Between August 5,2009 and June 24, 2014, the defendant, CHRISTOPHER B. EPPS, deposited and caused to be deposited cash, or used cash or caused cash to be used to Page 15 of 21 Case Document 3 Filed 08/05/14 Page 16 of 21 purchase cashier?s checks, totaling almost $700,000 utilizing four bank accounts which he owned I or controlled. 64, When the deposits were made, EPPS knew of the reporting requirement for cash - transactions in excess of $10,000. To avoid having a CTR ?led, EPPS structured the cash transactions in amounts not greater than $10,000, as set forth below: 65. On or about the dates set forth below, in Rankin and Hinds Counties in the Northern Division of the Southern District of Mississippi and elsewhere, the defendant, CHRISTOPHER B. EPPS, did knowingly and for the purpose of evading the reporting requirements of Section 5313(a), Title 31, United States Code, and the regulations promulgated thereunder, structure, assist in structuring, and attempt to structure or assist in structuring the following transactions with domestic ?nancial institutions, and cause-and attempt to cause such institutions to fail to ?le Currency Transaction Reports required by Section 5313 fer currency transactions in excess of $10,000, and did so while violating another law of the United States: COUNT DATE TIME CASH TRANSACTION, AMOUNT BANK LOCATION. 28 8/6/09 12:28 - $9,000 - BankPlus Flowood, MS 12:48 .111. . $6,000 118 Jackson, MS 8:54 am. cashier?s check $9,000 BankPlus - Flowood, MS 9:24 am. cashier's check $9,000 MSPECU Jackson, MS 4/6/1 1 9/9/11 9:11 am. . cashier?s check $9,000 BankPlus Flowood, MS 9:21 am. cashier's check $9,000 'ons FloWood, MS 8:41 am. hase cashier?s check $9,000 I BankPlus Flowood, MS. - 12/16/11 9:16 am. urchase cashier's check $9,000 ons Flowood, MS - 2/3/12 . 10:15 am. cashier's check $9,500 BankPlus MS Page 16 of 21 Case Document 3 Filed 08/05/14 Page 17 of 21 3/26/12 4/26/12 6/26/12 _7/31/12 10/4/12 6/24/13 7/8/13 7/19/13 - 7/31/1-3 10:27 am. 9:24 am. 9:35 am. 9:25 am. 9:35 am 8:59 am. 9:10 am. 9:22 am. 9:37 am. 10:49 a.m. 11:03 am. 10:26 am. 10:36 am. - 8:56 am. 9:13' am- 1055 am. 11:04 21.111. 11:50 3111. 8:55 am. 9:07 am. cashier's check cashier's check cashier's check cashier's check cashier's check cashier's check cashier's check cashier's check urchase cashier's cheek cashier's check cashier's check cashier's check cashier's check 't 't cashier?s check cashier's check $7,500 $9,500 $6,000 $9,500 $9,500 $9,500 $9,500 $9,500 $7,000 $9,500 $9,500 $9,200 I $9,500 $9,500 $9,500 $8,100 $9,300 $39,500 $9,500 $9,500 'ons BankPlus 'ons BankPlus 'ons .BankPlus 'ons BankPlus . OHS BankPlus. 0118 BankPlus 'ons BankPlus OHS- BankPlus ons MSPECU Bankle 0118 Flewood,-MS . Flowood, MS MS Flowood, MS Flowood, MS Flowood, MS _Flow0.0d, MS Flow00d, MS FloWood, MS Flowood, MS. Flo'Wood, MS Flowood,_MS Flowood, MS FlowOOd, MS Flow/bod, MS Flowood, MS. Flewood, MS ackson, MS Flowood, MS Flowood, MS Allin violation of Sections 5324(a)(3) and 5324(d), Title 31, United States Code; Section 1010.100, 1010.311 and 1010.313, Title 31, Code of Federal Regulations; and Section 2, Title . - 518-, United States Code. Page 17 of21 Case Document 3 Filed 08/05/14 Page 18 of 21 COUNT 42-43 66. The allegations contained in paragraphs 1 through 65 of this indictment are realleged and incorporated by reference as though fully set forth herein. 67. On or about the dates listed below, in Rankin and Hinds County in Northern Division of the District of Mississippi, and elsewhere, the? defendant, CHRISTOPHER B. EPPS, did knowingly conduct and attempt to conduct a ?nancial transaction affecting interstate and foreign commerce, to wit, applying for and securing a loan and conducting a wire transfer, both of which involved the proceeds of a speci?ed unlawful activity, that is bribery and kickbacks from CECIL MCCRORY and others knoWn and unknown to the Grand Jury, . knowing that the transactions were designed in whole and in part to conceal and disguise, the nature, location, source, ownership, and control of the proceeds of said speci?ed unlawful activity and that while conducting and attempting to conduct such ?nancial transactions knew. that the preperty involved in the ?nancial transactions represented the proceeds of some form of unlawful activity, speci?cally: COUNT DATE TRANSACTION FINANCIAL. AMOUNT - INSTITUTION 42 November 8, 2011 Mortgage for Biloxi WellsFargo - $257,000.00 Condominium Home Mortgage 43 June 12., 2013 Wire Transfer for Pass Edward Jones $200,000.00 I Christian Condominium - All in violation of Sections 1956(a)(1)(B)(i) and 2, Title 18, United States Code. Page 18 of21 Case Document 3 Filed 08/05/14 Page 19 of 21 COUNTS 44-49 68. That on or about the dates listed below, in Rankin County in the Northern Division of the Southern District of Mississippi, and elsewhere, the defendant, CHRISTOPHER B. EPPS, a resident of Flowood, Mississippi, did willfully aid and assist in, and procure, counsel, - and advise the preparation and presentation to the Internal Revenue Service, of a US. Individual Income Tax Return, Form 1040, of CHRISTOPHER B. EPPS for the calendar years hereinafter speci?ed. The subject returns were false and fraudulent as to material matters, in that they represented that total income for EPPS and his wife on Line 22 of each individual Form 1040 was as stated below, Whereas, as the defendant then and there knew, the. correct and actual total 7 income for EPPS and his wife on Line 22 of each individual Form 1040 during the subject calendar years was actually higher as set forth below. OFFENSE COUNT TAX YEAR - TOTAL INCOME ACTUAL TOTAL DATE REPORTED INCOME 44. . March 3, 2009 2008 $205,540.00 $405,540.00 45 March 23, 201.0 2009 $206,51 1.00 $357,820.81 46 March 5, 2011 2010 $217,444.00 $249,144.00 47 March 13, 2012 2011 I $239,245.00 $276,245.00 - 48 March 12, 2013 2012 $217,109.00 I $330,109.00 . 49 _March 25, 2014 2013 $209,901.00 $386,901.00 Allin Violation of Section 7206(2), Title 26, United States Code. NOTICE OF. INTENT TO SEEK CRIMINAL FORFEITURE 69. As a result of committing the offenses as alleged in this Indictment, the defendants shall forfeit to the United States all property involved in or traceable to property involved in the offenses, including but not limited to all proceeds obtained directly or indirectly fromthe offenses, - and all property used to facilitate the offenses. Page 19 of21 Case Document 3 Filed 08/05/14 Page 20 of 21 70. . The grand jury has determined that probable'cause exists to believe that the following property is subject to forfeiture as a result of one or more of the offenses alleged in this indictment: 1) Real property located at 1100 West Beach BOulevard, Unit 304, Pass Christian, Harrison County, Mississippi, more particularly described as follows: Unit Number Three Hundred Four (304), PASS MARMNNE CONDOMINIUMS, a condominium according to the official map or plat thereof on ?le and on record in the of?ce of the Chancery Clerk of the First Judicial District of Harrison County, Mississippi, in Plat Book 50 at page 6 thereof, together with an undivided interest in and to the common elements and appurtenances thereof, as set forth in the . Declaration of Condominiums and therefore subject to that certain Declaration of Condominium recorded as Instrument 1' and corrected and re-recorded as Instrument 1 thereof; 2) Real property located at 511 Shalom Way, Flowood, Rankin County, Mississippi more particularly described as: LOT 22, LINEAGE LAKE OF LAKELAND, PART 1 AMENDED, a . subdivision according to the map or plat thereof on ?le and of record in the office of the Chancery Clerk of Rankin County at Brandon, Mississippi in Plat Cabinet at Slots 44, 45 and 46, reference to which map or plat lS hereby made in aid of and as a part of this description. - - TOGETHER WITH: an easement for ingress and egress and regress over all private streets and right-of-ways by virtue of Article Section 8.1, 8.2 and 8.7 of the covenants as recorded in Book 1042 at Page 490; 3) All funds on deposit in Edward Jones account nmnbered 4) All funds on deposit in Edward Jones account numbered 1-1-6; 5) All funds on deposit in Regions Bank account? numbered 6) All funds on deposit in Regions Bank account numbered 7) All funds on deposit in Bank Plus account numbered All funds on deposit in Mississippi Public Employees Credit Union account Page. 20 of 21 Case Document3 Filed 08/05/14 Page 21 of 21 numbered One (1) 2010 Mercedes Benz 8550, VIN: and 10) One (1) 2007 Mercedes Benz S65 V12 AMG, VIN: 800. Further, if any property described above, as a result of any act or omission of the defendants: I cannot be located upon the exercise of due diligence; has been transferred or soldito, or deposited. I with, a third party; has been placed beyond the jurisdiction of the Court; has been substantially" diminished in value; or has been commingled with other prioperty, which cannot be divided without dif?culty, then it is the intent of the United States to seek a judgment of forfeiture of any other property of the defendants, up to the value of the property described in this notice or any bill of I particulars supporting it. I All pursuant to Section 981(a)(1)(A) (C), Title 18, United States Code, Section - Title 18, United States Code, Section Title 26, United States Code, Section 7303, Title 26, United States Code and Section 53 Title 31, United States Code. 0L H. BRITTAIN Attorney for the United States, Acting Under Authority Conferred by 28 U.S.C. 515 A TRUE BILL: SIGNATURE REDACTED Foreperson of the Grand Jury . This indictment was returned in open court by the foreperson or deputy foreperson of the grand Jury on this the day of August, 2014. an UNITED STATES MAGISTRATE JUDGE Page 21 of21