Case 1:19-cr-10079-RWZ Document 1 Filed 03/05/19 Page 1 of 6

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

Criminal No

UNITED STATES OF AMERICA

\(\(^ \00'Vi ^

Violation:
V.

Count One: Racketeering Conspiracy
(18 U.S.C. § 1962(d))

JOHNVANDEMOER,
Defendant.

INFORMATION

At all times relevant to this Information:

General Allegations

1.

Defendant JOHN VANDEMOER ("VANDEMOER") was a resident of Palo Alto,

California. VANDEMOER was employed as the sailing coach at Stanford University.

2.

Stanford University ("Stanford") is a highly selective private university located in

Palo Alto, California. The university's athletic teams compete in most sports at the Division I level,
the highest level.of intercollegiate athletics sanctioned by the National Collegiate Athletic
Association ("NCAA").

3.

Like many universities, Stanford recruits student athletes, and may apply different

criteria when evaluating applications from students with demonstrated athletic abilities. The
Stanford admissions office typically allocates a number of admissions slots to the Stanford
athletics department, which in turn allocates those slots among the head coaches of varsity sports

for recruiting purposes. The admissions prospects of recruited athletes are higher than those of
non-recruited athletes with similar grades and standardized test scores.

 Case 1:19-cr-10079-RWZ Document 1 Filed 03/05/19 Page 2 of 6

The Enterprise

4.

The Edge College & Career Network, LLC, also known as "The Key," was a for-

profit college counseling and preparation business in Newport Beach, California, founded by
William Rick Singer in or about 2007 and incorporated in the State of California in or about 2012.
5.

The Key Worldwide Foundation ("KWF") was a non-profit corporation in

Newport Beach, California that Singer established as a purported charity in or about 2012. In or
about 2013, the Intemal Revenue Service ("IRS") approved KWF as an exempt organization
under Section 501(c)(3) of the Intemal Revenue Code, meaning that KWF was exempt from
paying federal income tax. KWF maintained several bank accounts (collectively, the "KWF
charitable accounts").

6.

Together, The Key and KWF constituted an "enterprise" as defined by Title 18,

United States Code, Section 1961(4) (the "Key Enterprise"), that is, an association in fact of

entities engaged in, and the activities of which affected, interstate and foreign commerce ("the
enterprise"). The Key Enterprise constituted an ongoing organization whose members functioned
as a continuing unit for a common purpose of achieving the objectives of the enterprise.
Purposes of the Racketeering Conspiracv

7.

The principal purposes of the racketeering conspiracy included the following:
a.

to facilitate the admission of students to elite universities, including

Stanford, as recmited athletes, regardless of their athletic abilities; and
b.

to enrich Singer and his co-conspirators personally, and to secure

additional funding for athletic programs controlled by individual coaches, including the Stanford
sailing program controlled by VANDEMOER.

 Case 1:19-cr-10079-RWZ Document 1 Filed 03/05/19 Page 3 of 6

Manner and Means of the Racketeering Conspiracy

8.

Among the manner and means by which the VANDEMOER, Singer, and others

known and unknown to the United States Attorney carried out the racketeering conspiracy were
the following:

a.

designating applicants as purported recruits for competitive college athletic

teams, including the Stanford sailing team, without regard for the applicants' athletic abilities, in
exchange for bribes; and

b.

concealing the nature and source of the bribe payments by funneling

payments through the KWF charitable accounts.
Acts in Furtherance of the Racketeering Conspiracy

9.

In or about the summer of 2017, VANDEMOER agreed to designate the child of

one of Singer's clients ("Stanford Applicant 1") as a recruit for the Stanford sailing team, in
exchange for a payment to Stanford sailing.

10.

In support of the student's application. Singer's associate created a student-athlete

"profile" that was sent electronically to Stanford, and that falsely suggested that Stanford
Applicant 1 was a competitive sailor.
11.

In or about May 2018, after Stanford Applicant 1 deferred his application to

Stanford for one year. Singer mailed a payment of $110,000 from one of the KWF charitable
accounts to the Stanford sailing program in exchange for VANDEMOER's agreement to designate

Stanford Applicant 1 as a sailing recruit in the following year's recruitment cycle.
12.

In or about the summer of 2018, after Stanford Applicant 1 decided to attend a

different university, VANDEMOER agreed with Singer to use that same recruiting spot for the

 Case 1:19-cr-10079-RWZ Document 1 Filed 03/05/19 Page 4 of 6

child of another one of Singer's clients ("Stanford Applicant 2"), in exchange for a $500,000
payment to the Stanford sailing program.

13.

In support of the student's application, Singer, together with others, created

documents falsely indicating that Stanford Applicant 2 was a competitive sailor, although the
student in fact had minimal sailing experience.

14.

Although Stanford Applicant 2 ultimately did not apply to Stanford, Singer mailed

a pajmient of $160,000 j&om one of the KWF charitable accounts to the Stanford sailing program.
15.

VANDEMOER agreed with Singer that the payment would serve as a "deposit" for

a future student's purported recruitment.

 Case 1:19-cr-10079-RWZ Document 1 Filed 03/05/19 Page 5 of 6

COUNT ONE

Racketeering Conspiracy
(18U.S.C.§ 1962(d))
The United States Attorney charges:

16.

The United States Attorney re-alleges and incorporates by reference paragraphs 1-

15 of this Information.

17.

From in or about 2016, and continuing through February 2019, in the District of

Massachusetts and elsewhere, the defendant,
JOHN VANDEMOER,

being a person associated with The Key Enterprise, an enterprise engaged in, and the activities of
which affected interstate and foreign commerce, conspired with others known and unknown to the
United States Attorney to violate Title 18, United States Code, Section 1962(c), that is, to conduct

and participate, directly and indirectly, in the conduct of the affairs of the enterprise through a

pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and
(5).

18.

The pattern ofracketeering activity referenced above, as defined by Title 18, United

States Code, Sections 1961(1) and (5), consisted of multiple acts indictable under:

a. Title 18, United States Code, Section 1341 (relating to mail fraud);
b. Title 18, United States Code, Sections 1341 and 1346 (relating to honest
services mail fraud);
c. Title 18, United States Code, Section 1343 (relating to wire fraud);
d. Title 18, United States Code, Sections 1343 and 1346 (relating to honest
services wire fraud); and
e. Title 18, United States Code, Section 1956 (laundering of monetary
instruments).

 Case 1:19-cr-10079-RWZ Document 1 Filed 03/05/19 Page 6 of 6

19.

It was part of the conspiracy that VANDEMOER agreed that a conspirator would

commit at least two acts of racketeering activity in the conduct of the affairs of the enterprise.
All in violation of Title 18, United States Code, Section 1962(d).

ANDREW E. TELLING
UNITED STATES ATTORNEY

By:

JVC
ERIC
Sc S. ROSEN
JUSTIN D. O'CONNELL
KRISTEN A. KEARNEY
LESLIE A. WRIGHT

Assistant U.S. Attorneys
Date: March 5,2019

 Case 1:19-cr-10079-RWZ Document 1-1 Filed 03/05/19 Page 1 of 2
«feJS 45 (5/97) - (Revised U.S.D.C. MA 3/25/2011)

U.S. District Court - District of Massachusetts

Criminal Case Cover Sheet

City

Boston

County

Investigating Agency

Category No.

Place of Offense:

™

Related Case Information:

Superseding Ind./ Inf.
Same
ocuiiv. Defendant
Magistrate Judge Case Number

Middlesex

Search Warrant Case Number
R 20/R 40 from District of

Case No.

I^OrlOO^

New Defendant X
See additional information

Defendant Information:

Defendzint Name John Vandemoer

Juvenile:

Is this person an attorney and/or amember ofany state/federal bar:

•

Yes

No

•

Yes 0 No

Alias Name
rCitv&State^ Stanford, CA

Address

Birth date (Yr only):

SSN (Iast4#):_7j06__ Sex M

Defense Counsel if known:

Nationality: USA

Race: White

Robert Fisher, Esq.

Address Nixon Peabody

trt

53 State Street

Bar Number

Boston, MA 02109-2835

U.S. Attorney Information:

AUSA

BarNumber if applicable

Eric S. Rosen

Interpreter:

Victims:

Yes

No

NY4412326

List language and/or dialect:

f^Yes • No Ifyes, are there multiple crime victims under 18 USC§3771(d)(2)

Matter to be SEALED:

\7\ Yes

•

\ [warrant Requested

Yes • no

No
Regular Process

In Custody

Location Status:

Arrest Date

[^Already in Federal Custody as of
n Already in State Custody at
I IOn Pretrial Release: Ordered by:

in

I [Serving Sentence

  [^waiting Trial

on

Charging Document:

I IComplaint

[^Information

• Indictment

Total # of Counts:

I IPetty

I IMisdemeanor

[71 Felony —

Continue on Page 2 for Entry of U.S.C. Citations

0

I hereby certify
thatabove.
the case numbers of any prior pjfoceeAngs
accurately
set forth
11 fj. before a Magistrate Judge

Date:

March 5, 2019

Signature of AUSA:

are

 Case 1:19-cr-10079-RWZ Document 1-1 Filed 03/05/19 Page 2 of 2
JS 45 (5/97) (Revised U.S.D.C. MA 12/7/05)Page 2 of 2 or Reverse

District Court Case Number (To be filled in by deputy clerk):
Name of Defendant

John Vandemoer
U.S.C. Citations

Index Kev/Code

Setl

Description of Offense Charged

Conspiracy to Commit RICO

18USC 1962(d)

^

^

Count Numbers

1

Forfeiture

Set 2

18use 1963

1

Set 3

Set 4

Set 5

Set 6

Set?

Set 8

Set 9

Set 10

Set 11

Set 12

Set 13

Set 14

Set 15

ADDITIGNAL INFORMATION:

18-6218-MPK, 18-6237-MPK, 18-6236-MPK, 18-6234-MPK, 18-6238-MPK

18-6235-MPK. 18-6476-MPK, 18-6477-MPK, 18-6475-MPK. 18-6478-MPK, 18-6261-MPK, 18-6260-MPK
19-6003-MPK, 19-6005-MPK, 19-6004-MPK, 19-6006-MPK. 18-6240-MPK, 18-6310-MPK. 18-6474-MPK. 18-6474-MPK

18-7227-MPK, 19-6029-MPK, 19-6030-MPK
USAMA CRIM- Criminal Case Cover Sheet.pdf 3/4/2013