Case: 3:19-cr-00078-TMR Doc #: 3 Filed: 04/25/19 Page: 1 of 6 PAGEID #: 9 3:19-cr-78 Judge Thomas M. Rose Case: Doc 3 Filed: 04/25/19 Page: 2 of 6 PAGEID 10 Commission exerted considerable influence over, and had the ability to approve, the awarding of certain contracts by the City of Dayton and its various component units. 3. According to publicly available information including audit records CityWide Development Corporation (?CityWide?) was a non?profit organization that functioned as a development and financing arm of the City of Dayton. Given this relationship between these two entities, CityWide was a component unit of the City of Dayton. In its financing and development capacity, CityWide routinely awarded thousands of dollars in contracts to private companies for the demolition of certain homes within the limits of the City of Dayton. 4. From in or around 2001 through in or around February 2018, defendant JOEY D. WILLIAMS served as an elected commissioner of the City of Dayton. Through his position, defendant JOEY D. WILLIAMS had the ability to exert influence and control over City of Dayton business, including matters relating to the awarding of contracts by its various component units, including CityWide. 5. A person identified herein as Individual A operated businesses in southern Ohio that sought to obtain contracts with the City of Dayton. Individual A?s businesses had the ability Page 2 of 6 Case: Doc 3 Filed: 04/25/19 Page: 3 of 6 PAGEID 11 to provide a variety of services, including the completion of home improvement and construction projects. II. THE CORRUPT SOLICITATION, DEMAND AND ACCEPTANCE OF A THING OF VALUE INTENDING TO BE INFLUENCED AND REWARDED AS WELL AS THE EXECUTION OF THIS SCHEME 6. Between on or about January 31, 2015 and on or about December 31, 2015, in the Southern District of Ohio, defendant JOEY D. WILLIAMS corruptly solicited, demanded, accepted and agreed to accept a thing of value involving $5,000 or more during that one year period intending to be influenced and rewarded in connection with a transaction and series of transactions of the City of Dayton involving $5,000 or more. 7. During early 2015, defendant JOEY D. WILLIAMS and Individual A had discussions concerning difficulties Individual A confronted obtaining contracts or other work with the City of Dayton. Contemporaneous with these conversations, defendant JOEY D. WILLIAMS indicated that he had a construction project that he hoped to complete at his personal residence. As their conversations progressed, Individual A offered to complete this construction project at defendant JOEY D. home for a substantially discounted price. Defendant JOEY D. WILLIAMS accepted this offer, understanding that, in return for these discounted services, Individual A anticipated that defendant Page 3 of 6 Case: Doc 3 Filed: 04/25/19 Page: 4 of 6 PAGEID 12 JOEY D. WILLIAMS would use his position with the City of Dayton to take official acts to influence and otherwise impact the awarding of city contracts to one of Individual A?s businesses. 8. Based, at least in part, on the significant free benefits that Individual A had provided to him, defendant JOEY D. WILLIAMS took official acts, intervening on behalf of Individual A with the City of Dayton. For instance, defendant JOEY D. WILLIAMS exerted influence with City of Dayton employees as well as its affiliated entities, causing them to award contracts both from CityWide and the City of Dayton totaling in excess of $150,000 to one of Individual A?s businesses. 9. While intending to be rewarded and influenced, at least in part, in taking these actions on behalf of Individual A, defendant JOEY D. WILLIAMS continued to improperly solicit, demand and accept additional substantial things of value from Individual A including further construction work. In this manner, defendant JOEY D. WILLIAMS accepted from Individual A over $50,000 in free benefits, including cash payments as well as the construction of a patio at his home. 10. Throughout this time, defendant JOEY D. WILLIAMS engaged in a pattern of activity to conceal and otherwise hide not only his corrupt intentions but also the things of value Page 4 of 6 Case: Doc 3 Filed: 04/25/19 Page: 5 of 6 PAGEID 13 that he had received from Individual A. For instance, defendant JOEY D. WILLIAMS demanded that Individual A provide a fraudulent invoice, falsely reflecting that defendant JOEY D. WILLIAMS personally had paid Individual A over $50,000 for the home improvement project. Similarly, defendant JOEY D. WILLIAMS sought and received thousands of dollars in cash from Individual defendant JOEY D. WILLIAMS then used this money to personally pay subcontractors who had performed work on his home improvement project. Defendant JOEY D. WILLIAMS engaged in these actions to create the false appearance that he, in fact, had paid for his construction project and to conceal that he had corruptly and improperly demanded, accepted and agreed to accept Page 5 of 6 Case: Doc 3 Filed: 04/25/19 Page: 6 of 6 PAGEID 14 a thing of value involving $5,000 or more during that one year period intending to be influenced and rewarded in connection with a transaction and series of transactions of the City of Dayton involving $5,000 or more. In violation of Title 18, United States Coder Section A TRUE BILL Foregerson BENJAMIN C. GLASSMAN United States Attorney BRENT G. TABACCHI Assistant United States Attorney Page 6 of 6