Case ECF No. 1 filed 12/18/19 PageID.1 Page 1 of 37 37 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION Case22: 1 9-cr-20836 UNITED STATES OF AMERICA, V. Filed: 12?18-2019At 11:06 AM USA SEALED MATTER (LG) D-l RICHARD SOLLARS, VIOLATIONS: D-2 SHADY AWAD, and 18 U.S.C. 371 (Conspiracy) D-3 JEFFREY BAUM, 18 U.S.C. 666(a) (Bribery) 18 U.S.C. 1343 (Wire Fraud) Defendants. INDICTMENT The Grand Jury charges: GENERAL ALLEGATIONS At all times relevant to this indictment: 1. Defendant RICHARD SOLLARS was the elected Mayor of the City of Taylor, Michigan (?Taylor?), a local government entity that received federal assistance in excess of $10,000 in each of the calendar years 2015 through 2019. 2. Beginning in 2015, the City of Taylor began a program. known as the Right of First Refusal program program?). Under the program, Taylor would exercise its right of ?rst refusal to acquire tax-foreclosed properties in its city from the Wayne County Treasurer?s Of?ce. Then, Taylor would select one or more developers to acquire, redevelop and resell the tax-foreclosed properties, which consisted of single family homes, as well as commercial and vacant properties. 1 Case ECF No. 1 filed 12/18/19 PageID.2 Page 2 of 37 Taylor would enter into agreements with the developers, which required them to pay Taylor?s purchase price for the properties, rehabilitate the properties and pay all fees associated with rehabilitation. After the developers ful?lled their obligations under the agreement, Taylor would issue a certi?cate of occupancy and transfer ownership of the properties to the developers. RICHARD SOLLARS had considerable control and in?uence over the ROFR program, including the decision of which developers were selected to participate. 3. RICHARD SOLLARS operated a political campaign ?ind entitled ?Committee to Elect Richard (Rick) Sollars, Jr.? (?the campaign fund?). 4. SHADY AWAD was a businessman who owned a property development company called Realty Transition, LLC (?Realty Transition?). AWAD also owned a company called Downriver Management, LLC. 5. JEFFREY BAUM was an employee of Taylor who served as the manager of Taylor?s Community Development Department. As manager of the Community Development Department, BAUM managed the ROFR Program. BAUM also served as the treasurer of campaign fund. 6. In each year between 2015 and 2019, SHADY company, Realty Transition, was selected by RICHARD SOLLARS to develop the vast majority of the tax?foreclosed properties in the City?s ROFR program. In 2015, Realty Transition was awarded the right to develop all 95 of Taylor?s tax-foreclosed Case ECF No. 1 filed 12/18/19 PageID.3 Page 3 of 37 properties. In 2016, Realty Transition received 29 of Taylor?s 34 tax?foreclosed properties. In 2017, Realty Transition received 38 of Taylor?s 45 tax-foreclosed properties. In 2018, Realty Transition received Taylor?s entire tax?foreclosed property inventory, totaling 37 properties. (18 U.S.C. 371 666(3) Conspiracy to Commit Bribery Concerning Programs Receiving Federal Funds) D-l RICHARD SOLLARS D-2 SHADY AWAD D-3 JEFFREY BAUM 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count One as if fully set forth herein. 2. From in or about June 2015, through in or about February 2019, in the Eastern District of Michigan, Southern Division, and elsewhere, defendants RICHARD SOLLARS, SHADY AWAD, and JEFFREY BAUM did unlawfully, willfully, and knowingly combine, conspire, confederate, and agree with each other, and others, to corruptly solicit and demand for the bene?t of any person, and accept and agree to accept, over $30,000 in renovations to home, over $1 1,000 in renovations to lake house, over $12,000 worth of household appliances and cabinets, cash, and other items of value, with the intent to in?uence and reward SOLLARS and BAUM in connection with a business, transaction, or 3 Case ECF No. 1 filed 12/18/19 PageID.4 Page 4 of 37 series of transactions of the City of Taylor involving $5,000 or more, in violation of Title 18, United States Code, Section 666(a). MANNER AND MEANS BY WHICH THE CONSPIRACY WAS CARRIED OUT 3. It was part of the conspiracy that, in exchange for items of value, RICHARD SOLLARS and JEFFREY BAUM would assist SHADY AWAD and other developers in obtaining properties owned by Taylor in connection with the City?s ROFR program. 4. It was further part of the conspiracy that SHADY AWAD would reward RICHARD SOLLARS for assistance in obtaining properties under the ROFR program by providing SOLLARS with free renovations at his home and lake house that included installing hardwood ?oors, garage doors, front doors, and a garage storage unit. AWAD also re?nished a deck at lake house and provided SOLLARS with a humidor, a refrigerator, a double oven with a gas range, a microwave, a dishwasher, a washer and dryer, a vacuum cleaner and metal storage cabinets. 5. It was further part of the conspiracy that SHADY AWAD would provide items of value to JEFFREY BAUM to in?uence and reward BAUM for assistance in obtaining properties under the ROFR program. I 6. It was further part of the conspiracy that JEFFREY BAUM, with the Case ECF No. 1 filed 12/18/19 PageID.5 Page 5 of 37 assistance and approval of RICHARD SOLLARS, would accept thousands of dollars in cash from Developer A, in exchange for providing Developer A properties under the ROFR program. 7. It was further part of the conspiracy that JEFFREY BAUM would direct public of?cials at the City of Taylor to dismiss tickets charging civil infractions that had been issued by the City against Realty Transition and SHADY AWAD. 8. . Between 2016 and 2018, RICHARD SOLLARS used his in?uence as a public of?cial to persuade public of?cials in nearby cities to aWard Realty Transition tax-foreclosed properties for SHADY AWAD to rehabilitate. 9. Between 2017 and 2019, RICHARD SOLLARS directed SHADY AWAD to provide credit card information to DeveloperA, who was interested in acquiring tax-foreclosed properties under the City?s ROF program. Developer A also owned a market in the City of Taylor. SOLLARS then directed Developer A to charge various amounts to credit card. At direction, Developer A gave SOLLARS cash in the amounts Developer A charged to credit card. Cash SOLLARS obtained from Developer A ?om charges to credit card totaled over $19,000. 1 Case ECF No. 1 filed 12/18/19 PageID.6 Page 6 of 37 10. In 2017 and 2018, RICHARD SOLLARS went on trips to Las Vegas with SHADY AWAD and, during those trips, accepted thousands of dollars in cash from AWAD. OVERT ACTS 11. In furtherance of the unlawful conspiracy, and to effect its objectives, the defendants and their co-conspirators committed the following overt acts, among others, in the Eastern District of Michigan and elsewhere. 12. On or about July 20, 2015, without a legitimate bid process, RICHARD SOLLARS recommended to the Taylor City Council that SHADY company Realty Transition be awarded all of the tax-foreclosed properties that Taylor had or would acquire under its ROFR Program. 13. In or about July 2015, at the direction of RICHARD SOLLARS, Reality Transition was awarded all 95 tax-foreclosed properties in Taylor?s ROFR Program. 14. On June 10, 2016, SHADY AWAD exchanged text messages with RICHARD SOLLARS regarding AWAD having Contractor A replace the hardwood ?ooring on the second level of home. AWAD told SOLLARS that Contractor A ?3 work was ?amazing,? and joked that ?[t]he price will be even better than the work.? SHADY AWAD ended the text message with a smiley face emoji with a winking eye. Case ECF No. 1 filed 12/18/19 PageID.7 Page 7 of 37 15. On August 8, 2016, SHADY AWAD texted RICHARD SOLLARS asking if AWAD could send ?guys? to house to ?clear out upstairs to clear out ?lrniture and carpet.? AWAD wrote, ?[h]ardwood starting tomorrow morning is that SOLLARS responded, ?That works.? 16. Between August 12, 2016, and August 26, 2016, at SHADY direction, Contractor A installed hardwood on the ?oor of the entire second level of RICHARD home. 17. On or about August 12, 2016, SHADY AWAD caused a Realty Transition check in the amount of $1,700 to be issued to Contractor A to pay for the hardwood ?ooring on the second level of RICHARD home. 18. On August 16, 2016, at the direction of RICHARD SOLLARS, Realty Transition was awarded 29 of the 34 tax-foreclosed properties in Taylor?s ROFR Program. 19. On or about August 26, 2016, SHADY AWAD caused a check from Realty Transition, in the amount of $1,200 to be issued to Contractor A to pay for the hardwood ?ooring on the second level of RICHARD home. 20. In August 2016, SHADY AWAD supplied hardwood ?ooring to Contractor A for installation on the second level of RICHARD home. 21. On September 26, 2016, JEFFREY BAUM texted RICHARD SOLLARS about a wooden cigar humidor costing over $1,600 that had been Case ECF No. 1 filed 12/18/19 PageID.8 Page 8 of 37 purchased by SHADY AWAD for SOLLARS. In the text, BAUM told SOLLARS ?Your humidor has shipped. 5-7 business days, 210 for He will be whining about every fee for the next six months.? 22. On September 26, 2016, RICHARD SOLLARS texted SHADY AWAD, asking him whether the humidor included Cuban cigars. One minute later, SOLLARS texted JEFFREY BAUM, stating, ?He will be calling you in a panic. I just asked him when the Cuban cigars to ?ll it will be arriving.? 23. On October 13, 2016, SHADY AWAD texted RICHARD SOLLARS, letting him know that the humidor that AWAD had purchased for SOLLARS was shipping that day. 24. In or about 2017, JEFFREY BAUM met with Developer A at DeveIOper A?s market and transferred two of Taylor?s tax-foreclosed properties to Developer A. Around that same time in 2017, Developer A paid BAUM a $1,000 cash kickback. 25. On April 19, 2017, SHADY AWAD directed Contractor A to meet with RICHARD SOLLARS to discuss installing hardwood ?oors at lake house. 26. On May 19, 2017, RICHARD SOLLARS complained to SHADY AWAD about the delay in Contractor A ?s completion of the hardwood ?ooring at lake house, stating ?The Friday of Memorial Day weekend? I though Case ECF No. 1 filed 12/18/19 PageID.9 Page 9 of 37 (sic) he said 4-5 days?? We have a ton of people coming over that weekend.? After receiving that message, AWAD contacted Contractor A and asked, ?how many days left at Rick?s just wondering.? Contractor A responded that the lake house ?ooring would probably be completed by the end of the week. 27. On May 23, 2017, Contractor A texted SHADY AWAD a photograph of the hardwood ?ooring Contractor A had installed at RICHARD lake house, with a caption little sneak peek for Rick.? 28. On May 26, 2017, Contractor A and SHADY AWAD had a text discussion about payment for installing the hardwood ?ooring at RICHARD lake house. Contractor A inquired whether AWAD was still at his of?ce and told AWAD, ?Got a key and the bill for you. Ricks total $6962.00.? AWAD responded with several sad face emojis and wrote, ?And we pay it in two weeks.? Contractor A responded ?Don?t have to give it all right now, but de?nitely need to pick up good portion to pay all the guys today if possible?? AWAD told Contractor A, ?Of course stop on in.? 29. On or about May 26, 2017, SHADY AWAD issued a check from his company Downriver Management in the amount of $4,000 to Contractor A as partial payment for the hardwood ?ooring installed in RICHARD lake house. The memo line of the check concealed lake house address, instead listing the address of one of properties. Case ECF No. 1 filed 12/18/19 Page 10 of 37 30. On or about June 2, 2017, SHADY AWAD issued a check from his Downriver Management account in the amount of $3,000 to Contractor A as the ?nal payment for the hardwood installed at RICHARD lake house. The memo line of the June 2, 2017 check listed an address for property owned by AWAD, stating, ?9855 Mortonview Mr. Hardwood Special.? 31. On April 26, 2017, RICHARD SOLLARS and SHADY AWAD exchanged text messages regarding prices for kitchen appliances from ABC Warehouse for home. AWAD texted SOLLARS a list of model numbers and individual prices for a refrigerator, stove, microwave oven and dishwasher. 32. On or about June 6, 2017, using his ABC Warehouse corporate account, SHADY AWAD ordered a refrigerator, stove, microwave oven and dishwasher-for RICHARD home. AWAD originally directed ABC Warehouse to deliver the appliances to ?9855 Mortonview,? but later changed the delivery address to home address. 33. On June 6, 2017, SHADY AWAD caused the kitchen appliances listed above to be delivered and installed in RICHARD home. The invoice for the appliances was issued in the name of PROPERTY for an amount of $5,300. 10 Case ECF No. 1 filed 12/18/19 PageID.11 Page 11 of 37 34. On July 17, 2017, SHADY AWAD contacted Contractor A to discuss re?nishing the deck at RICHARDS lake house. AWAD texted Contractor A, ?Ricks house this week you take care of deck pls.? After Contractor A responded that he was ?trying,? AWAD responded, ?Pls very important.? Approximately one hour later, AWAD texted Contractor A, ?Mayor house sir,? to which Contractor A responded, ?On it.? AWAD added ?Ok know how he is.? 35. On July 18, 2017, at the direction of RICHARD SOLLARS, Realty Transition was awarded 38 of approximately 43 of Taylor?s tax-foreclosed properties in the ROFR Program. 36. On July 20, 2017, SHADY AWAD texted Contractor A, ?Any news on ricks deck.? Contractor A responded that his worker said he would be out there and that he would check. A few minutes later, RICHARD SOLLARS and AWAD texted each other about the work on lake house deck. SOLLARS: I just left and not a sole in sight. They haven?t even been there to power wash. I am now going to run into a huge scheduling con?ict. AWAD: when is the deal line Sorry let me know the deadline I?ll go out there if I have 2. A few minutes later, Contractor A noti?ed SHADY AWAD that he and his workers were going to begin work on the deck at RICHARD lake house the following day. 11 Case ECF No. 1 filed 12/18/19 PageID.12 Page 12 of 37 37. Later on July 20, 2017, RICHARDS SOLLARS expressed his frustration about the delay in the deck work at his lake house to SHADY AWAD in a text message exchange. 38. Following the message of frustration from RICHARD SOLLARS, SHADY AWAD pleaded with Contractor A, ?Pls [Contractor I?ll pay whatever Stay on [the worker building the deck] thanks My relationship with Rick is worth $1 million so whatever it takes I?ll pay for it.? (emphasis added). 39. On July 22, 2017, SHADY AWAD told RICHARD SOLLARS in text messages that he planned to do a better job managing the contractor working on his lake house deck. AWAD texted, ?if I could pay a million bucks to have it [the deck] done know I would I?m really upset about this and I?m gonna stay on the sky until the job is done.? One minute later, SHADY AWAD texted Contractor A stating, would rather pay twice just to make. . .Rick happy please please please power wash stain it [the deck] away.? 40. On August 1, 2017, Contractor A and SHADY AWAD texted about payment for re?nishing the deck at lake house. Contractor A told AWAD, ?Total bill $2900, but I?ll take care of $900, towards what I owe for the wood, so just remaining $2000.? AWAD responded, ?love stop by anytime Contractor A asked how he should bill the work on deck. AWAD 12 Case ECF No. 1 filed 12/18/19 PageID.13 Page 13 of 37 texted, ?6944 Mcguire,? which is the address of a house that AWAD owned through the ROFR Program. 41. Between August 1, 2017 and August 10, 2017, RICHARD SOLLARS and SHADY AWAD exchanged several text messages about the deck work. SOLLARS: I will need them not to show up in the am. I need to accept a delivery in the basement. Honestly, if they don?t want to ?nish tomorrow, I may just need to ?nish it myself. There (sic) schedule is becoming really tough to work around. They are making a small job dif?cult. AWAD: Please let them ?nish. I cash them out today top dollar they promised it?s gonna look immaculate They are so close from (sic) completion [Contractor is a cluster fuck but his end product is usually very good.? SOLLARS: We are getting a desk delivered between 830 and 1030 tomorrow morning. They can come anytime after 1030. I have honestly never seen such a small task become such a big project. They have had one guy and I swear to you the only thing he did was the railing today. AWAD: Rick I apologize for everything I don?t know what to say they charged me $3500 I told them to do the best job and cost is irrelevant don?t know if [Contractor left comfortable but he has a clean heart just a cluster fuck. I would pay any amount of money to ?x the situation I truly apologize. 42. On August 11, 2017. SHADY AWAD issued a check to Contractor A in the amount of $7,900, of which $2,900 was payment for work on the deck at RICHARD lake house. 13 Case ECF No. 1 filed 12/18/19 PageID.14 Page 14 of 37 43. On or about August 21, 2017, in order to avoid detection of their illegal activities, RICHARD SOLLARS and SHADY AWAD began using an app called WhatsApp to send messages. SOLLARS sent AWAD a message using WhatsApp that stated, ?Test.? AWAD responded, ?Perfect. . .Best way to talk and text thx.? Following that, RICHARD SOLLARS and SHADY AWAD engaged in the following text message conversation using WhatsApp messaging: SOLLARS: Cool Let me know when you talk to him [Contractor AWAD: No ?lter, If your pissed yell at me it helps me improve and get better. SOLLARS: I won?t get pissed as long as [Contractor A ?s deck worker] doesn?t come over. . .Meet me at Bigby tomorrow am for a quick 5 min around 8:30 if you can AWAD: 0k This app is completely private SOLLARS: Easier to discuss than text. It will be quick and painless I AWAD: I?ll be there 44. In or about October 2017, while in Las Vegas, Nevada, SHADY AWAD gave RICHARD SOLLARS at least $4,000 in cash so that SOLLARS could gamble. AWAD called the money a ?care package.? 45. In or about September 2017, SHADY AWAD directed ContractorA to install additional hardwood ?ooring in RICHARD home and provided wife?s contact information to coordinate the installation. 14 Case ECF No. 1 filed 12/18/19 PageID.15 Page 15 of 37 46. On November 10, 2017, SHADY AWAD texted Contractor A and asked, ?Did ?oors arrive for rick Contractor A advised AWAD that the wood had arrived and that he had already con?rmed with RICHARD wife to install the floors on Monday of the following week. 47. On November 21, 2017, Contractor A installed hardwood ?ooring over the entire basement ?oor at RICHARD home. Later, Contractor A contacted SHADY AWAD about payment. In order to conceal his illegal activities, AWAD told ContractorA to bill the job to property at 9855 Mortonview. 48. On November 22, 2017, Contractor A texted SHADY AWAD, ?Cool to grab a check shortly? Should I head over to the of?ce?? AWAD told Contractor A he could, but when Contractor A arrived there he texted AWAD again to let him know no one was at his of?ce and that ?Total owed $4550. Need as close to three as possible.? 49. On Nevember 22, 2017, SHADY AWAD issued a check from his Realty Transition account to Contractor A in the amount of $4,550. Included on the memo line was the address ?9855 Mortonview.? The money was payment for the hardwood ?ooring installed in basement. 50. On December 23, 2017, RICHARD SOLLARS wished SHADY AWAD a ?very merry Christmas? and texted, ?let?s hook up next week when you 15 Case ECF No. 1 filed 12/18/19 PageID.16 Page 16 of 37 get back.? AWAD responded, ?Thx for everything [Really Transition silent partner.? (emphasis added). 51. In or about December 2017, Developer A gave JEFFREY BAUM three $250 gift cards. 52. On March 5, 2018, SHADY AWAD advised RICHARD SOLLARS Warehouse] said it?s special order next week should be in.? 53. On April 26, 2018, SHADY AWAD purchased a washer and dryer for RICHARD SOLLARS, along with warranties, totaling $3,678.65. 54. On July 17, 2018, at the direction of RICHARD SOLLARS, Realty Transition was awarded all 37 of the City?s tax-foreclosed properties in the ROFR Program. 55. In or about July 2018, Developer A, with the knowledge and approval of RICHARD SOLLARS, gave JEFFREY BAUM approximately $4,500 in cash, to reward BAUM for helping Developer A obtain nine properties from the ROFR Program. 56. In or about July 2018, RICHARD SOLLARS told Developer A not to ?spoil? JEFFREY BAUM by paying him too large of kickbacks related to the properties Developer A received from the ROFR program. 57. On September 19, 2018, SHADY AWAD directed ContractorA to call RICHARD wife. 16' Case ECF No. 1 filed 12/18/19 PageID.17 Page 17 of 37 58. On September 21, 2018, SHADY AWAD urged ContractorA to install additional hardwood ?ooring in home, texting, ?Pls get ?oor over there we have to ?nish it and start rick Monday it?s urgent thx.? 5 9. On or about October 2, 2018, Contractor A installed hardwood ?ooring in two rooms on the main level of RICHARD home. 60. On October 12, 2018, Contractor A texted SHADY AWAD about payment for the hardwood ?ooring, telling AWAD he owed Contractor A, ?$2,500 total, for Ricks.? 61. On or about October 12, 2018, SHADY AWAD issued Contractor A a check from his Downriver Management company in the amount of $2,500 to pay for hardwood ?ooring. 62. In or about December 2018, Developer A again gave JEFFREY BAUM three $250 gift cards. 63. On or about December 24, 2018, Developer A gave JEFFREY BAUM $500 in cash. All in violation of Title 18, United States Code, Sections 371 and 666(a). 17 Case ECF No. 1 filed 12/18/19 PageID.18 Page 18 of 37 COUNT TWO (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-l RICHARD SOLLARS Paragraphs 1 through 6 of the General Allegations are hereby re?alleged and incorporated by reference in Count Two as if fully set forth herein. 2. In or about August 2016, in the Eastern District of Michigan, Southern Division and elsewhere, defendant RICHARD SOLLARS did corruptly solicit and demand for the bene?t of a person, and accepted and agreed to accept a thing of value, namely, the installation of hardwood ?ooring on the entire second level of home, intending to be in?uenced and rewarded in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). COUNT THREE (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-2 SHADY AWAD 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Three as if fully set forth herein. 2. In or about August 2016, in the Eastern District of Michigan, Southern Division and elsewhere, defendant SHADY AWAD did corruptly give, offer and agree to give a thing of value to RICHARD SOLLARS, namely, the installation of 18 Case ECF No. 1 filed 12/18/19 PageID.19 Page 19 of 37 hardwood ?ooring on the entire second level of home, with the intent to in?uence and reward SOLLARS in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). COUNT FOUR (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-l RICHARD SOLLARS 1. Paragraphs 1 through 6 of the General Allegations are hereby re?alleged and incorporated by reference in Count Four as if fully set forth herein. 2. In or about May 2017, in the Eastern District of Michigan, Southern Division and elsewhere, defendant RICHARD SOLLARS did corruptly solicit and demand for the bene?t of a person, and accepted and agreed accept to a thing of value, namely, the installation of hardwood ?ooring at lake house, intending to be in?uenced and rewarded in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). 19 Case ECF No. 1 filed 12/18/19 PageID.20 Page 20 of 37 COUNT FIVE (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-2 SHADY AWAD 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Five as if ?illy set forth herein. 2. In or about May 2017, in the Eastern District of Michigan, Southern Division and elsewhere, defendant SHADY AWAD did corruptly give, offer and agree to give a thing of value to RICHARD SOLLARS, namely, the installation of hardwood ?ooring at lake house, with the intent to in?uence and reward SOLLARS in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). (18 U.S.C. Bribery Concerning Programs Receiving Federal Funds) D-l RICHARD SOLLARS 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Six as if fully set forth herein. 2. In or about June 2017, in the Eastern District of Michigan, Southern Division and elsewhere, defendant RICHARD SOLLARS did corruptly solicit and demand for the bene?t of a person, and accepted and agreed to accept things of value, 20 Case ECF No. 1 filed 12/18/19 PageID.21 Page 21 of 37 namely, a refrigerator, a double oven with a gas range, a microwave and a dishwasher, intending to be in?uenced and rewarded in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in Violation of Title 18, United States Code, Section 666(a). COUNT SEVEN (18 U.S.C. 666(a) Bribery Concerning Programs Receiving Federal Funds) D-2 SHADY AWAD l. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Seven as if fully set forth herein. 2. In or about June 2017, in the Eastern District of Michigan, Southern Division and elsewhere, defendant SHADY AWAD did corruptly give, offer and agree to give things of value to RICHARD SOLLARS, namely, a refrigerator, a double oven with a gas range, a microwave and a dishwasher, with the intent to in?uence and reward SOLLARS in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). 21 Case ECF No. 1 filed 12/18/19 PageID.22 Page 22 of 37 COUNT EIGHT (18 U.S.C. 666(a) Bribery Concerning Programs Receiving Federal Funds) D-l RICHARD SOLLARS 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Eight as if fully set forth herein. 2. In or about August 2017, in the Eastern District of Michigan, Southern Division and elsewhere, defendant RICHARD SOLLARS did corruptly solicit and demand for the bene?t of a person, and accepted and agreed to accept a thing of value, namely, the re?nishing of a deck at lake house, intending to be in?uenced and rewarded in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). COUNT NINE (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-2 SHADY AWAD 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Nine as if fully set forth herein. 2. In or about August 2017, in the Eastern District of Michigan, Southern Division and elsewhere, defendant SHADY AWAD did corruptly give, offer and agree to give things of value to RICHARD SOLLARS, namely, the re?nishing of 22 Case ECF No. 1 filed 12/18/19 PageID.23 Page 23 of 37 a deck at lake house, with the intent to in?uence and reward SOLLARS in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). COUNT TEN (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D?l RICHARD SOLLARS 1. Paragraphs 1 through 6 of the General Allegations are hereby re?alleged and incorporated, by reference in Count Ten as if fully set forth herein. 2. In or about November 2017, in the Eastern District of Michigan, Southern Division and elsewhere, defendant RICHARD SOLLARS did corruptly solicit and demand for the bene?t of a person, and accepted and agreed to accept things of value, namely, the installation of hardwood ?ooring in the basement of home, intending to be in?uenced and rewarded in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). 23 Case ECF No. 1 filed 12/18/19 PageID.24 Page 24 of 37 COUNT ELEVEN (18 U.S.C. 666(a), Bribery Concerning Programs Receiving Federal Funds) D-2 SHADY AWAD 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Eleven as if fully set forth herein. 2. In or about November 2017, in the Eastern District of Michigan, Southern Division and elsewhere, defendant SHADY AWAD did corruptly give, offer and agree to give things of value to RICHARD SOLLARS, namely, the installation of hardwood ?ooring in the basement of home, with the intent to in?uence and reward SOLLARS in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). COUNT TWELVE (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-l RICHARD SOLLARS 1. Paragraphs 1 through 6 of the General Allegations are hereby re?alleged and incorporated by reference in Count Twelve as if fully set forth herein. 2. In or about April 2018, in the Eastern District of Michigan, Southern Division and elsewhere, defendant RICHARD SOLLARS did corruptly solicit and demand for the bene?t of a person, and accepted and agreed to accept things of value, 24 Case ECF No. 1 filed 12/18/19 PageID.25 Page 25 of 37 namely, a washer and dryer worth over $3,000, intending to be in?uenced and rewarded in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). COUNT THIRTEEN (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-2 SHADY AWAD 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Thirteen as if fully set forth herein. 2. In or about April 2018, in the Eastern District of Michigan, Southern Division and elsewhere, defendant SHADY AWAD did corruptly give, offer and agree to give things of value to RICHARD SOLLARS, namely, a washer and dryer worth over $3,000, with the intent to in?uence and reward SOLLARS in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in Violation of Title 18, United States Code, Section 666(3). 25 Case ECF No. 1 filed 12/18/19 PageID.26 Page 26 of 37 COUNT FOURTEEN (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-l RICHARD SOLLARS 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Fourteen as if fully set forth herein. 2. In or about October 2018, in the Eastern District of Michigan, Southern Division and elsewhere, defendant RICHARD SOLLARS did corruptly solicit and demand for the bene?t of a person, and accepted and agreed to accept things of value, namely, the installation of hardwood ?ooring in two rooms of home, intending to be in?uenced and rewarded in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in violation of Title 18, United States Code, Section 666(a). COUNT FIFTEEN (18 U.S.C. 666(a) - Bribery Concerning Programs Receiving Federal Funds) D-2 SHADY AWAD 1. Paragraphs 1 through 6 of the General Allegations are hereby re-alleged and incorporated by reference in Count Fifteen as if fully set forth herein. 2. In or about October 2018, in the Eastern District of Michigan, Southern Division and elsewhere, defendant SHADY AWAD did corruptly give, offer and 26 Case ECF No. 1 filed 12/18/19 PageID.27 Page 27 of 37 agree to give things of value to RICHARD SOLLARS, namely, the installation of hardwood ?ooring in two rooms of home, with the intent to in?uence and reward SOLLARS in connection with a business or transaction of the City of Taylor involving $5,000 or more. All in Violation of Title 18, United States Code, Section 666(a). COUNTS SIXTEEN THROUGH THIRTY-THREE (18 U.S.C. 1343 - Wire Fraud) D-l RICHARD SOLLARS JEFFREY BAUM 1. Paragraphs 1 through 6 of the General Allegations are hereby re?alleged and incorporated by reference in Counts Sixteen through Thirty-Three as if set forth herein. 2. Beginning in or about June 2015, and continuing through in or about March 2019, in the Eastern District of Michigan, Southern Division, and elsewhere, defendants RICHARD SOLLARS and JEFFREY BAUM devised and executed a scheme and arti?ce to defraud others to obtain money by means of materially false and fraudulent pretenses, representations and promises. In order to execute the scheme and arti?ce to defraud, SOLLARS and BAUM transmitted and caused to be transmitted by means of wire communications in interstate commerce, writings, signs, signals, pictures and sounds. 27 Case ECF No. 1 filed 12/18/19 PageID.28 Page 28 of 37 The Scheme and Arti?ce to Defraud 3. It was part of the scheme and arti?ce to defraud that SOLLARS and BAUM would falsely represent to the public and to donors that campaign fund, Committee to Elect Richard (Rick) Sollars, Jr., was a legitimate political campaign fund that spent its funds in ways consistent with a political campaign fund. In truth and in fact, as SOLLARS and BAUM well knew, SOLLARS and BAUM stole thousands of dollars from the campaign fund and converted the money to own personal use and bene?t, contrary to and representations to the donors. 4. It was part of the scheme and arti?ce to defraud that RICHARD SOLLARS and JEFFREY BAUM would hold fundraising events to raise money for campaign fund, at which SOLLARS and BAUM would falsely represent to donors that the campaign fund spent its ?nds in ways consistent with a political campaign fund. 5. It was part of the scheme and arti?ce to defraud that RICHARD SOLLARS would take blank campaign fund checks bearing JEFFREY signature to Developer A ?5 market where SOLLARS would cash them and keep the cash for own personal use. 6. It was part of the scheme and arti?ce to defraud that RICHARD SOLLARS would direct Developer A to create false invoices for catering services 28 Case ECF No. 1 filed 12/18/19 PageID.29 Page 29 of 37 that had not been provided by . Developer A in order to conceal the fact that SOLLARS was stealing the money from his campaign ?nd. 7. It was part of the scheme and arti?ce to defraud that JEFFREY BAUM would instruct Developer A about what to include in the false catering invoices. 8. It was part of the scheme and arti?ce to defraud that RICHARD SOLLARS and JEFFREY BAUM would solicit donations from business owners and other individuals by falsely representing that the monies would be used to pay Developer A for food catering at events held by SOLLARS.- However, the checks did not go to pay for any food catering. Instead, the donor checks were cashed by Developer A, who would give the money back to SOLLARS in the form of cash and scratch-off lottery tickets. 9. It was part of the scheme and arti?ce to defraud that JEFFREY BAUM and RICHARD SOLLARS would direct donors to bring checks to Developer A?s market to ostensibly pay for catering that was never actually provided. 10. It was part of the scheme and arti?ce to defraud that RICHARD SOLLARS and JEFFREY BAUM would create and cause the creation of false invoices and false State of Michigan campaign committee reports that concealed their theft of the campaign fund money. 29 Case ECF No. 1 filed 12/18/19 PageID.30 Page 30 of 37 11. It was part of the scheme and arti?ce to defraud that RICHARD SOLLARS would solicit and accept cash donations to his campaign fund, which he kept and used for personal expenses. 12. It was part of the scheme and arti?ce to defraud that RICHARD SOLLARS would conceal the money that he stole through his fraud scheme by hiding over $200,000 in cash in his home. 13. On or about each of the dates set forth below, in the Eastern District of Michigan, Southern Division, RICHARD SOLLARS and JEFFREY BAUM did, for the purpose of executing the scheme and arti?ce to defraud described above, and attempting to do so, knowingly cause to be transmitted by means of wire communications in interstate commerce, writings, signs, signals, pictures and sounds, with each wire communication constituting a separate count of this indictment. 14. The following wire communications were made in connection with RICHARD SOLLARS cashing campaign fund checks at Developer A?s market: 30 Case ECF No. 1 filed 12/18/19 PageID.31 Page 31 of 37 Count Approximate Date of Wiring Description of Wiring 16 November 9, 2017 Check Deposit: SOLLARS campaign check no. 1439, dated November 7, 2017; memo: Catering; signed by JEFFREY BAUM 17 December 4, 2017 Check Deposit: SOLLARS campaign check no. 1446, dated December 1, 2017; memo: Employee Holiday Party; signed by JEFFREY BAUM 18 December 19, 2017 Check Deposit: SOLLARS campaign check no. 1451, dated December 15, 2017; memo: Employee Party Food; signed by JEFFREY BAUM 19 January 23, 2018 Check Deposit: SOLLARS campaign check no. 1452, dated December 15, 2017; memo: Catering Super Bowl City Hall; signed by JEFFREY BAUM 20 February 16, 2018 Check Deposit: SOLLARS campaign check no. 1462, dated February 12, 2018; memo: S.O.C. 2018; signed by JEFFREY BAUM 31 Case ECF No. 1 filed 12/18/19 PageID.32 Page 32 of 37 21 July 3, 2018 Check Deposit: SOLLARS campaign check no. 1508, dated June 29, 2018; memo: TSF Sponsors; signed by JEFFREY BAUM 22 January 3, 2019 Check Deposit: SOLLARS campaign check no. 1558, dated January 3, 2019; memo: S.O.C. 2019; signed by JEFFREY BAUM 15. The following Wire communications were made in connection with campaign donors? checks for purported ?catering? being cashed at Developer" A ?s market: Count Approximate Date of Wiring Description of Wiring 23 November 2, 2017 Check Deposit: AA check no. 50311, to Developer A ?5 market, dated October 31, 2017 24 November 24, 2017 Check Deposit: AA check no. 50530, to Developer A ?5 market, dated November 21, 2017 25 December 6, 2017 Check Deposit: PSG check no. 1051, to Developer A?s market, dated December 4, 2017 32 Case ECF No. 1 filed 12/18/19 PageID.33 Page 33 of 37 26 December 20, 2017 Check Deposit: VPM check no. 15768, to Devel0per A?s market, dated December 8, 2017, memo: City of Taylor Xmas Party Sponsorship 27 December 19, 2017 Check Deposit: CIS check no. 9175, to Developer A?s market, dated December 15, 2017, memo: Donation City of Taylor 28 December 21, 2017 Check Deposit: VPM check no. 15780, to Developer A?s market, dated December 18, 2017, memo: Donation Xmas Party Sponsorship 29 October 22, 2018 Check Deposit: AA check no. 52641, to Developer A market, dated October 19, 201 8 30 October 22, 2018 Check Deposit: PSG check no. 1314, to Developer A?s market, dated October 19, 2018 31 October 25, 2018 Check Deposit: MRS check no. 2786, to Developer A?s market, dated October 23, 2018, memo: Donation 32 October 26, 2018 Check Deposit: ED check no. 1139, to Developer A ?s 33 Case ECF No. 1 filed 12/18/19 PageID.34 Page 34 of 37 market, dated October 23, 2018. 33 November 16,2018 Check Deposit: VPS check no. 15859 to Developer A, dated November 13, 2018; memo: Sponsorship Xmas party 10 Development All in Violation of Title 18, United States Code, Section 1343. FORFEITURE ALLEGATION (18 U.S.C. 28 U.S.C. 2461(c) Criminal Forfeiture) 1. The allegations contained in the General Allegations and in Counts One through Thirty-Three of this Indictment are re?alleged and incorporated by reference for the purpose of alleging forfeiture under Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c). 2. Under Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(0), upon conviction of a violation of Title 18, United States Code, Section 666, Title 18, United States Code, Section 1343 and/or a conspiracy to violate section 666, in violation of Title 18, United States Code, Section 371, the defendants, RICHARD SOLLARS, SHADY AWAD, and JEFFREY BAUM shall forfeit to the United States of America any property, real or personal, which constitutes or is derived from 34 Case ECF No. 1 filed 12/18/19 PageID.35 Page 35 of 37 proceeds traceable to said violations. The property to be forfeited includes, but is not limited to, the following: 3. $205,993.00 in US. Currency seized in Taylor, Michigan on or about February 19, 2019; 4 Real property located at 22190 Hunter Circle North, Taylor, Wayne County, Michigan 48180 more fully described as: Lot 43, FOX CHASE SUBDIVISION, according to the plat thereof as recorded in Liber 114, Pages 22, 23, and 24, of Plats, Wayne County Records. PARCEL ID: 60-066-04-0043-000 Real property located at 264 Harris, Cement City, Lenawee County, Michigan 49233 more fully described as: Lot No. 4, Silver Lake Grove, according to the plat thereof as recorded in Liber 16 of Plats, Page 1 1, Lenawee County Records. TAX PARCEL ID: WDO-6750040-00 Money Judgment. The United States also intends to seek a forfeiture money judgment for the total amount of proceeds that each defendant obtained as a result of the charged violations. Such sum in aggregate is property representing the proceeds of violations of Title 18, United States Code, Sections 371, 666, and 1343, or property that is traceable to such property. 4. Substitute Assets. Under Title 21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(0), the defendants shall forfeit substitute property, up to the value of the property described above, if, as a result of any act or omission of the defendants, any of the property described 35 Case ECF No. 1 filed 12/18/19 PageID.36 Page 36 of 37 above: cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited 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 property which cannot be divided without dif?culty. THIS IS A TRUE BILL. s/ Grand Jury oreperson GRAND JURY FOREPERSON MATTHEW SCHNEIDER United States Attorney S/Davz'd A. Gardey DAVID A. GARDEY Assistant United States Attorney Chief, Public Corruption Unit s/R. Michael Bullotta R. MICHAEL BULLOTTA Assistant United States Attorney S/Dawn N. [son DAWN N. ISON Assistant United States Attorney Dated: December 18, 2019 36 Case ECF No. 1 filed 12/18/19 PagelD.37 Page 37 of 37 Case:2:19?cr?20836 Judge: Goldsmith, Mark A. MJ: Stafford, Elizabeth A- Filed: 12?1 8-2019 At 11:06 AM USA SEALED MATTER (LG) Companion Gaseglnformation Companion Case Numb?r: United States District Court rimi Eastern District of Michigan nal Case 0? NOTE: It is the of the Assistant US Attorney signing this form to complete it This may be a companion case based on ElYes lNo Initials: f3, Case Title: USA v. Richard Sollars, et al County where offense occurred: Wayne Offense Type: Felony Indictment -- no prior complaint Information a Superseding to Case No: Judge: Reason: Defendant Name Charges Prior Complaint (if applicable) Please take notice that the below listed Assistant United States Attorney is the attorney of record for the above captioned case December 18, 2019 11/ Date R. Michael Bullotta' Assistant United States Attorney 211 W. Fort Street, Suite 2001 Detroit, MI 48226 michael.bullotta@usdoj.gov (313) 226-9507 1 Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, or (2) the same or related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be companion cases even though one of them may have already been terminated.