Jeffrey E. Thompson statement of offense

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES or AMERICA Criminal Number:
A . I Violations: -
V.
18 U.S.C. 371
(Conspiracy)

JEFFREY E. THOMPSON,
22 D.C. Code l805a(a)(1)
Defendant. (Conspiracy)
STATEMENT OF OFFENSE

Pursuant to Rule 11 of the Federal Rules of Criminal Procedure, the United States and the

defendant EFFREY E. THOMPSON agree and stipulate that at all relevant times:
DEFENDANT AND HIS RELATED COMPANIES

1. Defendant JEFFREY E. THOMPSON a resident of the District
of Columbia, was the Chairman, Chief Executive Officer, and majority owner of Thompson,
Cobb, Bazilio and Associates, P.C. TCBA was a for-profit corporation registered in
the District of Columbia that provided accounting, management. consulting, and tax services.
TCBA billed and-received millions of dollars under contracts with various District of Columbia
and federal government entities. TCEA's main office was in the District of Columbia.

2. THOMPSON was also the Chairman, Chief Executive Officer, President, and sole
owner of D.C. Healthcare Systems, Inc. DCHSI was an investment holding
company and a for~profit corporation registered in the District of Columbia. DCHSI's address in
the District of Columbia was the same as TCBA's address. A

3. DCHSI owned D.C. Chartered Health Plan, Inc.

CHARTERED contracted with the District of Columbia government to provide managed care
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services to a substantial number of District of Columbia residents. CHARTERED's contract

0 with the District of Columbia, paid primarily by the federal government, totaled approximately

$300 million each year. CHARTERED's main office was in the District of Columbia.

VINTRODUCTION
was a prolific. political donor. Since 2000, THOMPSON made

contributions to nearly three dozen principal campaign committees for District of Columbia
political candidates and more than two dozen authorized committees for federal political
candidates. As used herein, "principal campaign committees" describes the principal campaign
committees of District of Columbia candidates and "authorized committees" describes the
authorized campaign committees of federal candidates.

5. In addition to making political contributions in his own name, THOMPSON
engaged in fundraising activities, including organizing events at TCBA's office in the District of
Columbia, to raise money for District of Columbia and federal political candidates through their
principal campaign committees and authorized committees.

6. Contrary to District of Columbia and federal campaign finance laws,
THOMPSON solicited individuals, within the District of Columbia and across the United States,
including relatives, friends, employees, independent contractors, and the senior management of
TCBA, to make contributions and to recruit others to make contributions in their names and the
names of their relatives to principal campaign committees, authorized committees, and a federal
multicandidate political committee induced by the assurance that THOMPSON
would arrange to pay for and otherwise reimburse the contributions.

I 7. THOMPSON used personal and corporate money to advance funds and reimburse
individuals for the political contributions that they made in their names and the names of their

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relatives at THOMPSON's direction. The funding for these "conduit contributions" took several

.forms, including THOMPSON issuing personal checks, authorizing and directing TCBA and

DCHSI to issue corporate funds, and authorizing and directing TCBA to make 'payments
variously designated as salary and contractor payments, bonus payments, and advances on
bonuses, all designed to disguise the fact that the funds were reimbursements for political
contributions, whether repaid before or after the conduit contributions. .

8. THOMPSON and others at TCBA misrepresented the nature of such
reimbursement payments in TCBA's accounting books and records, referring to the
reimbursement payments variously as "advances," "bonuses," "advances on bonus,"
and consultant fees, among other things. As THOMPSON and others at TCBA well knew, these
terms frequently misrepresented the reimbursement payments, as the payments were not in fact
advances, bonuses, advances on bonuses, or consultant fees.

9. In addition to making conduit contributions, THOMPSON used TCBA and
DCHSI to disburse excessive and unreported contributions to pay for campaign services and
materials in coordination with and in support of political candidates. The nature of these
coordinated in--kind contributions, referred to herein as "shadow campaigns," took several forms,
including the dissemination of campaign-prepared materials in support of political candidates.
For example, during the primary election cycle for Mayor of the District of Columbia, from in or
about May 2010 through in or about September 2010, THOMPSON used TCBA and DCHSI to
funnel over $653,000 to pay for campaign services and campaign materials in support of a
shadow campaign for a Mayoral candidate (hereafter, CAMPAIGN
Similarly, during the primary election cycle for President of the United States, from in or about
February 2008 through in or about May 2008, THOMPSON used TCBA and DCHSI to funnel

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approximately $608,750 to pay for campaign services in support of a shadow campaign for a
Presidential candidate (hereafter, CAMPAIGN

10. In funding these shadow campaigns, THOMPSON enlisted the assistance of
others, including EUGENIA HARRIS a resident of the District of Columbia and
longtime political consultant, who had been involved in District of Columbia political campaigns
for over two decades. HARRIS owned and controlled two for--profit corporations registered in,
and with their offices located in, the District of Colmnbia: Belle International, Inc.
and Details International, Inc. BELLE and DETAILS were entities through
which HARRIS, at THOMPSON's direction, paid fimds to be used for shadow campaigns.
Through these entities, THOMPSON fimded shadow campaigns for PRESIDENTIAL
CAIVIPAIGN 1, MAYORAL CAMPAIGN A, and other District of Columbia campaigns,
including campaigns for the 2006 mayoral election, the 2007 special election for Ward 4
Member of the Council of the District of Columbia Council"), the 2008 election for At-
Large Member of the D.C. Council, the 2010 elections for Ward 1 and Ward 6 Members of the
D.C. Council, and the 2011 special election for At-Large Member of the D.C. Council.

11. In the process of making conduit contributions and ftmding shadow campaigns,
THOMPSON and others violated campaign finance laws and impeded District of Columbia and
federal campaign finance regulators from collecting and 'publicly disseminating accurate
campaign finance information. By funding and concealing conduit contributions, THOMPSON
and others caused the principal campaign committees and authorized committees to file reports
with campaign finance regulators falsely stating that individuals had made District of Columbia
and federal contributions, when, in truth and in fact, as THOMPSON well knew, the
contributions were made by THOMPSON, and by TCBA and DCHSI, at THOMPSON's

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direction. These reports were materially false because they misrepresented and concealed from
those regulators and the voting public the true source and amounts of contributions being made
by THOMPSON, TCBA, and DCHSI. By funding shadow campaigns through intermediaries,
THOMPSON and - others disguised the true source of the in--kind contributions and
misrepresented and concealed from District of Columbia and federal campaign finance
regulators, other candidates, and the voting public that they had fimded the shadow campaigns.
12. In the process of misrepresenting and concealing the conduit contributions and
shadow campaigns, THOMPSON and others at TCBA impeded the lawful functions of the
Internal Revenue Service by, among other things, causing and directing others to
misrepresent and to conceal political contributions in TCBA's financial records and in TCBA's
tax returns and filings with the IRS, creating false promissory notes to conceal the true nature of
the conduit reimbursements, and making and causing false statements and documents to be
submitted to the IRS in response to an IRS audit of TCBA that began in or about April 2010.

CONSPIRACY TO VIOLATE DISTRICT OF COLUMBIA
FINANCE LAWS

13. The District of Columbia's Office of Campaign Finance was an agency
and department of the District of Columbia with jurisdiction to enforce the limits and
prohibitions of the District of Columbia Campaign Finance Reform and Conflict of Interest Act

of 1974, as amended (then codified at D.C. Code ll-1101.01 through 1-1151.06) (the

Campaign Act"). The D.C. Campaign Act regulated the role of money in the election of

candidates running for District of Columbia office and provided for public disclosure of the
financing of District of Columbia election campaigns 'by imposing limits on the amount of

money that could be contributed to a District of Columbia candidate and that candidate's

principal campaign committee; prohibiting any person (including any corporation) from making
a contribution in the name of another, including by reimbursement; and requiring principal
campaign committees to file periodic reports of receipts and disbursements. These periodic
reports, which were filed with the OCF and made publicly available, were intended to provide
voters with a transparent record of such contributions to candidates for District of Columbia
office.

14. From at least in or about September 2006 through in or about April 2011,
THOMPSON, together with others, unlawfully, willfully, and knowingly conspired to defraud
the District of Columbia and OCF by funding and concealing contributions in excess of those
permitted under the D.C. Campaign Act, and thereby obstructed and impeded the due
administration of the campaign finance laws.

Conduit Contributions

15. A THOMPSON and others conspired to defraud the District of Columbia and the
OCF by causing individuals, including relatives, friends, employees, independent contractors,
and the senior management of TCBA, to make contributions to the principal campaign
committees of candidates for Mayor of the District of Columbia and Member of the D.C.
Council; assuring such individuals that they would be reimbursed for their contributions;
reimbursing those contributions using funds from THOMPSON, TCBA, and and
misrepresenting and concealing from the OCF, other candidates, and the public that they had
reimbursed individuals for contributions.

16. To expand his capacity to fund candidates of choice through conduit
contributions, THOMPSON enlisted individuals, including INDIVIDUAL G, a trusted associate
of THOMPSON, to recruit and reimburse conduits who would make contributions in their names

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to THOMPSON's preferred candidates, by providing such individuals with large sums of money

to use for this purpose.

17. Between in or about September 2006 and in or about April 2011, THOMPSON
utilized at least 75 conduits to make contributions to at least 15 mayoral and D.C. Council
candidates in excess of at least $500,000.

Shadow Campaigns

18. THOMPSON and others conspired to defraud the District of Columbia and the
OCF by paying for campaign services and materials in support of shadow campaigns for certain
candidates for Mayor of the District of Columbia and Member of the D.C. Council and their
principal campaign committees, disguising the true source of the in-kind contributions, that is,
THOMPSON and his companies, by transferring the funds through intermediaries, and
misrepresenting and concealing from the OCF, other candidates, and the public that they had
funded the shadow campaigns.

Secret Payments for 2010 MAYORAL CAMPAIGN A

19. MAYORAL CAMPAIGN A was a principal campaign committee whose

candidate, MAYORAL CANDIDATE A, was running for Mayor of the District of Columbia

during the 2010 District of Columbia primary election cycle.
20. VERNON HAWKINS a resident of the District of Columbia,

was a senior advisor for MAYORAL. CAMPAIGN A on matters such as staffing,

communications, and field operations, which included Get Out the Vote operations.

21. D.C. COUNCIL CANDIDATE A, a resident of the District of Columbia, worked
from time to time for CHARTERED and was an announced candidate for At-Large Member of
the Council during the 2008 District of Columbia election cycle.

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22. Prior to March 30, 2010, THOMPSON, HAWKINS, and HARRIS discussed the
potential for MAYORAL CANDIDATE A to enter the upcoming election for Mayor of the
District of Columbia. THOMPSON expressed to HAWKINS and HARRIS his willingness to
financially support MAYORAL CANDIDATE A if MAYORAL CANDIDATE A decided to
run for Mayor. THOMPSON's willingness to support MAYORAL CAMPAIGN A was based
on an expectation that the election of MAYORAL CANDIDATE A would improve the business
climate for CHARTERED. THOMPSON explained to and HARRIS that
THOMPSON could not support MAYORAL CANDIDATE A in a public manner because such
support would lead to retribution by the then-current Mayor and worsen the business climate for

CHARTERED. however, agreed to raise funds for MAYORAL CANDIDATE A

I from donors not publicly associated with THOMPSON.

23. Prior to March 30, 2010, THOMPSON, HAWKINS, and MAYORAL
CANDIDATE A discussed THOMPSON's willingness to raise' funds for MAYORAL
CANDIDATE A if MAYORAL CANDIDATE A decided to run for Mayor. THOMPSON
explained to MAYORAL CANDIDATE A that THOMPSON could not support MAYORAL
CANDIDATE A in a public manner because such support would lead to retribution by the then-
current Mayor and worsen the business climate for CHARTERED.

24. On March 30, 2010, MAYORAL CANDIDATE A publicly entered the race for
Mayor of the District of Columbia.

25. After March 30, 2010, THOMPSON met with HAWKINS to discuss a shadow

campaign, to be funded by THOMPSON, to pay for campaign services and campaign materials

- in support of MAYORAL CAMPAIGN A. Due to the late entry of MAYORAL CANDIDATE

A into the race for Mayor of the District of Columbia, HAWKINS told THOMPSON that such
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contributions were neccessary for MAYORAL CANDIDATE A to' win the. election.
THOMPSON discussed and agreed with HAWKINS and HARRIS to fund a shadow campaign
in support of MAYORAL CAMPAIGN A in an amount in excess of the "individual contribution
limit under the D.C. Campaign Act.

.26. In order to prevent the detection of the funding of the shadow campaign by the
OCF and the public, THOMPSON discussed and agreed with HAWKINS and HARRIS that

funding would be provided through payments from TCBA and DCHSI to DETAILS and/or

BELLE. In May 2010, at THOMPSON's direction, DCHSI transferred approximately $l5,000

to DETAILS to purchase campaign materials for the use of MAYORAL CAMPAIGN A.

27. On or about June 7, 2010, at the request of MAYORAL CANDIDATE A,
THOMPSON met with MAYORAL CANDIDATE A to discuss THOMPSON's fundraising in
support of MAYORAL CANDIDATE A. MAYORAL CANDIDATE A discussed, among other
things, the report of contributions due to be filed by the candidates' principal campaign

committees with OCF on June 10, 2010. MAYORAL CANDIDATE A requested that

THOMPSON expedite his fimdraising to provide MAYORAL CAMPAIGN A with an

opportunity to report publicly that it raised more contributions during 'the prior three-month
period than any other candidate's principal campaign committee. THOMPSON agreed to
expedite his fundraising in support of MAYORAL CANDIDATE A, but reminded MAYORAL
CANDIDATE A that his support would have to be from donors not publicly associated with
THOMPSON. It was THOMPSON's intention to reimburse many of these donors for their
contributions. To keep THOMPSON's support for MAYORAL CANDIDATE A from

becoming public, THOMPSON directed MAYORAL CANDIDATE A to refer to THOMPSON

as "Uncle Earl" when discussing with others support for MAYORAL
CANDIDATE A. MAYORAL CANDIDATE A agreed to keep THOMPSON's support secret.

28. Between on or about June 7, 2010, and June 10, 2010, THOMPSON directly and
indirectly caused individuals to make contributions to MAYORAL CAMPAIGN A, assured such
individuals that they would be reimbursed for their contributions, and subsequently reimbursed
them for those contributions using funds from THOMPSON, TCBA, and DCHSI.

29. On or about June 10, 2010, MAYORAL CAMPAIGN A filed a report with OCF
that reported more contributions in the prior three-month period than any other candidate's
principal campaign committee. The report disclosed a large number of contributions received on
one day, June 10, 2010. A significant amount of the contributions reported as received on June
10, 2010, were for contributions reimbursed directly and indirectly by THOMPSON. As
intended, the $15,000 payment made to DETAILS and used to fund the shadow campaign was
not reported in the June 10, 2010 report to OCF.

30. On or about July 28, 2010, at the direction of THOMPSON, TCBA issued a check
in the amount of '$87,800, payable to BELLE, to fund the shadow campaign.

31. THOMPSON and HARRIS arranged for D.C. COUNCIL CANDIDATE A (Who

was not then a candidate for political office) to serve as the official campaign driver for

MAYORAL CANDIDATE A and paid D.C. COUNCIL CANDIDATE A for such services.
Using funds provided by THOMPSON, HARRIS leased a luxury sport utility vehicle for
COUNCIL CANDIDATE A to drive when D.C. COUNCIL CANDIDATE A drove MAYORAL
CANDIDATE A to campaign-related and other events. I

32. In or about August 2010, HAWKINS informed THOMPSON that, in order for
MAYORAL CANDIDATE A to win the primary election, THOMPSON would have to fund

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additional shadow campaign expenditures, to be used principally to pay for GOTV efforts in
support of MAYORAL CAMPAIGN A. HAWKINS estimated that those additional shadow

campaign expenditures would exceed $400,000. Given the size of the estimated expenditures,

THOMPSON instructed HAWKINS to tell MAYORAL CANDIDATE A that if MAYORAL

CANDIDATE A wanted THOMPSON to fund the additional shadow campaign expenditures,
MAYORAL CANDIDATE A would have to ask THOMPSON personally. Thereafter,
THOMPSON directed HARRIS to schedule a meeting between THOMPSON and' MAYORAL
CANDIDATE A to give MAYORAL CANDIDATE A an opportunity to ask THOMPSON
personally for the additional shadow campaign expenditures.

33. As directed by THOMPSON, HARRIS arranged a dinner meeting at her
apartment between and MAYORAL CANDIDATE A. COUNCIL
CANDIDATE A drove MAYORAL CANDIDATE A to apartment for the dinner
meeting. During the meeting, MAYORAL CANDIDATE A discussed, among other things, the
status of the mayoral race and the need for a successful GOTV campaign in order to ensure that
MAYORAL CANDIDATE A won the election. MAYORAL CANDIDATE A presented to
THOIVIPSON a one-page budget of approximately $425,000 for GOTV expenses in support of
and in coordination with MAYORAL CAMPAIGN A. MAYORAL CANDIDATE A asked
THOMPSON to pay for the GOTV campaign. THOMPSON agreed to pay for the GOTV
campaign. Because THOMPSON's payments for the GOTV campaign could not be made public
due to THOMPSON's fear of retribution from the then--current Mayor, and because they
exceeded the legal limits on individual contributions, THOMPSON told MAYORAL

CANDIDATE A that THOMPSON's payment for the GOTV campaign would pass through

HARRIS, and that HAWKINS and HARRIS would manage the GOTV campaign in support of A

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and in coordination with MAYORAL CAMPAIGN A. While leaving HARRIS's apartment,
MAYORAL CANDIDATE A expressed gratitude for THOMPSON's agreement to pay for the
GOTV campaign and referred to THOMPSON as "Uncle."

34. On or about the dates below, THOMPSON authorized and directed TCBA to
issue the following checks and Wire payments to BELLE in order to pay for campaign services

and campaign materials for the shadow campaign:


is-5 3.:
Check September 2010 $180,000
Wire Transfer September 10, 2010 $76,000
Check September 10,2010 $185,000
Wire Transfer September 14, 2010 $125,000

35. Using funds provided by THOMPSON, and in consultation with HAWKINS,

HARRIS made various expenditures for the shadow campaign in support of MAYORAL

CAMPAIGN A. For example, using funds provided by THOMPSON, HARRIS paid for

individuals to manage field operations and transportation related to the shadow campaign by,
among other things, working directly with, sharing canvassing information with, sharing
workspace with, and coordinating operations with employees and agents of MAYORAL
CAMPAIGN A, including those managing the campaign's official GOTV efforts.

36. Using funds provided by THOMPSON, and in consultation with HAWKINS,
HARRIS paid for campaign materials related to the shadow campaign in support of MAYORAL
CAMPAIGN A, including yard signs, t--shirts, door knockers, posters, rental vans, and catering

services.

37. On September 14, 2010, MAYORAL CANDIDATE A Won the primary election
for Mayor of the District of Columbia.

38. After September 14, 2010, at the request of HAWKINS to cover a campaign
expense promised by a close family member of MAYORAL CANDIDATE A, THOMPSON
paid $10,000 to INDIVIDUAL to cover the campaign expense promised by the close family
member of MAYORAL CANDIDATE A on behalf of MAYORAL CAMPAIGN A.
INDIVIDUAL told THOMPSON that INDIVIDUAL and the close family member of
MAYORAL CANDIDATE A used the $10,000 to pay cash to individuals who had worked in
support of MAYORAL CAMPAIGN A.

39. On November 2, 2010, MAYORAL CANDIDATE A won the general election
for Mayor of the District of Coltunbia. I

40. In or about November 2010, HARRIS and THOMPSON discussed a request from
MAYORAL CANDIDATE A for THOMPSON to pay for expenses in support of a candidate in
a local labor union run-off election. Thereafter, THOMPSON paid approximately $10,000 to
HARRIS to fund expenses of the candidate.

41. On January 2, 2011, MAYORAL CANDIDATE A was sworn in as the Mayor of
the District of Columbia. 0

42. After January 2, 2011, THOMPSON funded more than $40,000 in expenditures
through HARRIS to pay for home improvements, employment, and other items for the benefit of
a close personal friend of MAYORAL CANDIDATE A. MAYORAL CANDIDATE A thanked
THOMPSON for getting work for the friend.

43. In or about August 2011, THOMPSON asked HARRIS to contact MAYORAL
CANDIDATE A to request MAYORAL CANDIDATE A to expedite a settlement agreement

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between the District of Columbia government and CHARTERED. HARRIS contacted"
MAYORAL CANDIDATE A to discuss expediting the matter. Shortly thereafter, THOMPSON
learned that the District of Columbia government would proceed in resolving the matter with
CHARTERED.

Secret Payments for 2006 MAYORAL CAMPAIGN
44. MAYORAL CANDIDATE B, a resident of the District of Columbia, was an

announced candidate for Mayor of the District of Columbia during the 2006 District of Columbia
election cycle. MAYORAL CAMPAIGN was the principal campaign committee for
MAYORAL CANDIDATE B. I

45. MICHAEL A. BROWN a resident of thevDistrict of Columbia, was
an announced candidate for Mayor of the District of Columbia during the 2006 District of
Columbia election cycle.

46. THOMPSON supported MAYORAL CANDIDATE through fundraising
efforts of approximately $325,000, which included conduit contributions in the names of others
that THOMPSON reimbursed with personal and corporate funds.

47. In support of MAYORAL CANDIDATE B, THOMPSON fimded a voter
registration drive. In July 2006, THOMPSON caused DCHSI to issue a check payable to a for-
profit entity in the amount of $1 33,333 to fund the voter registration drive. The primary purpose
of the drive was to identify and register voters likely to vote for MAYORAL CANDIDATE

48. In or around August 2006, after discussions with a senior adviser to MAYORAL
CAMPAIGN and discussions with HARRIS, THOMPSON agreed to fund a shadow campaign
in support of MAYORAL CAMPAIGN in an amount in excess of the individual contribution
limit under the D.C. Campaign Act. Between in or about August 2006 and September 2006,

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THOMPSON caused DCHSI to issue checks payable to a for-profit entity totaling approximately
$278,000, which in turn were used to pay for the shadow campaign in support of MAYORAL
CAMPAIGN 13, including a GOTV effort.

49. In September 2006, when it appeared to THOMPSON that BROWN would not
win the election but would take votes away from MAYORAL CANDIDATE B, THOMPSON
met with BROWN to encourage BROWN to drop out of the race. As a result of those
discussions, on or about September 6, 2006, THOMPSON and' BROWN agreed that

THOMPSON would pay BROWN $200,000, and would enterinto a consulting agreement with a

lobbying firm that employed BROWN, in return for BROWN dropping out of the race for Mayor

of the District of Columbia and endorsing MAYORAL CANDIDATE B.

50. On or about September 7, 2006, BROWN publicly announced a suspension of his
campaign and endorsed MAYORAL CANDIDATE B.

51. On or about September 8, 2006, THOMPSON authorized a payment in the
amount of $200,000 to be made for the intended benefit of BROWN. THOMPSON, on behalf of
TCBA, and BROWN, on behalf of a lobbying firm that employed him, also executed a 12-month
consulting agreement in which TCBA agreed to pay a retainer of $12,500 per month for a total of
$1 50,000.

Secret Payments for 2007 BROWN Campaigr_1
52. In or about April 2007, BROWN was an announced candidate in a special
election for Ward 4 Member of the DC. Council. BROWN met with THOMPSON and sought a
contribution from THOMPSON to BROWN's principal campaign committee.

53. During the meeting, THOMPSON discussed funding BROWN's campaign and

specifically discussed with BROWN: that THOMPSON could not publicly support

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BROWN's campaign for Ward 4 Member of the D.C. Council because of the then-Mayor's
support of another candidate; but that THOMPSON would have someone contact BROWN.

54. . Following this meeting, at THOMPSON's direction, HARRIS communicated
with BROWN about funding the shadow campaign. THOMPSON, through HARRIS, provided
funds in support of BROWN's campaign for Ward 4 Member of the D.C. Council.
THOMPSON understood that his contribution would exceed the individual contribution limit
under the D.C. Campaign Act.

Secret Pavments for 2008 D.C. COUNCIL CANDIDATE A Campaign

55. THOMPSON offered financial support to D.C. COUNCIL CANDIDATE A.
During their discussions, THOMPSON and D.C. COUNCIL CANDIDATE A agreed that
THOMPSON would provide fmancial support to D.C. COUNCIL CANDIDATE A, including
through unreported and excessive in~kind contributions to be paid through HARRIS in
coordination with and in support of D.C. COUNCIL CANDIDATE A's principal campaign
committee.

56. From in or about September 2008, until in or about October 2008, THOMPSON,
together with HARRIS, made and disbursed in-kind contributions in excess of $100,000 in
coordination with and in support of D.C. COUNCIL CANDIDATE A's principal campaign
committee.

Secret Payments for 2008 BROWN Campaign

57. BROWN was an announced candidate for At~Large Member of the D.C. Council

during the 2008 District of Columbia election cycle. In or about October 2008, BROWN met

with THOMPSON and sought approximately $100,000 from THOMPSON to fund a GOTV

shadow campaign in support of and in coordination with BROWN's principal campaign

committee.
58. During the meeting, THOMPSON agreed with BROWN to the following:

THOMPSON would contribute to BROWN's principal campaign committee for At~Large

Member, but not in a public manner; THOMPSON's contribution to BROWN's principal

campaign committee would exceed the individual contribution limit under the D.C. Campaign
Act; and BROWN would consult with HARRIS to arrange THOMPSON's in-kind
contribution.

59. Following this meeting, at THOMPSON's direction, BROWN coordinated with
HARRIS on the shadow campaign.

60. From in or about October 2008, until in on or about November 2008,
THOMPSON, together with HARRIS, and with BROWN's knowledge, using funds provided
from THOMPSON, made and disbursed in-kind contributions of more than $100,000 to fund a
GOTV shadow campaign in coordination with and in support of BROWN's campaign for At-
Large Member of the D.C. Council. I I

Secret Pavments for 2010 D.C. COUNCIL. CANDIDATE Campaign

61. D.C. COUNCIL CANDIDATE B, a resident of the District of Columbia, was
employed from time to time as a consultant for CHARTERED and an announced candidate for
Member of the D.C. Council, specifically, the Ward 6 seat, during the 2010 District of Columbia
election cycle.

62. D.C. COUNCIL CANDIDATE sought THOMPSON's financial support for the

election. During their discussions, THOMPSON agreed to provide financial support to D.C.

A COUNCIL CANDIDATE B, including through unreported and excessive in-kind contributions

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to be paid through HARRIS in coordination with and in support of D.C. COUNCIL
CANDIDATE B's principal campaign committee.

63. From at least in or about May 2010 until in or about September 2010,
THOMPSON, together with HARRIS, using funds provided by THOMPSON, made and
disbursed in-kind contributions of more than $26,000 in coordination with and in support of D.C
COUNCIL CANDIDATE B's principal campaign committee.

Secret Payments for 2010 D.C. COUNCIL CANDIDATE Campaign

64. D.C. COUNCIL CANDIDATE C, a resident of the District of Columbia, was an
announced candidate for Member of the D.C. Council, specifically, the Ward 1 seat, during the
2010 District of Columbia election cycle.

65. THOMPSON met with D.C. COUNCIL CANDIDATE to discuss
THOMPSON's interest in supporting D.C. COUNCIL CANDIDATE C. THOMPSON and
D.C. COUNCIL CANDIDATE discussed and agreed that THOMPSON would provide
financial support to D.C. COUNCIL CANDIDATE C, including through unreported and
excessive in-kind contributions to be paid through others in coordination with and in support of
D.C. COUNCIL CANDIDATE C's principal campaign committee.

66. From in or about April 2010. until in or about September 2010, THOMPSON,
together with others, using funds provided by THOMPSON through TCBA and DCHSI, made
and disbursed in-kind contributions in excess of $140,000 in coordination with and in support of
D.C. COUNCIL CANDIDATE C's principal campaign committee.

Secret Payments for 2011 D.C. COUNCIL CANDIDATE Campaign

67. D.C. COUNCIL CANDIDATE D, a resident of the District of Columbia, was an

announced candidate for At-Large Member of the D.C. Council during the April 2011 District of

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Columbia special election. CAMPAIGN was the principal campaign committee for D.C.
COUNCIL CANDIDATE D.

68. In or around January 2011, THOMPSON discussed with HAWKINS, HARRIS,
and D.C. COUNCIL CANDIDATE the electability of D.C. COUNCIL CANDIDATE in the
upcoming special election. THOMPSON paid for a poll to gauge, among other things, the
electability of D.C. COUNCIL D. The poll reflected favorably on D.C.
COUNCIL CANDIDATE D's electability. Based on the results of the poll, THOMPSON
decided to support D.C. COUNCIL CANDIDATE in the upcoming special election.

69. On March 10, 2011, a deadline for CAMPAIGN to report to OCF its campaign
contributions, THOMPSON met D.C. COUNCIL CANDIDATE and others at TCBA's
offices. Earlier that day, THOMPSON purchased money orders to use for conduit contributions
to pay to CAMPAIGN D. THOMPSON put D.C. COUNCIL CANDIDATE in an office at
TCBA to solicit donors by phone, while THOMPSON. solicited contributions, including conduit
contributions, in support of CAMPAIGN by phone from another office at TCBA. D.C.
COUNCIL CANDIDATE B, who was not then a candidate for political office, and a close
family member of D.C. COUNCIL CANDIDATE received the checks, money orders, credit
card forms, and donation forms fiom THOMPSON, and together they entered the information
into CAMPAIGN D's OCF report while at TCBA's offices. At the end of the evening on March
10, 2011, CAMPAIGN filed a report with OCF that reported more contributions in the
reporting period than any other candidate's principal campaign committee. The 'majority of
contributions reported as received by CAMPAIGN were for contributions reimbursed directly

and indirectly by THOMPSON.

70. At or around the same time period, THOMPSON discussed and agreed with
HAWKINS to make and disburse unreported in-kind contributions, for purposes of a GOTV
shadow campaign in support of D.C. Council Candidate D, in coordination with and in support
of CAMPAIGN in an amount in excess of the individual contribution limit under the D.C.
Campaign Act. Between March 4, 2011 and May 10, 2011, THOMPSON caused DCHSI to
transfer approximately $148,146 to BELLE and DETAILS to fund the GOTV shadow campaign
in support of CAMPAIGN D. I

71. During the campaign for the special election, THOMPSON understood that D.C.
COUNCIL CANDIDATE was aware of THOMPSON's funding of the excessive and
unreported GOTV campaign. A

CONSPIRACY TO VIOLATE FEDERAL CAMPAIGN FINANCE LAWS

72. The Federal Election Commission was an agency and department of the
United States with jurisdiction to enforce the limits and prohibitions of the Federal Election
Campaign Act of 1971, as amended, codified at 2 U.S.C. 431-455 (the "Election Act").
Similar to the D.C. Campaign Act, the Election Act limited financial influence in the election of
candidates running for federal office and provided for public disclosure of the financing of
federal election campaigns by limiting the amount and source of money that could be contributed
to a federal candidate and that candidate's authorized committee; prohibiting any person from
making conduit contributions; prohibiting direct contributions of corporate money to federal
candidates, their authorized committees, and and requiring authorized committees to file
periodic reports of receipts and disbursements. These periodic reports, which were filed with the
FEC andimade publicly available, were intended to provide citizens with a transparent record of
such contributions to candidates for federal office.

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73. THOMPSON, together with others, knowingly and willfully made:
contributions in excess of the limits of the Election Act; contributions of corporate money to
candidates for federal office and PAC 1; and contributions to candidates for federal office in
the names of other persons, each aggregating $25,000 and more in a calendar year.

Federal Conduit Contributions

74. THOMPSON made unlawful corporate and conduit contributions to candidates
for federal office in 2006, 2007, 2008, 2009, 2010, 20,11, and 2012. During calendar year 2008,
THOMPSON: directly and indirectly caused individuals to make contributions to the
authorized committees of candidates for the United States House of Representatives and
President, as well as PAC 1, aggregating $25,000 and more in that calendar' year; assured
such individuals that they would be reimbursed for their contributions; and reimbursed those

contributions using funds from THOMPSON, TCBA, and DCHSI. During calendar year 2010,

THOMPSON: directly and indirectly caused individuals to make contributions to the A

authorized committees of candidates for the United States House of Representatives and Senate,
aggregating $25,000 and more in that calendar year; assured such individuals that they would
be reimbursed for their contributions; and reimbursed those contributions using funds from
THOMPSON, TCBA, and DCHSI.

75. Between 2006 and 2012, THOMPSON utilized at least 32 conduits to make
contributions to at least 13 federal candidates and PAC 1 in excess of at least $250,000.

76. THOMPSON and others at TCBA falsely recorded and caused to be falsely

recorded certain amounts in the general ledger of TCBA and other TCBA books and records

variously as "advances," "bonuses," "advances on bonus," and consultant fees when, in

truth and in fact, those amounts represented reimbursements of corporate money for

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contributions to candidates for federal office, which contributions were made in the names of
other persons.
Shadow Campaign in Support of PRESIDENTIAL CAMPAIGN 1

77. TROY WHITE a resident of the City of New York, was the operator
of Wytehouse Marketing, Inc.

78. INDIVIDUAL A, a resident of the District 'of Columbia, worked for a public
affairs firm and served as a Senior Advisor to PRESIDENTIAL CAMPAIGN 1.

79. INDIVIDUAL B, a resident of the State of Texas, supported PRESIDENTIAL
CAMPAIGN 1 and was affiliated with CIVIC ORGANIZATION A, a civic organization that
maintained tax--exempt status underisection 501(c)(4) of the Internal Revenue Code.

80. I INDIVIDUAL C, a resident of the State of Texas, was a supporter of
PRESIDENTIAL CAMPAIGN 1.

81. In or about February 2008, INDIVIDUAL A asked THOMPSON to fund street
teams that would be paid to assist PRESIDENTIAL CAMPAIGN 1 during upcoming primary
elections. INDIVIDUAL A put THOMPSON in contact with WHITE, whose marketing firm
organized street teams, to discuss how the use of street teams could support PRESIDENTIAL
CAMPAIGN 1.

82. Shortly after introducing THOMPSON to WHITE, INDIVIDUAL A introduced
THOMPSON to INDIVIDUAL C, whom INDIVIDUAL A stated would assist WHITE with
implementing paid street teams and canvassers throughout Texas. The paid street team members
and canvassers in Texas were to include members of CIVIC ORGANIZATION A, who were
recruited by INDIVIDUAL B, and would provide support to PRESIDENTIAL CAMPAIGN 1.
THOMPSON, WHITE, and INDIVIDUAL A agreed that the paid street team members and

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canvassers would disseminate and distribute campaign materials prepared by PRESIDENTIAL
CAMPAIGN 1. THOMPSON, WHITE, and INDIVIDUAL communicated by phone in
advance of the Texas federal primary and caucus election on March 4, 2008, including through
three-way calls and the exchange of text messages.

83. In February 2008, THOMPSON authorized TCBA to transfer $233,000 to
BELLE and, in turn, HARRIS transferred $231,250 fiom BELLE to WYTEHOUSE to pay for
the services that the street team members and canvassers would provide in support of
PRESIDENTIAL CAMPAIGN 1 leading up to the Texas federal primary and caucus election on

March 4, 2008:

$134 000 on 27 2003 $133 0 on 27 2003 Texas Federal p,.ima,y and
$99 000 on 29 2008 $98 000 on 29 2003 Caucus on March 4, 2008

84. Following the Texas federal primary and caucus election, THOMPSON agreed to
continue financing WYTEI-IOUSE's paid street team members and canvassers in support of

PRESIDENTIAL CAMPAIGN in advance of the federal primary election on

-- April 22, 2008. THOMPSON, WHITE, and INDIVIDUAL A agreed that the paid street team

members and canvassers would disseminate and distribute campaign materials prepared by
PRESIDENTIAL CAMPAIGN 1. Consistent with what took place during the Texas federal
primary and caucus election, INDIVIDUAL assisted WHITE by finding individuals, many of
whom were affiliated with CIVIC ORGANIZATION A, to serve as paid canvassers for

PRESIDENTIAL CAMPAIGN I in different locations throughout

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85. In April 2008, THOMPSON authorized TCBA to transfer $156,500 to BELLE
and, in turn, HARRIS transferred $156,500 from BELLE to WYTEHOUSE to pay for the
services that the street team members and canvassers would provide in support of
PRESIDENTIAL CAMPAIGN 1 leading up to the federal primaiy election on

April 22, 2008:

$7,500 on April 1, 2008 $7,500 on April 1, 2008 Federal
$63,000 on April 11, 2008 $63,000 on April 11, 2008 Presidential Primary on
$86,000 on April 21, 2008 $86,000 on April 22, 2008 22' 2?08

86. Following the federal primary election, THOMPSON agreed to
continue financing WYTEHOUSE's paid street team members and canvassers in support of
PRESIDENTIAL CAMPAIGN 1 in advance of the Indiana and North Carolina federal primary
elections on May 0, 2008. THOMPSON, WHITE, and INDIVIDUAL A agreed that the paid
street team members and canvassers would disseminate and distribute campaign materials

prepared by PRESIDENTIAL CAMPAIGN 1. INDIVIDUAL assisted WHITE by finding

individuals, many of whom were affiliated with CIVIC ORGANIZATION A, to serve as paid

canvassers for PRESIDENTIAL CAMPAIGN 1 in different locations throughout Indiana.

87. On or about April 21, 2008, INDIVIDUAL A sent an e-mail to THOMPSON and
WHITE, titled "This is what they will need in NC -- Please advise." The e--mail forwarded
PRESIDENTIAL CAMPAIGN 1's strategy for maximizing visibility in North Carolina. Later

that day, WHITE sent a reply e-mail to INDIVIDUAL A's e~mail, copying THOMPSON on the

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e-mail, and wrote: "These are the cities we can cover in NC: Charlotte, Raleigh, Durham,
Greensboro, Fayetteville, Wilmington, Winston--Salem. Let me know what you think
88. In May 2008, THOMPSON authorized DCHSI to transfer $134,000 to BELLE
and, in tum, HARRIS transferred $133,000 from BELLE to WYTEHOUSE to pay for the
services that the street team members and -canvassers would provide in support of
PRESIDENTIAL CAMPAIGN 1 leading up to the Indiana and North Carolina federal primary

elections on May 6, 2008:

$57,000 on May 1, 2008 $56,500 on May 2, 2008 Indiana and North Carolina
Federal Primaries on May 6,
$77,000 on May 6, 2008 $76,500 on May 6, 2008 2003

89. Following the Indiana and North Carolina federal primary elections,
THOMPSON agreed to continue financing WYTEHOUSE's paid street team members and
canvassers in support of PRESIDENTIAL CAMPAIGN 1 in-advance of the Puerto Rico federal
primary election on June 1, 2008. A

90. On or about May 22, 2008, THOMPSON authorized TCBA to transfer $88,000 to
BELLE and, in turn, HARRIS transferred $88,000 from BELLE to WYTEHOUSE to pay for the
services that the street team members and canvassers would provide in support of
PRESIDENTIAL CAMPAIGN 1 leading up to the Puerto Rico federal primary election on June

1, 2008:

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. $2008

91. On or about May 29, 2008, INDIVIDUAL sent an e-mail to THOMPSON titled
"Fwd: Pics" and wrote: "We bought everything or made it here [in] PR. All the white shirts
[waving] signs or flags are our people. This is just one of the many sights across the island being
covered since last Friday. The caravan of vans together with the 18 wheeler sound system is
unbelievable . . . . See you soon."

8 92. During the 2008 presidential primary election cycle, THOMPSON authorized
approximately $611,500 to be transferred from TCBA and DCHSI to BELLE, of which
$608,750 was funneled to WYTEHOUSE to pay for services WYTEHOUSE and others
provided in support of PRESIDENTIAL CAMPAIGN 1. These services included assembling
and organizing paid street teams and canvassers to disseminate and distribute campaign materials
prepared by the PRESIDENTIAL CAMPAIGN 1, including posters, lawn signs, pamphlets, and
stickers. The agreed--upon goal of these efforts was to raise PRESIDENTIAL CAMPAIGN 1's
visibility during the 2008 presidential primary election cycle.

93. As intended by THOMPSON, the hundreds of thousands of dollars in corporate
funds THOMPSON funneled through BELLE and to WYTEHOUSE to provide services in
support of PRESIDENTIAL CAMPAIGN 1 during .the 2008 election cycle were never reported
to the FEC because THOMPSON knew that funding this effort violated federal campaign

finance laws.

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94. THOMPSON directed and caused the wire transfers from TCBA and DCHSI to
BELLE to be recorded in the books and records of TCBA and DCHSI as advances to

THOMPSON and consulting fees, respectively, in order to conceal the true nature of the illegal

I corporate and excessive campaign contributions to PRESIDENTIAL CAMPAIGN l.

95. During these time periods, a major political party in Texas employed what is

known as a "two-step" voting process in which voters were allowed to vote twice, once in a

- primary and once in a caucus. Approximately two-thirds of the delegates would go to the winner

4 of the primary and approximately one--third of the delegates would go to the winner of the

caucus.

96. On or about April 11, 2008, THOMPSON received an e-mail from INDIVIDUAL
in which INDIVIDUAL wrote: "Mr. Troy White suggested I contact you in
regards to a challenge to the Texas Democratic Party caucus system. Like you I am a strong
supporter of CAMPAIGN 1] and have done my best to help [it] win. Along
with the help we were able to do through you, I have organized over 400 volunteers for
CAMPAIGN 1] during super Tuesday in AZ and NM.
CAMPAIGN 1] won both of those states. In Texas I helped organize the volunteer effort for
south Texas and have been in charge of senatorial district 19 for the caucus.
CAMPAIGN 1] carried senatorial 19 caucus 70/30. I now believe we have a decent shot of
knocking out the whole caucus system depriving 2] of those delegates which
[they] won state wide. ORGANIZATION believes we have a good possibility of
throwing out the Caucus system in Texas by challenging the caucus system as having a
discriminatory impact against the Latino (predominately Mexican-American) community in
Texas. . . . Thank you for allowing us to help CAMPAIGN

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97. On or about April 14, 2008, INDIVIDUAL B, on behalf of CIVIC
ORGANIZATION A, attended a meeting at TCBA that included THOMPSON and others.
During this meeting, THOMPSON agreed to finance a demonstration in the District of Columbia
that would be organized by CIVIC ORGANIZATION A. The demonstration was to take place

in front of a major political party's headquarters regarding the decision not to seat delegates from

a state whose primary election had already occurred. THOMPSON agreed to pay for the meals,

lodging, promotion, and transportation of the demonstrators who were CIVIC ORGANIZATION
A members.

98. On or about April 24, 2008, THOMPSON authorized DCHSI to transfer
approximately $150,000 to CIVIC ORGANIZATION A's bank account to pay for the
demonstration in the District of Columbia organized by CIVIC ORGANIZATION A.

99. In or about April 2008, THOMPSON also agreed to finance a lawsuit that would
be filed by CIVIC ORGANIZATION A in federal court in Texas to challenge the Texas "two-
step" voting process.

100. On or about April 30, 2008, THOMPSON authorized DCHSI to transfer
approximately $50,000 from its corporate bank account in the District of Columbia to CIVIC
ORGANIZATION A's bank account to pay for the lawsuit in Texas challenging the "two-step"
voting process.

101. I On or about May 1, 2008, INDIVIDUAL sent an e-mail to THOMPSON and
INDIVIDUAL A titled "Media Coverage Florida Voters" and wrote: "There was a great event
today organized by ORGANIZATION . . . . Hundreds came to DC and demonstrated

in front of the [political party

102. On or about May 14, 2008, INDIVIDUAL sent an e-mail to THOMPSON and
INDIVIDUAL A titled ORGANIZATION TRO Motion" and provided an update on
the status of the lawsuit filed in federal court in Texas challenging the "two-step" voting process.
INDIVIDUAL directed THOMPSON and INDIVIDUAL A to contact INDIVIDUAL with
any questions.

103. THOMPSON directed and caused the wire transfers to CIVIC ORGANIZATION
A to be recorded in DCHSI's books and records as a charitable contribution when, in truth and in
fact, the funds were provided to assist PRESIDENTIAL CAMPAIGN 1.

CONSPIRACY TO VIOLATE THE INTERNAL REVENUE LAWS

104. EMPLOYEE A was a resident of the Commonwealth of Virginia, a certified
public accountant, and the controller for TCBA, working under THOMPSON's direction.
THOMPSON and EMPLOYEE A caused TCBA to disguise and record falsely TCBA's conduit
contribution reimbursement payments to TCEA's partners, principals, employees, and
consultants as "advances," "bonuses," "advances on bonus," and consultant fees in
TCBA's books and records. THOMPSON and EMPLOYEE A knew that TCBA's conduit
contribution reimbursement payments were not accurately described in TCBA's books and
records. .

105. In or about April 2007, THOMPSON and EMPLOYEE A caused TCBA to
misrepresent, conceal, and improperly deduct TCBA's conduit contribution reimbursement

payments to LEE CALHOUN a TCBA principal and conduit contributor, in

TCBA's Form 1120 U.S. Corporate Income Tax Return for 2007. THOMPSON directed

EMPLOYEE A to zero--out an "advance" account that EMPLOYEE A had created in TCBA's
books and records in CALHOUN's name. To do so, EMPLOYEE A falsely designated as a

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"bonus" approximately '$78,000 in past conduit contribution reimbursement payments to
CALHOUN by TCBA. EMPLOYEE A grossed-up the purported "bonus" to allow TCBA to
withhold approximately $47,000 in taxes that CALHOUN would have owed on his personal
income tax return, which allowed CALHOUN to avoid incurring any tax liability as a result of
his participation as a conduit contributor. THOMPSON and EMPLOYEE A caused TCBA to
issue a false W-2 tax form to CALHOUN for 2007, which overstated CALHOUN's actual
income from TCBA. THOMPSON and EMPLOYEE A knew that TCBA's conduit contribution
reimbursement payments to CALHOUN were not tax-deductible by TCBA.

106. THOMPSON and EMPLOYEEA caused TCBA to file false corporate income
tax returns that misrepresented, concealed, and improperly deducted TCBA's conduit
contribution reimbursement payments to certain TCBA employees in TCBA's Form 1120 U.S.
Corporate Income Tax Returns for 2007 and 2008. THOMPSON and EMPLOYEE A caused
TCBA to prepare and send false W-2 tax forms to certain employees that included conduit
contribution reimbursement payments as income to those employees. THOMPSON and
EMPLOYEE A knew that TCBA's conduit contribution reimbursement payments to TCBA's
employees were not tax-deductible by TCBA.

107. THOMPSON and EMPLOYEE A caused TCBA to file false corporate income
tax returns that misrepresented, concealed, and improperly deducted TCBA's conduit
contribution reimbursement payments to consultants in TCBA's Form 1120 US, Corporate
Income Tax Retums for 2006, 2007, 2008, 2009, 2010, and 2011. For example, THOMPSON
and EMPLOYEE. A caused TCBA to misrepresent, conceal, and improperly deduct TCBA's
conduit contribution reimbursement payments to STANLEY STRAUGHTER, a consultant for
TCBA and a conduit contributor, in TCBA's Form 1120 U.S. Corporate Income Tax Returns for

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2008, 2009, and 2010. THOMPSON and EMPLOYEE A knew that TCBA's conduit
contribution reimbursement payments to consultants were not tax-deductible by TCBA.

108. THOMPSON caused DCHSI to file a false Form 1120 Corporate Income
Tax Return that misrepresented, concealed, and improperly deducted DCHSI's payments of a
total of $134,000 to WYTEHOUSE, which were made in support of PRESIDENTIAL
CAMPAIGN 1, as consulting fees and tax-deductible business expenses. THOMPSON knew
that DCHSI's payments to WYTEHOUSE were not tax-deductible by DCHSI.

109. caused DCHSI to file a false Form 1120 U.S. Corporate Income
Tax Return that misrepresented, concealed, and improperly deducted DCHSI's payments of a
total of $200,000 to CIVIC ORGANIZATION A, which were made in support of
PRESIDENTIAL CAMPAIGN 1, as tax-deductible charitable contributions. THOMPSON
knew that DCHSI's payments to CIVIC ORGANIZATION A were not tax-deductible by
DCHSI.

110. In or about April 2010, the IRS notified TCBA and THOMPSON of an audit.
Prior to responding and participating in the IRS audit, THOMPSON informed EMPLOYEE A

about the impending audit. From in or about July 2010, through March 2, 2012, THOMPSON

and EMPLOYEE A, at direction, caused TCBA to provide false and misleading

statements and documents from TCBA's general ledger and its books and records to the IRS
auditor in a continuing effort to misrepresent and conceal TCBA's unlawful conduit and in-kind
contributions.

111. THOMPSON discussed the IRS audit with two TCBA officers (hereafter,
and In response to specific requests from the IRS auditor
concerning TCBA's shareholder loans and advance accounts, THOMPSON caused a TCBA

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employee to create false, backdated documents, including false promissory notes. THOMPSON
met with OFFICER A and OFFICER to discuss the need to sign the false promissory notes and
to provide the false promissory notes to the IRS auditor. This was done to conceal TCBA's
conduit contributions fi'om the IRS. As part of that meeting, THOMPSON, OFFICER A, and
OFFICER executed the false promissory notes. As agreed, THOMPSON caused the false
promissory notes to be given to the IRS auditor.

112. In or about December 2011, THOMPSON and HARRIS agreed that she would
file a Form l120X Amended U.S. Corporation Income Tax Return for BELLE in an effort to
conceal TCBA's funding of the shadow campaign for MAYORAL CAMPAIGN A.
THOMPSON caused TCBA to create additional false documents, and provided the false
documents to HARRIS, in an effort to conceal TCBA's funding of the shadow campaign for
MAYORAL CAMPAIGN A.

This statement of the offense is not intended to constitute a complete recitation of all
facts known by THOMPSON, but is, instead, intended to provide the necessary legal basis for
the guilty plea.

RONALD C. MACHEN JR.
United States Attorney

No. 44 889
By: '5 -

Michael K. Bar No. 430517
Loyaan A. Egal, New York Bar

Lionel Andre, D.C. Bar No. 422534

Ellen Chubin Epstein, D.C. Bar No. 442861
Jonathan P. Hooks, D.C. Bar No. 468570
Ephraim (Fry) Wernick, D.C. Bar No. 497158
Assistant United States Attorneys

United States Attorney's Office

555 Fourth Street, N.W.

Washington, D.C. 20530




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'Defendant's Acceptance

I have read this Statement of the Offense and carefully reviewed every part of it with my
attorneys. '1 am fully satisfied the legal services provided by my attorneys in connection
with this Statement of the Offense and all matters relating to it. I fully understand this Statement
of the Offense and voluntarily agree to it. No threats have been madeto me, nor am I under the
influence of anything that could impede my ability to understand this Statement of the Offense
fully. No agreements, promises, understandings, or representations have been made with, to, or

for me other than those set forth in the plea agreement.

Date SON

Defense Counsel's Acknowledgment
We are Jeffrey E. Thompson's attorneys. We have reviewed every part of this Statement
of the Offense with him. It accurately and completely sets forth. the Statement of the Offense
agreed to by the defendant and the Office of the United States Attorney for the District of

Columbia.

Dateg It flo/\/

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