beaumont isd contractor calvin walker's indictments
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Case 1 :1 1 -cr-00067-TH "SEALED* Document 2 Filed 05/04/11 Paoe 1 of 18p.tteo. o
"#;"* nlSiJg*r"J,"# FI* ^,
IN TI{E UNITED STATES DISTRICT COI'RTFOR TFIE EASTERN DISTRICT OF TEXAS MAY C 4 2OII
BEAI,IMONT DTVISION
UNITED STATES OF AMERICA
vs.
.CAI,'WNGARYWAIKER
u"oou,o, MALAND. CLERK
DEPUTYJ
J
$
CRIMINALNO. l:1l-CR- $ JIralg fieailf;eJy'
INDICTMENT
THE UNITED STATES GRAND JURYCHARGES:
Counts One - Three (Violation: 18 U.S.C. S134fMail Fraud; 18 U.S.C. S2
Aiding and Abetting)
From in or about September 2008, to in or about December 2010, in the Eastern
District of Texas and elsewhere, Calvin Gary Walkeq defendanl irnowingly devised and
intended to devise a scheme and artifice to defraud and to deceive the Beaumont lndependent
School District by the submission offalse and fraudulent invoices for electrical supplies and
materials never purchased or said invoices being inflated beyond the actual cost and
contracted mark-up by means offalse and fiaudulent pretenses and representations knowing
at the time that such preterses and representations would be and were false when made, said
scheme so devised and intended to be devised as follows:
Introduction
Calvin Gary Walker, defendan! doing business as Walker's Electric Company, was
chosen by the Beaumont Independent School District @ISD) through a competitive bidding
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process in August 2008 to exclusively provide electrical services to BISD which could not
be provided by the staff electricians. As part of the written contract with BiSD' the
defendant was to provide eiectrical supplies and materials at cost plw a tenpelcent mark-up.
Acklitionally, any use of subcontractors for an electrical project was aiso to be provided at
cost plus a ten percent mark-up. similarly, any rental equipment needed for an electrical
project was also to be provided at cost plus a ten percent mark-up. The contract between
BISD and Calvin Gary Walker, defendant, doing business as Walker's Ele.ctric Company,
was renewed in 2009 for an additional year by the BISD board of trustees and was again
awarded to the defendant and his company by competitive bid in 2010 under the same terms
and conditions-
The Scheme
calvin Gary walker, defendant, doing busiaess as walker's Electric company,
would submit invoices to BISD for costs of materials, supplies, and subcontractor services
which were routinely false and fraudulent in that the cost arnounts were inflated far beyond
the actual costs incurred by defendant. Such Walker's Electric Company invoices to BISD
for payment were sometimes accompanied by suppiier invoices for materials which were
altered or fabricated to reflect amolnts larger than the actual costs ofmaterials, supplies, and
subcontractor services. As a furtherpart
of saidscheme to obtain payments from BISD on
the invoices submitted to BISD for supplies and materials, Calvin Gary Walkel defendant
would also attach wa.lkey's Electric Company checks made payable to various suppliers in
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Case 1:'11-cr-00067-TH -SEALED* Document 2 Filed 05/04/1 1 Page 3 of 18
the inflated amounts which were never actually pfesented to or negotiated by such suppliers,
Aware ofthe intentionai misrepresentationsin the documentation submitted to BISD, Calvin
Gary Walker, defendant, also fraudulently invoiced an inflated ten percent mark-up based
upon the fraudulent material and supply costs.
In addition to the above false and fraudulent submissions to BISD, Calvin Gary
Walker, defendant, also fraudulently invoiced charges for bucket tuck lentals and the
related ten percent mark-up when, in fact, as the defendant well kneq he owned said bucket
truck equipment, and did not incur any rental costs.
As a result of said scheme and artifice to defraud, calvin Gary walker, defendant,
received approximately $3,700,000 or more in firnds from BISD in excess ofthe actual costs
incurred and the related ten percent mark-up, causing a loss to BISD of the same anount.
on or about the dates listed below, in the Eastem District of Texas and elsewhere,
Calvin Gary Walker, defendant, aided and abetted by others known and unknown to the
gand jury, for the puryose of executing the aforesaid scheme and altifice, did knowingly
cause to be delivered by the United States Postal Service or by commercial interstate carrier
according to the directions thereon, a letter conlaining a checig for the amount listed below,
as a payment for materials or supplies not provided to BISD, addressed to walker's Electric
Co., 3710 Roland Road, Beaumont, TX 77708'
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Case 1 :1 1-cr-00067-TH .SEALED" Document 2 Filed 05/04/11 Page 4 of 18
Count Date of Mailing Amount of Check BISDProject
$1s7,674.68
Amount of FalseMaterial Costs
May 1,2009 $ 82,700.00 Ozen HS SoftbalV $ 647,000
2 April 30,2010 $ 79,385.0iBaseball Lighting
SmithMiddle $ 18,000School repairs
Amelia/Caldwood $87,000Portable Buildings
It:Jy 22,2010
All in violation of 18 U.S.C. $$ 1341 and 2.
Counts Four- Nine (Violation: f8 U.S.C. S1343Wire Fraud; 18 U.S'C. 52
Aiding and Abetting)
The grandjury realleges the introduction and scheme and artifice described above in
the indictment in Counts One tlrough Three and incorporates the same by refelence.
on or about the below dates, in the Eastem Distict of Texas and elsewhere, calvin
Gary Walker, defendant, aided and abetted by others known and unknown to the grand jury,
for the pu4rose ofexecuting or attefiipting to execute the aforesaid scheme and artifice, did
knowingly cause to be transmitted in interstate and foreign commerce, by means of a wire
communication, certain signs, Signals, and sounds, narnely, electronic mailings or emails to
BISD of invoices containing inflated amounts for materials, supplies and subcontractor
services, and electronic tansmissions to other entities, as described below, which caused or
facilitated the payment of funds to defendant and his company:
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Count Date
February24,2009
Febrmry 26,2009
March20,2009
Apil24,2009
8 August 20,2009
November 30, 2010 Email of invoice ftomCalvin Walker to BISD
AIl in violation of 18 U.S.C. $$ 1343 and 2.
Nature of Wire BISD Amount of FalseTransmission Project Materials Costs
Facsimile fiom Walker Ozen SoftbalV 5647,000Electric to Goidleaf Baseball lightingFinancial, Ltd.
Emails tolfrom Walker Ozen Softbaly $647,000Electric to Goldleaf Baseball lightingFinancial, Ltd.
Electronic file transfer Ozen SoftbalV $647,000by Summit Electric Baseball lightingbetween Beawnont, Texasand Albuquerque, New Mexico
Electronic file transfer Regina HowelV $ 1 , I 83 ,000by Summit Electric South Park campusbetween Beaumont, Texasand AJbuquerque, New Mexico
Electronic file transfer Regina HowelV $343,000by Sunlnit Electric South Park campusbetween Beaumont, Texasand Albuquerque, New Mexico
Soulh ParkStadium lighting
$ 85,000
CountTen (Violation: 18 U.S.C. $2314Interstate Transportation
ofFunds by Fraud)
On or about the lSth day of December, 2009, in the Eastem District of Texas and
elsewhere, Calvin Gary Walker, defendant, did cause to be transported and transfered in
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interstate cormerce fiom the State of Texas to the State ofNew York, money, in the form
ofa businesscheck, No. 565676, in the amount of$138,596.70, by depositing the check into
an account maintained by the defendant at Capital One, N.A., knowing such check to have
been taken by fraud that being a scheme to inflate electrical maintenance invoices submitted
to the Beaumont Independent School District for paymen! inciuding an invoice for materials
used at Dunbar Elementary School, of which, as the defendant well knew, was false and
aaudulent in that the amount ofmaterials invoiced had been inflated beyond the conkactual
amount of cost plus ten percent maxk-up.
All in violation of 18 U.S.C. $ 23 14.
Counts Eleven - F ourteen (Violatiop: 18 U.S.C. $2314Ilterstate Transportation
of Funds by Fraud)
On or about tle dates listed belo% in the Eastem District of Texas, Calvin Gary
Walker, defendant, did cause to be transported and transferred in interstate cofirnerce from
the State of Texas to the State oflouisiana, money, in the form of business checks ofa
value of$5,000 or more as listed below, by depositing the checks into an account maintained
by the defendant at Capi'ral One, N.A., knowing such checks to have been taken by fraud, that
being a scheme to inflate elecftical maintenance invoices submitted to the Beaumont
Independent School District for paym.en! which, as the defendant well knew, were false and
fraudulent in that the amount ofmaterials invoiced had been inflated beyond the contractual
amount of cost plus ten percent maxk-up,
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Case 1:11-cr-00067-TH-SEALED* Document2 Filed 05/04/11 PageTof 18
Count Date Check No. Amount BISD Project
li May 29,2009 557268 $ i,285,064'00Regina/South Park
12 Ju1y30,2009 559382 $ 160,110.50 BinghamElementary
13 March5,2010 569M2 $ 119,051.02 FrenchElem'trailen
14 hily22,2010 575639 $ 157,674'68 Amelia/Caldwood
AII in violation of 18 U.S.C. $ 2314.
Counts Fifteen - Sixteen (Violation: 18 U.S'C' 5666Fraud upon Programs
receiving federal fu nds)
On or about the dates listed below, in the Eastern Distriot of Texas' Calvin Gary
walker, defendant, being an agent ofthe Beaumont Independent School Distict, Beaumon!
Texas, a locai government or organization receiving in the one year period begiruring January
1, 2008, federal benefits in excess of $10,000, did steal, embeufe and obtain by fraud'
propedy worth at least $5,000 under the care, custody, and control of the Beaumont
Independent Sohool District, in that the defendant submitted an invoice fol the cost of
materials for the repair of the following BISD facilities which was falsely and fraudulently
inllatedintheapproximateamountslistedbelow,anduponwhichthedefendantreceived
payment:
Count Date ofBISDCheck
15 October 16,2008
Amount of Check BISD Amount of FalseProject Material CostsInvoiced
S 5gg!757.26 MLK Middle School $ 91'000hurricane rePairs
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16 October16,2008 5599,757.26 SmithMiddleSchool $167'000hurricane rePairs
AII in violation of 18 U.S"C. $ 666(aXlXA).
Counts Seventeen-Twenty-four (Violation: 18 U.S.C. $666Fraud upon Programsreceiving federal funds)
on or about the dates listed below, in the Eastem District of Texas, Calvin Gary
walker, defendang being an agent ofthe B eaumont Independent school Distict, Beaumonq
Texas,alocalgovemmentororganizationreceivingintheoneyearperiodbegimingJanuary
L zoag, federal benefrts in excess of $10,000, did steal, embezz|e and obtain by ftaud'
property worth at least $5,000 urder the care, custody, and control of the Beaumont
Independent school District, in that the defendant submitted invoices fol the cost ofmatrials
or labor for the repair of the tbllowing BISD facilities which were falsely and fraudulenfly
inflated in the approximate amounts listed below, and upon which the defendant received
palment:
Count
11
18
Date of BISD Amount of CheckCheck
April 3,2009 $ I,153,300.00(initial PaYment)
April30,2009 $82,700.00(frnal payment)
May 29,2009 $ 1,285,064.00
BISD Amount of FalseProject Material (Labor)
Costs Invoiced
Ozen HS SoftbalV $ 647,000Baseball Lighting
Ozen HS SoftbalV same as Count 17Baseball Lighting
Regina Howell $ 588,000temporary campus
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20 May 29,2009 $1.285.064.00 SouthPark $ 594,000temporary campus
JuIy30,2009 $ 160,110.50 Bingham-Blanchette $ 145,000Elementary School
September 10, 2009 $ 1,592,839.10 Regina HowelV $ 343,000South Park
23 September 10,2009
rcmporar7 campuses
$ 1,592,839.10 ReginaHowelV $ 83,200SouthPark (labor)temporary camPuses
$ 138,596.70 Dunbar Elem. trailers $ 112,0004 December i 8. 2009
All in violation of 18 U.S.C. $ 666(a)(1XA).
Counts Twent!'-five - Thirtv (Violation: 18 U.S.C. $666Fraud upon programs
receiving federal funds)
On or aboul the dates listed below, in the Eastem District of Texas, Calvin Gary
Walker, defendant, being an agent ofthe Beaumont Independent School District, Beaumon!
Texas, a local govemment or organization receiving inthe one year period beginning January
1,2010, federal benefits in excess of $10,000, did steal, embezzle and obtain by fraud,
property worth at least $5,000 under the care, custody, and control of the Beaumont
Independent School District, in that the defendant submitted invoices for the cost ofmaterials
for the repair of the following BISD facilities which were falsely and fraudulently inflated
in the approximate amounts listed below, and upon which the defendant received payment:
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Case 1:1't-cr-00067-TH -SEALED* Document2 Filed 05/04/1 1 Page 10 of 18
Count Date of BISD Amount of Check BISD Amount of False. Check Project Material Costs
25 March5,2010 $ 119,051.02 FrenchElementarv $27'000temP. classrooms
26 Api129,2010 $ 79,385.01 SmithMddle $ 18'000School repairs
27 1u1y22,2010 $157,674.68 SouthParkstadium $ 20'000
28 luly 22;2010 8 157,674.68 Amelia/Caldwood $ 87,000Portable Buildings
29 October2l,2010 $164,435.40 Installgeneratorat $ 35,000BISD Administration
30 December 3, 2010 $ 499,000.00 South Park M.S.. stadium lights
All in violation of 18 U.S.C. $ 666(aX1)(A).
$ 85,000
Count Thirtv-one (Violation: 18 U.S.C. S666' Fraud upon programs
receivin g federal funds)
On or about the 16th day of October, 2008, in the Eastern District of Texas' CaMn
Gary Walker, defendant, being an agent of the Beairmont Independent School District,
Beaumont, Texas, a local govemment or organization ieceiving in the one year period
beginning January 1,2008, federal benefits in excess of$10,000, did steal, embezzle and
obtain by fraud, property worth at least $5,000 under the care, custody, and controlof the
Beaumont Independent School Distric! in that the defendant submitted two invoices for the
cost of bucket truck rentals of $1 12,000 for the repair of Smith Middle School and King
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Mddle School which was false and fraudulent in that the defendant did not rent said
equipment or invoice the equipment at cost, and upon which the defendant received payment
in that aurount.
All in violation of 18 U.S.C. $ 666(aXl)(A).
Count Thirty-two (Violation: 18 U.S.C. 5666Fraud upon programsreceiving federal funds)
On or about the 10th day of September, 2009, in the Eastern District of Texas, Calvin
Gary Walker, defendant, being an agent of the Beaumont lndependent School District,
Beaumont, Texas, a local govemment or organization receiving in the one year period
beginning January i, 2009, federal benefits in excess of $10,000, did steal, embezzle and
obtain by fraud, property worth at least $5,000 under the care, custody, and control of the
Beaumont Independent School District, in that the defendaot submitted an invoj.ce for the
cost of bucket truck rentals of $546,000 for the electical s]'sterr construction of Regina
Howell and South Park temporaxy campuses which was false and fraudulent in that the
defendant did not rent said equipment or invoice the equipment at cost, and upon which the
defendant received payment in that amount.
All in violation of 18 U.S.C. $ 666(aX1XA).
CountThirty-three(Violation: 18 U.S.C.
$1957Money Laundering)
On or about the 1 lth day of Septemb er, 2009, in the Eastem District of Texas and
elsewhere, Calvin Gary Walker, defendant, did klowingly engage and attempt to engage
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in a monetary transaotion in criminally derived property ofa value greater than $ 10,000 and
which was derived from a specified unlawful activity, that monetary transaction being the
negotiation of a check ftom the Beaumont lndependent School District in the amount of
51,592,839.10 by the defendant into the J.P. Morgan Chase Banlg which said monetary
transaction involved the proceeds of specified unlawful activily, that is, wire fraud as
described in Count 8 of this indictuent ani the theft of fimds as described in Coimts 22, 23
and 32 ofthis indictnent which is adopted herein, conduct puoishable under the laws ofthe
United States.
All in violation of 18 U.S.C. $ 1957(a).
Count Thirtv-four {Violation: 18 U.S.C. 51957Money Laundering)
On or about the 8th day of September, 2009, in the Eastem District of Texas and
elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage
in a monetary transaction in criminally derived property of a value greater than $ 10,000 and
which was derived from a specified unlawfui activity, that monetary hansaction being the
purchase of a 2010 Mercedes S5F, 4 door, VIN WDDNG7BB0AA28863 1, in the amount of
$117,000, which said monetary transaction involved the proceeds of specified unlawful
activity, that is, the theft of fu:rds described in Counts 7,4,5,6,7,11 - 12, and 15 - 21 ofthis
indictuent which is adopted herein, conduct punishable under the laws of the United States.
All in violation of 18 U-S.C. $ 1957(a).
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CountThirty-five (Violation: 18 U.S.C. $1957Money Laundering)
On or about the 27st day of September, 2009, in the Eastern District of Texas and
elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage
in a monetary transaction in criminally derived property ofa value greater than $ 10,000 and
which was derived ftom a specified unlawful activif, that monetary transaction being the
purchase ofa Transamerica Preferred Choice Fixed Annuity Contract 02TPC047 479 for the
amount of$1,600,000 by the defendant using fimds from the JP Morgan savings account
nurnber *****+7080of defendant which said monetary ftansaction involved the proceeds
of specifred unlawful activity, that is, the theft of funds described in Counts I,4, 5,6,7,8,
11 - 12,15 - 23, and 32 of this indictnent which are adopted herein, conduct punishable
under the laws of the United States.
Al1 in violation of i8 U.S.C. $ i957(a).
Count Thir8-six (Violation: 18 U.S.C. $1957Money Laundering)
On or about the 7th day of Octobet,2009, in the Eastem District of Texas, Calvin
Gai-y Walker, defendant, did knowingly engage and attempt to engage in a monetary
transaction in criminally derived property of a value greater than $10,000 and which was
derived from a specified unlawfr{ activity, that monetary transaction being the purchase ofa uact of land for $175,000 on Pleasure Island, Port Arthur, Texas, described as Tract 31A.'
Lafitte's Landing, which said monetary transaction involved the proceeds of specified
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unlawful activity, tlat is, the theft of funds as described in Counts l,4,5,6,7,11 - 12,and
15 - 21 of this indictment which is adopted herein, conduct punishable under the laws ofthe
United States.
All in violation of 18 U.S.C. $ i957(a).
Connt Thirtv-seven (Violation: 18 U.S.C. 51957Money Laundering)
On or about the 28th day of October, 2009, n the Eastem District of Texas and
elsewhere, Calvin Gary Walker, defendant, did knowingly engage and attempt to engage
in a monetary transaction in criminally derived property of a value greater than $ 10,000 and
which was derived from a specified uniawfill activity, tlat monetary transaction being the
purchase ofa Transarnerica Preferred Choice Fixed A:rnuity Contxact 02TPC080685 for the
amount of $1,800,000 by the defendant using frrnds ftorn the JP Morgan savings account
number *****{'7080of defendang which said monetary transaction involved the proceeds
of specified unlawfirl activity, that is, the theft of fiuds described in Counts 1, 4 through 8,
11 - 12, 15 - 23, ard 32 ofthis indicfinent which is adopted herein, conduct punishable under
the laws of the United States.
All in violation of 18 U.S.C. $ 1957(a).
NOTICE OF INTENTION TO SEEK CRIMINAI FORFETTURES
As a result of committing one or more of the offerses alleged in Counts 1 - 37 of the
indictnent Calvin Gary Walker, defendan! did use or intend to use personal property to
commit said offenses and shall forfeit to the United States such property pursuant to 18
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U.S.C. $981(a)(lXC), $ 982 (aXa), and28 U.S.C. $ 2461(c), includingbutnotlimitedtothe
following:
1. Personal Property
a. MONEY JIIDGMENT, being asum ofmoney equal to $3,700,000.00 in United Statescurrency rqxesenting the amount of proceeds obtained as a result of the above fraudoffenses, in violation of I 8 U.S.C. $ $ 666, 1341, 1343, 2314, and 1957.
b. The following assets or funds representing proceeds obtained as a result ofthe abovefraud offenses, in vioiation of 18 U.S.C. $$ 666, 1341, 1343,2314, and 1957:
A Trarsarnericd Preferred Choice Fixed Annuity Contract 02TPC 047 47 9, pwchnedfor $1,600,000 on or about September 21, 2009, using funds from the JP Morgansavings account number ***!k**7080of Calvin Walker;
A TransamericaPrefened Choice Fixed Amuity Contract 02TPC080685 purchasedfor $1,800,000 on or about October 28,2009, using frnds from the JP Morgansavings account numbef, *x**'r*7080 of Calvin Walker;
A 2010 Mercedes S5F, 4 door, \IIN WDDNG7Bts0AA288631, purchased on orabout September 8,2009, fromMercedesBenz ofHouston, Greenway, inthe amormtof $1 17,000;
Tbree BISD checks in the amounts of $9,743.86, $1O,325.34, nd$499,000, andthefunds they represent, seized from the defendant on or about December 7 ,2010.
2. Real Property
A parcel of land purchased on or about Octo ber'7,2009 described as Tract 31A ofa Replat of Lots numbered Thirty-one and Thirty-two (3 1 &32) ofLafitte's LandingPhase Two, a 106.97 acre subdivision out of and a part of the N. Coleman Survey A-12 and the Dennis Gahagan League, Abstract No. 123, in the City of Port Arthur,
Jefferson County, Texas, as the sameappears upon the map or plat thereof, on file and
of record in Vo1.16 page 309 Map Records of Jefferson Cotmty, Texas;
3, Substitute Assets
If as a result of any act or omission by defendan! any of the property described
Page
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above:
(a) cannot be located upon the exercise of due diligence;(b) has been transferred or sold tq or deposited with, a third party;(c) has been piaced beyond the jurisdiction of the court;(d) has been substantially diminished in value; or(e) has been commingled with other property which cannot be divided withoutdifficulty;
it is the intent ofthe United States, pursuant to Title 2 I , United States Code, Section 853 (p),
incorporated by reference by 18 U.S.C. $981(aX1XC) and $ 982 (a)(a), and 28 U.S'C' $
Zail@),to seek forfeiture of any other property of defendant up to the value ofthe above
forfeitabie properly, including but not linited to all properfy, both real and personal owned
by defendant.
By virnre of the commission of the aforementioned offenses charged in this
Indictnent by the defendan! any and ail interest the defendant has in the above-described
property is vested in the United States and hereby forfeited to the United States for its use or
for any other disposition in iG discretion pursuant to 18 U.S.C. $981(aX1XC) and $ 982
(a)(4), and 28 U.S.C. $ 2461(c).
ASSISTANT I'NITED STATES ATTORNEY
'RAND J['RY FOREPERSON
JOHNM. BALESUNITED-STATES ATTORNEY
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IN TTM UNITED STATES DISTRICT COI'RTFOR THE EASTERN DISTRICT OF TEXAS
BEAI'MONT DTVISION
LINITED STATES OF AMERICA 6$VS. t CRIMINAINO. t:11-CR-!
CALVINGARY\MAIKER O
NOTICE OFPENALTY
Counts One - Three
Violation: 18 U.S.C. $ 1341 (Mail Fraud); 18 U.S.C. $ 2 (Aiding andAbettingan Offlense)
Penait: Not more than twenty (20) years imprisonment; a fine of not morethan $250,000, or both. A terrn of supervised release of not morethan five (5) years.
Soeciai Assessment: $100
Counts Four - Nine
Violation: 18 U.S.C. g 1343 (\Mire Fraud); 18 U.S.C. g 2 (Aiding and Abettingan Offense)
Penalty: Not more than twenty (20) years imprisonment; a flne of not morethan $250,000, or both. A term of supervised release of not morethan five (5) years.
Special Assessment: $100.00
Counts Ten - Fourteen
Violation: 18 U.S.C. $ 2314 (nterstate Transportation of Money by Fraud)
Penaltv: Imprisonment of not more than ten (10) years, a fine not to exceed$250,000.00, or both. A term of supervised release ofnot more tha:r tbree (3)years rnay be imposed.
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Snecial Assessment: $100.00 for each count.
Counts Fifteen - Thirtv-two
Violation: 18 U.S.C. $ 666(a)(1)(A) (Fraud upon Programs receiving federalfunds)
Penalty: Imprisonment of not more than ten (10) years, a fine not to exceed$250,000, or both; a temr of supewised release of not more than tl'lree(3) years.
Special Assessment: $ I00.00
Counts Thirty-three - Thirtv-seven
Violation: 18 U.S.C. $ 1957 (vloney Larmdering Transactions Greaterthan $10,000)
Penalty: Not more than ten (10) yean imprisonment; a fine of not more than$250,000 or twice the value ofthe criminally derived property, or both;a term of supervised release ofnot more lhan tlree (3) years'
Soeciai Assessment: $100.00
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