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1 2I STEVEN W MYHRE First Assistant United States Attorney Case 2Q6-cr-00100RCJ-RJJ Document 1 Filed 03/22/2006 Page 1 of ,, public officials as set forth below 20 1 From in or about June 2005, to in or about March 2006, Maynard 23 citizens of Nye County, Nevada, of the intangible right to the honest services of their elected 22 executed, and attempted to execute, a scheme and artifice to deprive and defraud the 21 Martin RICHARDS also known as Joe RICHARDS, defendant herein, devised, planned, 18 At all times relevant to this Indictment, unless otherwise stated: 19 Introduction 17 THE GRAND JURY CHARGES THAT: 14 MAYNARD MARTIN RICHARDS, 18 USC 1343, 1346, and 2 - Fraud 16 DEFENDANT ) 15 ) aka JOE RICHARDS, ) by Wire Deprivation of Honest Services 13 VS ) VIOLATIONS: 12 PLAINTIFF, 2:06-CR- / 11 Ij 11 UNITED STATES OF AMERICA, ) CRIMINAL INDICTMENT 10 -ooo 8 DISTRICT OF NEVADA UNITED STATES DISTRICT COURT 6 5 (702) /Fax: (702) Las Vegas, Nevada Las Vegas Blvd South, Suite 5000 Assistant United States Attorney 31 KIMBERLY M FRAYN United States Attorney 1 DANIEL G BOGDEN

2 2 2 Nye County, Nevada, was a political subdivision of the State of Nevada I The Nye County Commission 2 26 government 251 Commissioner Trummell also served as a cooperating witness with the United States 24: 5 Candice Trummell was a duly elected Commissioner of Nye County 23 Commissioner 22 return for the performance of the official duties of County 21 c The duty not to receive compensation from private sources in 20 and 16 employment or economic opportunity which would tend 17 improperly to influence a reasonable person in the position of 19 discharge of the duties and functions of County Commissioner: 15 b The duty not to seek or accept any gift, service, favor, 18 County Commissioner to depart from the faithful and impartial 14 fraud, dishonesty, or self-enrichment; 13 office of County Commissioner impartially and free from deceit, 12 a The duty to exercise the responsibilities and obligations of the 11 but were not limited to, the following: 10 as a political body as well as to the citizens of Nye County individually, which duties included, 81, regard to the citizens of Nye County and each Commissioner owed the citizens of Nye 7 4 Each of the five County Commissioners held a position of trust with 9 County fiduciary and legal duties to provide honest services to the Nye County Commission 6 promulgation of ordinances and the issue of licenses 5 governed Nye County, Nevada, and regulated its business activities through the 3 3 The Nye County Commission ( Commission ) was a five-member body 4 of elected public officials (hereinafter County Commissioner(s) or Commissioner(s) ) who Case 206-cr-00100RCJ-RJJ Document 1 Filed 03/22/2006 Page 2o7

3 211 6 The State of Nevada and Nye County had authorized the operation cf I The Operation of Brothels in Nye County : 18 as the corner of Homestead Road and Silver Street and further described as Lot 8, Block 24, 241 Calvada 14 Property 22 large enough to allow for the operation of a brothel without violating the 300 yard rule Defendant RICHARDS planned to build and operate a brothel on the 21! 11 The Calvada 14 Property was subject to the Ordinance and was not 20 the Property ) 19 Calvada Unit 14, Pahrump, Nevada (hereinafter referred to as the Calvada 14 Property or Defendant RICHARDS owned land in Nye County at a location known 15 The Commission granted defendant RICHARDS license to operate as many as three 16 brothels 14 brothels in Nye County under the privilege of licenses granted to him by the Commission 13 9 Defendant RICHARDS was engaged in the business of operating 12 Richards and the Calvada 14 Property ii I of adoption [of this ordinancej (hereinafter, the 300 yard rule ) 10 (300) yards of any public street, road or highway, except for operations existing at the time 9 Ordinance states, n part: No [brothel] operation may be [liocated within three hundred 8 1 County Ordinance Section (hereinafter referred to as the Ordinance ) The 7 8 Among the ordinances restricting the operation of brothels was Nyc 6 brothels 5 of brothels and, from time to time, enacted ordinances that restricted the operation of 7 Among other things, the Commission issued licenses for the operation 4I 3i houses of prostitution, commonly referred to as brothels, within the borders of Nye County Case 206-cr-OQ1 Q0-RCJ-RJJ Document I Filed 03122/2006 Page 3 of 7

4 1 The Scheme It was further the purpose and object of the scheme to conceal the true 25L revised and corrupted Ordinance to the full Commission for a vote It was a part of the scheme and artifice to defraud that defendant 24 restrictions that prevented the building of a brothel on the Property, and to then advance the 231 and her public office to revise the Ordinance to benefit his business interests and remove any 22:1 the ways and means by which Commissioner Trummell would use her position of public trust 21 RICHARDS met with Commissioner Trummell at various times and places to plan and devise 19J The Manner and Means of the Scheme 1 8 RICHARDS, or the scheme, through a planned pattern of deceit, deception, and dishonesty 17 identities of any participants in the scheme and their relationships with defendant It was further the purpose and object of the scheme to conceal the true 15 and dishonesty 14 nature, scope and purpose of the scheme through a planned pattern of deceit, deception, 1 2: the citizens of Nye County of the honest services of their elected public officials 11 property and business advantages that would enrich defendant RICHARDS while defrauding It was further the purpose and object of the scheme to obtain money, 9 Commissioners citizens of Nye County of the honest services of their public officials; namely, the Nye County The purpose and object of the scheme was to defraud and deprive the 6 The Purpose and Object of the Scheme 5L brothel on the Calvada 14 Property and to otherwise benefit his business interests 4 Commission to enact a revision to the Ordinance in such a way as to allow him to build a 3h to devise, executed, and attempted to execute, a fraudulent scheme to cause the County 2 13 Defendant RICHARDS knowingly and intentionally devised, attempted Cise 206cr-001Q0-RCJ-RJJ Oocuin<mt 1 Filed 03(22/2006 Page 4 of 7

5 19 It was further a part of the scheme and artifice to defraud that on cr which he caused Commissioner Trummell to sign The memorandum stated falsely and her to use her position of public trust and her public office to revise the Ordinance and to 23 advance the revised and corrupted Ordinance to the full Commission for a vote 1 7 devised and used the artifice of a memorandum captioned as Memorandum of Scholarship 8 as a conduit through which to conceal payments of money to Commissioner Trummell 16, purpose of the payment of money to Commissioner Trummefl, defendant RICHARDS 12 public trust and her public office to revise the Ordinance and advance the revised and 15 August 15, 2005, and in an attempt to deceive others and to conceal the true nature and It was further part of the scheme and artifice to defraud that on or about 13t1 corrupted Ordinance to the full Commission for a vote 11 $4,000 in the form of a check in an attempt to influence her corruptly to use her position of 10 August 15, 2005, defendant RICHARDS met with Commissioner Trummell and paid her 7j RICHARDS devised and used, and attempted to use, the artifice of the Richards Family Trust 20 It was further part of the scheme and artifice to defraud that defendant 20 purpose of a scholarship when, in truth and in fact, the money was paid for the purpose of 19 deceptively that defendant RICHARDS paid $5,000 to Commissioner Trummell for the 5! and corrupted Ordinance to the full Commission for a vote 3 $1,000 in cash in an attempt to influence her corruptly to use her position of public trust and 2 about June 28, 2005, defendant RICHARDS met with Commissioner Trummell and paid her 4 her public office to revise the Ordinance to benefit RICHARDS and to advance the revised 9 21 It was further part of the scheme and artifice to defraud that on or about 21 influencing Commissioner Trummell in a corrupt fashion and in order to induce and influence Case 2 06-cr-0Q100-RCJ-RJJ Document I Fded 03122/2006 Page 5 of 7

6 2 RICHARDS communicated, and attempted to communicate, with other Commissioners in an 1 23 It was further part of the scheme and artifice to defraud that defendant 6 26 Nevada Utah, to Dulles, Virginia, and back to Nye County, 25 wire from Nye County, Nevada, to Windover, communication traveled by electronic signal over 24 the corrupted Ordinance and which Commissioner Trummell, which contained 231; COUNT DATE COMMUNICATION Two December Electronic Mail ( ) from Commissioner A to in Nye County, Nevada 22 in Washington, DC, and defendant RICHARDS One November 10, 2005 Telephone call between Commissioner Trummell 21 2O transmitted, by means of wire communication in interstate and foreign commerce, certain of the honest services of their elected public; officials, knowingly transmit, and cause to be writing, signs, signals, or sounds as follows: each other, did, for the purpose of executing the material scheme and artifice to defraud, as defendant herein, and others known and unknown to the Grand Jury, aided and abetted by described above, and for the purpose of depriving and defrauding the citizens of Nye County i 13 MAYNARD MARTIN RICHARDS, 12 of Nevada, On or about the dates indicated below, in the State and Federal District 1O forth herein 8 24 The Grand Jury charges and incorporates by reference the allegations 9 contained in paragraphs 1 through 23 as paragraph 24 of this Indictment as though fully set 7 (Fraud by Wire; Deprivation of Honest Services) 6 COUNTS ONEAND TWO 5 4 Commission 3 knowing attempt to advance the revised and corrupted Ordinance to a vote before the fud Cisc 2 06-cr RCJ-RJJ Document 1 Ftlod 03/22/2006 Page 6 of 7

7 3 A TRUE BILL: Case 2 06cr RCJRJJ Document 1 Filed 9322/2006 Page 7 of First Assistant United States Attorney United States Attorney 7 DANIEL G BOGDEN 6 5 FC REPERSON OF THE GRAND JURY IS, 4 2j DATED: this,21 day of March 2006 All in violation of Title 18, United States Code, Sections 1343, 1346, and 2

8 MAO Case 2:06-cr RCJRJJ Document 2 Filed 03122/2006 Page 1 of 1 PER 18 USC 3170 BY: []INFORMATION Matter Sealed: [] Li Juvenile DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION - IN US DISTRICT COURT [] INDICTMENT C Other than Juvenile Pre-indiclment Plea [3 Superseding [3 Defendant Added [3Indictment Information [] (3 Charges/Counts Added Name of District Courl andior Judge/Magistratii Location (City) UNITED STATES DISTRICT COURT DISTRICT OF NEVADA LAS VEGAS Divisional Office TERRIE MURRAY Name and Office of Person Furnishing tnformalion on Qus My DOther US Agency THIS FORM Phone No Name of Asst, U S Attorney STEVE MYHRE / KIMBERLY FRAYN (1 assigned) PROCEEDING Name of Complainant Agency, or Person (8 Title, if any) FBI - DEBORAH CALHOUN [3 person is awaiting trial in another Fede al or State Court (give name 0, court) CASE NO El USA vs Defendant: Address: Birth Date 2:G6-CR-100Q2 Interpreter Required Social Security Number a Dialect: jj S - MAYNARD MARTIN RICHARDS C DEFENDANT Male EJ Alien C] Female (if applicablei I [3 [3 this person/proceeding transferred train another district per (circle one) FRCrP 20, 21 or 40 Show District IhiS is a reprosecution of charges previously dismissed wriich were dismissed on motion of: [3 US Ally D Defense SHOW [3 this prosecution relates to a DOCKET NO 171 CU pending case invotving this same defendant (Notice of Related Case must still be Filed wth the Clerk) prior proceedings or appearance(s) before U S Magistrate Judge regarding this defendant were recorded under - - Place oil DISTRICT OF NEVADA o ferrse I County NYE JUDGE CASE NO Issue: Warrant 121 Summons Location Status: Arrest Dale or Date Transferred to Federal Custody U El Currently in Federal Custody Currently in State Custody Li Writ Required Li Currently on bond Li Fugitive Defense Counsel (if any): FPD [3 [J LEO FLANGAS CJA RETO Appointed on Target Letter This report amends AO 257 previously submitted OFFENSE CHARGED - USC CITATION - STATUTORY MAXIMUM PENALTIES - ADDITIONAL INFORMATION OR COMMENTS Total # of Counts 2 Set Title & Section/Offense Level IPelts I_/_Misdemeanor_=_3_I_Felony_=_4) Description of Offense Charged 18/1343, 1346 & 2 Fraud by Wire, Deprivation of Honest Services Count(s)

9 Case 2 O6-cr-OO1OORCJ-RJJ Document 3 Filed UNITED STATES DISTRICT DISTRICT OF NEVADA IN THE MATTER OF THE PARTIAL REPORTS OF THE REGULAR GRAND JURY THE March 17, 2005 TERM 5-01 ) ) DATE: March :15-1:20 pm PRESENT: The Honorable GEORGE W FOLEY, U S Magistrate Judge DEPUTY CLERK: LOla Abarca REPORTER Mary Howard UNITED STATES ATTORNE:Y: Kimberly Fravn PROCEEDINGS: Roll of the Regular Grand Jury is taken, with 19 members present which constitutes a quorum The foreperson of the Grand Jury presented its partial report and indictments On the motion of the United States Attorney, IT IS ORDERED that the said report and indictments be filed There is_q_ sealed indictment On the motion of the United States Attorney, IT IS ORDERED that the terms of release as to each defendant are fixed as indicated and that Bench Warrants and Summons issue where indicated 2:06-CR-098-RLH (RJJ) 2:06-CR-099-JCM (RJJ) J2:06-CR-1 00-RCJ (RJJ) 2:06-CR-1O1-RLH (LRL) 2:05-CR-352-PMP (GWF) SUPERSEDING LAMAR ANTONIO GANT MICHAEL RALPH NEWMAN FEDERAL - LOCAL MAYNARD MARTIN RICHARDS DEFENDANT & COUNSEL - LOCAL SILVINO MICHEL-TAPIA FEDERAL - LOCAL ANTONIO CASTRO-RODELAS FEDERAL - LOCAL WARRANT CUSTODY SUMMONS CUSTODY CUSTODY IT IS ORDERED that the Arraignment and Plea as to 2:06-CR-099-JCM (RJJ): 2:06-CR-101-RLH (LRL): shall be set on FridavMarch 31 8:30 am before Macustrate Judge Robert J Johnston in courtroom 3D IT IS FURTHER ORDERED that the Arraignment and Plea as to 2:05-cr-352-PMP (GWF) (SUPERSEDING) shall be set on Friday March 31, 8:30 am before Magistrate Judge ROBERT J JOHNSTON in courtroom 3D (TRIAL DATE SETFOR MAY j

10 Case 2:06-cr RCJ-RJJ Document 3 Filed 03/22/2006 Paqe 2 of 2 Page 2 March 22, 2006 GJ IT IS FURTHER ORDERED that the Arraignment and Plea as to 2:06-CR-100-RCJ (RJJ) shall be set on Friday April 7 6:30 am before Magistrate Judge ROBERT J JOHNSTON in courtroom 3D IT IS FURTHER ORDERED that the Arraignment and Plea as to the remaining case(s) will be held at the time of the initial appearance LANCE S WILSON, Clerk United States District Court Deputy Clerk

11 Case 2 06-cr-OO100-RCJ-RJJ Document 5 Filed UNITED STATES DISTRICT DISTRICT OF NEVADA (Amended to reflect correct filed stamp) IN THE MATTER OF THE PARTIAL ) REPORTS OF THE REGULAR GRAND JURY THE March 17, 2005 TERM 5-01 DATE:_ March :15-1:20 om PRESENT: The Honorable GEORGE W FOLEY, U S Magi DEPUTY CLERK: LiIb Abarc REPORTER UNITED STATES ATTORNEY: Kimberly Frayn PROCEEDINGS: Roll of the Regular Grand Jury is taken, with 19 members present quorum The foreperson of the Grand Jury presented its partial report and indictments On the motion of the United States Attorney, IT IS ORDERED that the said report and indictments be filed There iso sealed indictment On the motion of the United States Attorney, IT IS ORDERED that the terms of release as to each defendant are fixed as indicated and that Bench Warrants and Summons issue where indicated 2:06-CR-098-RLH (RJJ) LAMAR ANTONIO GANT WARRANT 2:06-CR-099-JCM (RJJ) MICHAEL RALPH NEWMAN FEDERAL - LOCAL CUSTODY 2:06-CR-i 00-RCJ (RJJ) MAYNARD MARTIN RICHARDS DEFENDANT&COUNSEL- LOCAL SUMMONS 2:06-CR-1O1-RLH (LRL) 2:05-CR-352-PMP (GWF) SUPERSEDING SILVINO MICHEL-TAPIA FEDERAL-LOCAL ANTONIO CASTRO-RODELAS FEDERAL - LOCAL CUSTODY CUSTODY IT IS ORDERED that the Arraignment and Plea as to 2:06-CR-099-JCM (RJJ); 2:06-CR-101-RLH (LRL): shall be set on Friday March 31 8:30 am before Magistrate Judge Robert J Johnston in courtroom 3D ROBERT IT IS FURTHER ORDERED that the Arraignment and Plea as to2:05-cr-352-pmp (GWF) (SUPERSEDING) shall be set on Friday March 31 8:30 am, before Magistrate Judge J JOHNSTON, in courtroom 3D (TRIAL DATE SET FOR MAY )

12 Cse 2 06-cr RCJRJJ Document 5 Filed 03/22/2006 Puge 2 ot2 GJ Page 2 March 22, 2006 IT IS FURTHER ORDERED that the Arraignment and Plea as to 2:06-CR-100-RCJ (RJJ) shall be set on Friday April 7 8:30 am, before Magistrate Judae ROBERT J JOHNSTON in courtroom 3D IT IS FURTHER ORDERED that the Arraignment and Plea as to the remaining case(s) will be held at the time of the initial appearance LANCE S WILSON, Clerk United States District Court Deputy Clerk