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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 FILED 2013 DEC -6 PH 4: 57 tLS. CCUPT WHRAL DIST. CF CAL! F.' LUS A:1GELES GY=---·----- UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA October 2013 Grand Jury UNITED STATES OF AMERICA, No. CR uC Plaintiff, v. CEDRIC EARL HUGHES, Defendant. I N D I C T M E N T [29 U.S.C. § 501(c): Embezzlement and Theft of Labor Union Assets; 18 U.S.C. § 1343: Wire Fraud.] The Grand Jury charges: INTRODUCTORY ALLEGATIONS 1. At all times material to this Indictment, United Union 20 Professionals ("UUP") was a labor organization engaged in an 21 industry affecting commerce within the meaning of the Labor 22 Management Reporting and Disclosure Act of 1959 and as defined in 23 Title 29, United States Code, Sections 402(a)-(c), (i), and (j). 24 2. From at least in or about March 2009 until on or about 25 June 22, 2010, defendant CEDRIC EARL HUGHES ("HUGHES") was an 26 officer and the Treasurer of UUP. 27 3. From at least in or about July 2009 until in or about 28 November 2010, defendant HUGHES was a signatory on Chase Bank Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 1 of 6 Page ID #:1

Cedric Hughes SEIU 721 Indictment Dec 2013

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Former Service Employees International Union (SEIU) Local 721 Treasurer Cedric Earl Hughes was indicted for 5 counts of wire fraud and a count of embezzlement.

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Page 1: Cedric Hughes SEIU 721 Indictment Dec 2013

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FILED

2013 DEC -6 PH 4: 57 CLEm~ tLS. ;J~STR:CT CCUPT

WHRAL DIST. CF CAL! F.' LUS A:1GELES

GY=---·-----

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

October 2013 Grand Jury

UNITED STATES OF AMERICA, No. CR uC Plaintiff,

v.

CEDRIC EARL HUGHES,

Defendant.

I N D I C T M E N T

[29 U.S.C. § 501(c): Embezzlement and Theft of Labor Union Assets; 18 U.S.C. § 1343: Wire Fraud.]

The Grand Jury charges:

INTRODUCTORY ALLEGATIONS

1. At all times material to this Indictment, United Union

20 Professionals ("UUP") was a labor organization engaged in an

21 industry affecting commerce within the meaning of the Labor

22 Management Reporting and Disclosure Act of 1959 and as defined in

23 Title 29, United States Code, Sections 402(a)-(c), (i), and (j).

24 2. From at least in or about March 2009 until on or about

25 June 22, 2010, defendant CEDRIC EARL HUGHES ("HUGHES") was an

26 officer and the Treasurer of UUP.

27 3. From at least in or about July 2009 until in or about

28 November 2010, defendant HUGHES was a signatory on Chase Bank

Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 1 of 6 Page ID #:1

Page 2: Cedric Hughes SEIU 721 Indictment Dec 2013

1 checking account number XXX-XXXX877-9 (the "UUP Chase Account")

2 and had possession of a debit card which could be used to

3 withdraw funds from the UUP Chase Account. During the time that

4 defendant HUGHES was the Treasurer of UUP, defendant HUGHES's

5 responsibilities included, among others, to make withdrawals from

6 the UUP Chase Account if those withdrawals were authorized by the

7 UUP Board.

8 4. These introductory allegations are hereby incorporated

9 by reference into each count of this Indictment as though fully

10 set forth therein.

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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 2 of 6 Page ID #:2

Page 3: Cedric Hughes SEIU 721 Indictment Dec 2013

1 COUNT ONE

2 [29 u.s.c. § 501(c)J

3 On or about May 26, 2010, in Los Angeles County, within the

4 Central District of California, and elsewhere, defendant CEDRIC

5 EARL HUGHES, while an officer of United Union Professionals

6 ("UUP"), knowingly and with intent to defraud, embezzled, stole,

7 and unlawfully and willfully abstracted and converted to his own

8 use and the use of others, the moneys, funds, securities,

9 property and other assets of UUP by depositing into his own

10 personal bank account without authorization from the UUP Board

11 Check Number 1570, dated May 26, 2010, from the UUP Chase

12 Account, in the approximate amount of $500.00.

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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 3 of 6 Page ID #:3

Page 4: Cedric Hughes SEIU 721 Indictment Dec 2013

1 COUNT TWO THROUGH SIX

2 [18 u.s.c. § 1343]

3 Beginning on or about May 26, 2010, and continuing through

4 on or about November 8, 2010, in Los Angeles County, within the

5 Central District of California, and elsewhere, defendant CEDRIC

6 EARL HUGHES ("HUGHES"), knowingly and with the intent to defraud,

7 devised, participated in, and executed a scheme to defraud United

8 Union Professionals ("UUP") as to material matters, and to obtain

9 money and property from UUP by means of material false and

10 fraudulent pretenses, representations, and promises, and the

11 concealment of material facts.

12 A.

13

SCHEME TO DEFRAUD

The fraudulent scheme operated, in substance, in the

14 following manner:

15 1. Defendant HUGHES made withdrawals from the UUP Chase

16 Account that were not authorized by the UUP Board, and which were

17 for his own personal use, by writing checks to himself which were

18 drawn on the UUP Chase Account, by making debit card purchases

19 using the debit card linked to the UUP Chase Account, and by

20 making cash withdrawals from the UUP Chase Account.

21 2. In order to conceal the withdrawals from officers at

22 UUP and to continue making withdrawals undetected, defendant

23 HUGHES knowingly and falsely told UUP officers that the checkbook

24 and other financial records for the UUP Chase Account had gone

25 missing when defendant HUGHES's truck was stolen.

26 3. In order to continue making withdrawals undetected,

27 defendant HUGHES failed to return the debit card for the UUP

28 Chase Account after he was asked to do so by UUP officers.

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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 4 of 6 Page ID #:4

Page 5: Cedric Hughes SEIU 721 Indictment Dec 2013

1 4 . In order to conceal the purpose of the checks that he

2 wrote to himself from the UUP Chase Account, defendant HUGHES

3 knowingly made false and misleading statements on the memo lines

4 of the checks.

5 5. As a result of the above-described fraudulent scheme,

6 defendant HUGHES caused approximately $15,193.75 in losses from

7 the UUP Chase Account.

8 B. USE OF THE WIRES

9 On or about the dates set forth below, in Los Angeles

10 County, in the Central District of California, and elsewhere,

11 defendant HUGHES, for the purpose of executing and attempting to

12 execute the above-described scheme to defraud, transmitted and

13 caused the transmission of the following items by means of wire

14 and radio communication in interstate and foreign commerce:

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16 Count

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20 THREE

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23 FOUR

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Date

05/26/2010

07/02/2010

07/12/2010

08/13/2010

Wire Transmission

Electronic request sent via interstate wire, requesting the transfer of $500.00 for payment of Check #1570 from the UUP Chase Account.

Electronic request sent via interstate wire, requesting the transfer of $1,013.49 for payment of Check #1577 from the UUP Chase Account.

Electronic request sent via interstate wire, requesting the transfer of $1,500.00 for payment of Check #1580 from the UUP Chase Account.

Electronic request sent via interstate wire, requesting the transfer of $1,500.00 for payment of Check #1596 from the UUP Chase Account.

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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 5 of 6 Page ID #:5

Page 6: Cedric Hughes SEIU 721 Indictment Dec 2013

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Count Date Wire Transmission

SIX 10/18/2010 Internet debit card purchase of airline tickets from Orbitz.com, in the amount of $573.19, using the UUP Chase Account, made via interstate wire communication.

ANDRE BIROTTE JR. United States Attorney

()v Cz.u ~ ROBERT E. DUGDALE Assistant United States Attorney Chief, Criminal Division

LAWRENCE S. MIDDLETON Assistant United States Attorney

A TRUE BILL

/6/ Foreperson

Chief, Public Corruption & Civil Rights Section

MARGARET L. CARTER Assistant United States Attorney Public Corruption and Civil Rights Section

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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 6 of 6 Page ID #:6